DAQ-2025-002456

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DAQC-405-25
Site ID 10238 (B1)

MEMORANDUM

TO: FILE – PACIFICORP ENERGY – Huntington Power Plant

THROUGH: Harold Burge, Major Source Compliance Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: April 29, 2025

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Emery County,
UT0000004901501001

INSPECTION DATE: April 16, 2025

SOURCE LOCATION: Huntington Canyon, Utah SR-31 (Deer Creek Road)

MAILING ADDRESS: Huntington Power Plant
P.O. Box 680
Huntington, Utah 84528

MAILING ADDRESS: PacifiCorp Headquarters
1407 West North Temple, Suite 330
Salt Lake City, UT 84116

SOURCE CONTACTS: Russ Willson, Sr. Environmental Analyst: Office: 435-687-4331
Cell: 435-609-6365, Email: [e-mail]

Terry Guthrie, Hunter and Huntington Plant Environmental Manager:
Office: 435-687-4334

OPERATING STATUS: Unit 1 operating
Unit 2 operating

PROCESS DESCRIPTION: The PacifiCorp Huntington Power Plant is a coal-fired steam electric
generating plant consisting of two boilers. Unit #1 is a 480 MW unit
constructed in October 1973; Unit #2 is a 480 MW unit that commenced
construction in April 1970. Bituminous and sub-bituminous coal is the
primary fuel source for the dry bottom, tangentially-fired boilers. Local
mines deliver coal via trucks. A newly installed, real time coal analyzer
continually checks the sulfur content and other constituents for BTU
values in the coal. Coal is combusted in a large furnace (each unit) and
heat is transferred to boiler tubes in the walls of the furnace. Sufficient
heat is generated to produce steam suitable for use in a steam turbine.
The turbine generators convert the steam to mechanical power to drive
the generator for the purpose of producing electricity. Fuel oil is used to
start up the boilers from a cold start and for boiler flame stabilization.

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To control emissions, the Huntington Power Plant uses baghouses, flue
gas desulphurization scrubbers (FGD), and low NOX burners for Units
#1 and Unit #2. Coal silos are controlled with dust collectors. Perimeter
roads and coal processing are covered by an approved fugitive dust
control plan.

APPLICABLE REGULATIONS:

Title V Operating Permit 1501001006, Dated November 21, 2024; last
revision November 21, 2024
NSPS (Part 60), A: General Provisions
NSPS (Part 60), D: Standards of Performance for Fossil-Fuel-Fired
Steam Generators for Which Construction is Commenced After August
17, 1971
NSPS (Part 60), Y: Standards of Performance for Coal Preparation and
Processing Plants
NSPS (Part 60), IIII: Standards of Performance for Compression Ignition
Internal Combustion Engines
(Part 64) Compliance Assurance Monitoring
MACT (Part 63), A: General Provisions
MACT (Part 63), ZZZZ: National Emissions Standards for Hazardous
Air Pollution for Stationary Reciprocating Internal Combustion Engines
MACT (Part 63), UUUUU: National Emissions Standards for Hazardous
Air Pollution: Coal and Oil- Fired Electric Utility Steam Generating
Units

SOURCE INSPECTION EVALUATION:
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 that are specifically designated as "State
Requirements". (R307-415-6b)

Status: This is a statement of fact and not an inspection item.

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)

Status: This is a statement of fact and not an inspection item.

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I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions 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 renewal 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 permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director 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 Director 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, reopened, 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 notification of planned changes or anticipated noncompliance shall not
stay any permit condition, except as provided under R307-415-7f(1) for minor permit
modifications. (R307-415-6a(6)(c))

Status: This is a statement of fact and not an inspection item.

I.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 front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit 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 reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered 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 permittee's right to operate unless a timely and complete
renewal application is submitted 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))

Status: This is a new permit issued on November 21, 2024.

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I.E Application Shield.

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

Status: This is a new permit issued on November 21, 2024.

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

Status: This is a statement of fact and not an inspection item.

I.G Permit Fee.

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

Status: In compliance – Emission inventory was paid as invoiced. Paid September 10, 2024.

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))

Status: This is a statement of fact and not an inspection item.

I.I Revision Exception.

No permit revision shall be required, under 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))

Status: This is a statement of fact and not an inspection item.

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:

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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 under 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 permit. (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 regulated 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 applicable 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))

Status: In compliance – Required records were made available and no claims of confidentiality were
made at time of the inspection.

I.K Certification.

Any application form, report, or compliance 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 certification 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)

Status: In compliance – Reports and certifications submitted appeared to have certification
statements and were signed by responsible officials.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. 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-reference 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 other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum, the
monitoring and related recordkeeping and reporting requirements in this 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;
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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 Provision 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 Director may require to determine the compliance status.

I.L.2 The permittee shall also submit all compliance certifications to the EPA, Region VIII, at the
following address or to such other address as may be required by the Director: (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

Status: In compliance – The annual compliance certification was received March 31, 2025 (due April
1, 2025), and deemed acceptable under a separate memo.

I.M Permit Shield.

I.M.1 Compliance with the provisions of this permit shall be deemed compliance with any
applicable requirements as of the date 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))

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I.M.2.d The ability of the Director 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))

Status: See section III of this permit.

I.N Reserved.

I.O Operational Flexibility.

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

Status: This is a statement of fact and not an inspection item.

I.P Off-permit Changes.

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

Status: This is a statement of fact and not an inspection item.

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.

Status: This is a statement of fact and not an inspection item.

I.R Permit Modifications.

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

Status: This is a statement of fact and not an inspection item.

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

I.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.
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I.S.1.b.3 The company or entity 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 Director 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 Director shall be notified promptly of any deviations from permit requirements
including those attributable to upset 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, shall 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
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 submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820
Phone: [phone]

I.S.3.b All reports, notifications or other submissions 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 Director:

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For annual compliance certifications:

Environmental Protection Agency, Region VIII
Office of Enforcement, Compliance and Environmental Justice
(mail code 8ENF)
1595 Wynkoop Street
Denver, CO 80202-1129

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

Environmental Protection Agency, Region VIII
Air Permitting and Monitoring Branch (mail code 8ARD-PM)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

Status: In compliance – Required records were made available at the time of the inspection.
Semi-annual monitoring reports have been submitted as required and are in the source’s file.

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 applicable 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 which this permit is due to
expire, unless the terms and conditions of this permit have been extended pursuant
to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

I.T.1.b The Director or EPA determines that this permit contains a material mistake or that
inaccurate statements were made in establishing the emissions standards or other
terms or conditions of this permit. (R307-415-7g(1)(c))

I.T.1.c EPA or the Director 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 existing 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 procedures as apply to initial
permit issuance and shall affect only those parts of this permit for which cause to reopen
exists. (R307-415-7g(2))

Status: This is a statement of fact and not an inspection item.
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I.U Inventory Requirements.

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

Status: In compliance – The annual 2024 emission inventory was submitted and shows in review in
the SLEIS database.

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))

Status: This is a statement of fact and not an inspection item.

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 Boiler Unit #1 (EU #1)
Nominal 480 MW gross capacity dry bottom tangentially-fired utility boiler fired on subbituminous and
bituminous coal using fuel oil during startup & flame stabilization. Equipped with low-NOx burners,
overfire air system, SO2 FGD scrubber and baghouse. NSPS Subpart D

II.A.3 Boiler Unit #2 (EU #2)
Nominal 480 MW gross capacity dry bottom tangentially-fired utility boiler fired on subbituminous and
bituminous coal using fuel oil during startup & flame stabilization. Equipped with low-NOx burners,
overfire air system, SO2 FGD scrubber and baghouse.

II.A.4 Coal Storage (EU #4)
Existing covered coal storage facility and open coal pile. No unit-specific applicable requirements.

II.A.5 Ash Landfill (EU #3)
Ash and sludge disposal. No unit-specific applicable requirements.

II.A.6 Unit #1 Cooling Towers (EU #5)
Unit #1 cooling towers for the circulating water system. No unit-specific applicable requirements.

II.A.7 Unit #2 Cooling Towers (EU #6)
Unit #2 cooling towers for the circulating water system. No unit-specific applicable requirements.

II.A.8 Coal Conveyors (EU #8)
Coal transfer on plant site.

II.A.9 Ash Haul Road (EU #10)
Ash haul road. No unit-specific applicable requirements.
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II.A.10 Unit #1 Emergency Generator (diesel engine) (EU #12)
Reciprocating internal combustion engine (RICE) emergency generator for Unit #1 rated at 1,155 hp and
manufactured in 1975. No unit-specific applicable requirements.

II.A.11 Unit #2 Emergency Generator (diesel engine) (EU #13)
RICE emergency generator for Unit #2 rated at 1,155 hp and manufactured in 1975. No unit-specific
applicable requirements.

II.A.12 Emergency Fire Pump (diesel engine) (EU #14)
RICE emergency fire pump (diesel engine) rated at 250 hp, constructed before June 12, 2006. Subject to
40 CFR 63 Subpart ZZZZ.

II.A.13 Coal Silo System Exhauster for Unit #1 (EU #17)
Coal silos for Unit #1 equipped with exhausters and dust collectors. No unit-specific applicable
requirements.

II.A.14 Coal Silo System Exhauster for Unit #2 (EU #18)
Coal silos for Unit #2 equipped with exhausters and dust collectors. No unit-specific applicable
requirements.

II.A.15 Distillate Fuel Oil Tanks (EU #20)
Three 70,000 gallon tanks (1973) and day tanks for the emergency diesel generators and fire pumps. No
unit-specific applicable requirements.

II.A.16 Lube Oil Storage Tanks (EU #21)
Two 10,000 gallon tanks constructed prior to 1976 that store lubricating oil including vents and associated
equipment. No unit-specific applicable requirements.

II.A.17 Oil Storage Area (EU #22)
Storage area for oil storage drums. No unit-specific applicable requirements.

II.A.18 Paved Access Road and Parking Area (EU #23)
Paved access road from the plant entrance to the administration building and parking area. No unit-
specific applicable requirements.

II.A.19 Cold Solvent Degreasing Operations (EU #24)
Bench-top cold degreasing units using Safety-Kleen, Simple Green, or other comparable degreasing
agents. No unit-specific applicable requirements.

II.A.20 Miscellaneous Electrical Equipment (EU #25)
Fugitive emission units including transformer insulating oil. No unit-specific applicable requirements.

II.A.21 Diesel Refueling Stations and Storage Tanks (EU #26)
Miscellaneous fuel storage tanks and associated dispensing equipment to refuel fleet vehicles and mobile
equipment. No unit-specific applicable requirements.

II.A.22 Gasoline Vehicle Refueling Station and Tanks (EU #27)
Miscellaneous gasoline storage tanks and associated dispensing equipment to refuel fleet vehicles and
mobile equipment. No unit-specific applicable requirements.

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II.A.23 Unit #1 Generator Seal Oil Air Detraining Tanks (EU #29-1)
Atmospheric vents from the seal oil air detraining tanks for Boiler Unit #1. No unit-specific applicable
requirements.

II.A.24 Unit #2 Generator Seal Oil Air Detraining Tanks (EU #29-2)
Atmospheric vents from the seal oil air detraining tanks for Boiler Unit #2. No unit-specific applicable
requirements.

II.A.25 Unit #1 Lube Oil Reservoirs (EU #30-1)
Lube oil reservoirs with vapor extractors for Boiler Unit #1. No unit-specific applicable requirements.

II.A.26 Unit #2 Lube Oil Reservoirs (EU #30-2)
Lube oil reservoirs with vapor extractors for Boiler Unit #2. No unit-specific applicable requirements.

II.A.27 Truck Mounted Vacuum System (EU #31)
Mobile truck mounted vacuum to clean up spilled material such as ash. No unit-specific applicable
requirements.

II.A.28 Ash Unloader for Feed Ash Silo (EU #32)
Equipment for unloading ash from Feed Ash silo and into trucks for transport to the ash landfill. No unit-
specific applicable requirements

II.A.29 Ash Unloader for Hi Carbon Ash Silo (EU #33)
Equipment for unloading ash from Hi Carbon Ash silo and into trucks for transport to the ash landfill. No
unit-specific applicable requirements

II.A.30 Emission Units Subject to 40% Opacity Limit (EU #34)
Units constructed prior to April 25, 1971 consisting of Boiler Unit #2 coal silo system exhauster, Unit #2
ash unloader, Unit #2 Generator Seal Oil Air Detraining Tanks, Unit #2 Lube Oil Reservoir, and the coal
reject handling system (EU #35).

II.A.31 Coal Reject Handling System (EU #35)
Material handling system that separates reject materials from the coal prior to pulverizing. No unit-
specific applicable requirements.

II.A.32 Central Accumulation Area (EU #36)
Area where hazardous waste is stored temporarily awaiting disposal. No unit-specific applicable
requirements.

II.A.33 Electro-hydraulic Control Reservoirs (EU #37)
Two 400 gallons tanks that store lubricating oil. No unit-specific applicable requirements.

II.A.34 Water Treatment Chemical Tanks (EU #38)
Tank storage including sulfuric acid, hydrochloric acid, lime, soda ash, sodium hydroxide, anti-scale, and
other miscellaneous water treatment chemicals. No unit-specific applicable requirements.

II.A.35 Paint Storage Areas (EU #40)
Various storage areas for sealed paint containers. No unit-specific applicable requirements.

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II.A.36 Coal handling and Blending Equipment (EU #41)
Includes truck unloading hopper enclosed on the sides with water sprays, covered conveyor belts with
enclosed transfer stations, radial stacker, Stamler feeder with water sprays, and screens. NPSP Subpart Y.

II.A.37 Unit #1 Coal Mill Reject Material Drops (EU #42)
Conveyor belt used to remove pyrites, tramp iron, and other reject materials from the Unit 1 coal mills.
NSPS Subpart Y.

II.A.38 Unit #2 Coal Mill Reject Material Drops (EU #43)
Conveyor belt used to remove pyrites, tramp iron, and other reject materials from the Unit 2 coal mills.
NSPS Subpart Y.

II.A.39 Real Time Coal Analyzer (EU #44)
Thermo Electron CQM coal analyzer with hopper and associated covered conveyor belts with enclosed
transfer stations equipped with dust closure seals and curtains at all loading points.

II.A.40 Unit #2 Fabric filters Group (EU #46)
Includes a total of three fabric filters, one fabric filters for each of the two lime/limestone day bin vents,
and one fabric filter for lime/limestone silo vent.

II.A.41 Water Pump Engine (EU # 47)
51 horsepower diesel engine used to drive the research farm's water pump and manufactured in 2012,
EPA Tier 4 certified, non-emergency non-black start RICE, with a displacement less than 30 liters per
cylinder, subject to 40 CFR 60 Subpart IIII.

II.A.42 Load-out Conveyor (EU# 48)
Gypsum load-out conveyor

II.A.43 Reverse Osmosis Soda Ash Silo (EU# 49)
Reverse osmosis soda ash silo equipped with bin vent.

II.A.44 Hi Carbon Ash Silo (EU# 50)
Hi carbon ash silo bin vent cartridge filter with 14,000 CFM fan

II.A.45 Feed Ash Silo (EU# 51)
Feed ash bin vent filter with 10,400 CFM fan and PTFE filter bags

Status: In compliance – No unapproved equipment was noted at the time of the inspection. The ash haul
road is now part of the landfill, it no longer exists (item II.A.9). II.A.13/14 are no longer in use, but
the company wants to keep it permitted. Painting is no longer conducted in-house but rather
contracted out. Therefore, paint is no longer stored on-site (item II.A.35). II.A.43 soda ash silo not
in use.

II.B.1 Conditions on permitted source (Source-wide).

II.B.1.a Condition:

Emissions from sources of fugitive dust shall be minimized. [Origin: DAQE-AN102380032-21].
[R307-205-5]

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II.B.1.a.1 Monitoring:

Adherence to the most recently approved fugitive dust control plan shall be monitored to
demonstrate that appropriate measures are being implemented to control fugitive dust.

II.B.1.a.2 Recordkeeping:

Records of measures taken to minimize fugitive dust shall be maintained as described in
Provision I.S.1 of this permit.

II.B.1.a.3 Reporting:

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

Status: In compliance – On April 1, 2025, PacifiCorp submitted an updated Fugitive Dust Control Plan
(FDCP) for its Huntington plant. The plan has been reviewed and deemed acceptable by email.

II.B.1.b Condition:

The permittee shall comply with the applicable requirements for recycling and emission reduction for
class I and class II refrigerants pursuant to 40 CFR 82, Subpart F - Recycling and Emissions Reduction.
[Origin: 40 CFR 82.150(b)]. [40 CFR 82 Subpart F]

II.B.1.b.1 Monitoring:

The permittee shall certify, in the annual compliance statement required in Section I of this
permit, its compliance status with the requirements of 40 CFR 82, Subpart F.

II.B.1.b.2 Recordkeeping:

All records required in 40 CFR 82, Subpart F shall be maintained consistent with the
requirements of Provision S.1 in Section I of this permit.

II.B.1.b.3 Reporting:

All reports required in 40 CFR 82, Subpart F shall be submitted as required. There are no
additional reporting requirements except as outlined in Section I of this permit.

Status: In compliance – Huntington Plant certifies that all refrigerants for the on-site chillers and air
conditioners are maintained and serviced by Rocky Mountain Mechanical.

II.B.1.c Condition:

Sulfur content of fuel oil shall be no greater than 0.85 lbs/MMBtu heat input unless otherwise specified in
this permit. [Origin: DAQE-AN102380032-21]. [R307-203-1(1)]

15
II.B.1.c.1 Monitoring:

The following specifications shall be recorded for each purchase of fuel: weight percent sulfur,
gross heating value (Btu per unit volume), and density. All specifications shall be ascertained in
accordance with methods of American Society for Testing and Materials.

Sulfur content in lbs/MMBtu shall be determined by the following equation:
S lbs/MMBtu = [(Weight percent sulfur/100) x Density (lb/gal)] / [(gross heating value (Btu/gal))
x (1 MMBtu/1,000,000 Btu)]

The permittee may obtain the above specifications by testing each purchase of fuel in accordance
with the required methods; by inspection of the specifications provided by the vendor for each
purchase of fuel; or by inspection of summary documentation of the fuel sulfur content from the
vendor, provided that the above specifications are available from the vendor for each purchase if
requested by the Director.

II.B.1.c.2 Recordkeeping:

The records required for monitoring shall be maintained as described by Provision S.1 in Section
I of this permit.

II.B.1.c.3 Reporting:

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

Status: In compliance – According to a monthly report provided by Sinclair Wyoming Refining Company
low sulfur fuel (ULSD) is delivered to the power plant.

II.B.1.d Condition:

The permittee shall not discharge into the atmosphere from any abrasive blasting any air contaminant for
a period or periods aggregating more than three minutes in any one hour which is a shade or density
darker than 40% opacity. [Origin: DAQE-AN102380032-21]. [R307-206]

II.B.1.d.1 Monitoring:

(a) Visible emissions shall be measured at least semi-annually using EPA Method 9. Visible
emissions from intermittent sources shall use procedures similar to Method 9, but the requirement
for observations to be made at 15 second intervals over a six-minute period shall not apply.

(b) Visible emissions from unconfined blasting shall be measured at the densest point of the
emission after a major portion of the spent abrasive has fallen out, at a point not less than five feet
nor more than twenty-five feet from the impact surface from any single abrasive blasting nozzle.

(c) An unconfined blasting operation that uses multiple nozzles shall be considered a single
source unless it can be demonstrated by the permittee that each nozzle, measured separately,
meets the emission and performance standards provided in R307-206-2 through 4.

(d) Visible emissions from confined blasting shall be measured at the densest point after the air
contaminant leaves the enclosure.
16
II.B.1.d.2 Recordkeeping:

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

II.B.1.d.3 Reporting:

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

Status: In compliance – Abrasive blasting is no longer conducted on-site. According to the source abrasive
blasting has not occurred in the on-site blast booth since 2015. Some abrasive blasting has been
done on-site by outside contractors using portable booths. When this occurs VEOs are conducted.

II.B.1.e Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this permit.
[Origin: DAQE-AN102380032-21]. [R307-201-3]

II.B.1.e.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
visible emissions other than steam are observed from an emission unit, an opacity determination
of that emission unit shall be performed by a certified observer within 24 hours of the initial
survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix
A, Method 9. If opacity exceeds the limit, maintenance shall be performed on the affected unit to
correct the problem.

II.B.1.e.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination shall be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit. If excess visible emission is indicated, a notation
of the resulting maintenance activity shall also be made in the log, and shall include the date of
the maintenance request, the date the maintenance was performed, the type of maintenance
performed, and the name of the person responsible for the maintenance.

II.B.1.e.3 Reporting:

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

Status: In compliance – The monthly VEO log was provided for review at the time of the inspection. The
log indicated that VEOs are conducted when emissions are observed, and that maintenance is
performed when required. All maintenance is logged in the maintenance tracking system.

17
II.B.1.f Condition:

At all times, including periods of startup, shutdown, and malfunction, the permittee shall, to the extent
practicable, maintain and operate any permitted plant equipment, 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. [Origin: DAQE-AN102380032-21]. [40 CFR 60 Subpart A, R307-401-8]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.f.2 Recordkeeping:

Permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with Provision I.S.1 of this permit.

II.B.1.f.3 Reporting:

In addition to the reports required in Section I of this permit, the following reports shall be
submitted:

(a) An annual projection of planned outages for steam boilers and associated pollution control
equipment shall be submitted to the Director not later than January 30 for each calendar year.

(b) Changes to the schedule of planned outages shall be reported to the Director within 96 hours
after the start of the outage or within 96 hours after the change to the planned outage schedule has
been realized.

(c) Maintenance outages shall be reported promptly or according to other applicable reporting
criteria in Provision I.S.

Status: In compliance – Maintenance activities are documented on a work order system in the SAP
database. The annual projection of planned outages, dated January 5, 2025, has been submitted
and is located in the source’s file. Outage changes are submitted as required. Outage notifications
have been submitted to the DAQ as required.

II.B.1.g Condition:

The plant-wide applicability limitation (PAL) of SO2 emission shall be no greater than 3,105 tons per year
and the PAL of NOx emission shall be no greater than 7,971 tons per year, based on 12-month rolling
total for the entire Huntington Plant from all point sources and fugitive emission. The PAL limits shall be
effective for ten years from August 6, 2019. If the permittee applies for PAL renewal, the permittee shall
submit application in accordance with 40 CFR Subpart 52.21(aa)(10) before the end of the PAL effective
date. The PAL shall remain effective until a revised approval order is issued. Once the PAL expires, the
permittee shall be subject to the requirements of 40 CFR Subpart 52.21(aa)(9). [Origin: AO DAQE-
AN102380032-21]. [R307-401-8, R307-405-21(1)]

18
State Only Requirements: (i) The annual NOx emission from the entire Huntington Plant from all point
and fugitive sources shall not exceed 6,604 tons/year based on 12-month rolling total. (ii) As of January
1, 2025, the annual NOx emission from the entire Huntington Plant from all point and fugitive sources
shall not exceed 6,422 tons/year based on 12-month rolling total. (iii) As of January 1, 2028, the annual
NOx emission from the entire Huntington Plant from all point and fugitive sources shall not exceed
6,240. tons/year based on 12-month rolling total. [SIP Section IX.H.23.e.i. through iii].
[SIP Section IX.H.23.e]

II.B.1.g.1 Monitoring:

SO2 and NOx emissions shall be monitored in accordance with 40 CFR part 52.21(aa)(12)(as
incorporated in R307-405-21(1)), Monitoring Requirements for PALs and as minimum it shall be
calculated by summing up emissions as follows:

(a) For Units #1 and #2 main boiler stacks, the permittee's reporting to EPA's Acid Rain
Emissions data base for NOx and SO2 in pounds per hour obtained from the boilers' CEM data
shall be used to calculate NOx and SO2 emission rates. All reported NOx and SO2 emissions,
including emissions associated with startups, shutdowns, and malfunctions, in pounds per hour,
shall be summed to get monthly total emissions.

(b) For emergency diesel-fired generators, emissions shall be calculated by multiplying the SO2
and NOx emission factors from the latest edition of EPA's emission factors compilation AP-42
and hours of operation. Records documenting generator usage shall be kept in a log, that shall
include the date the generator is used and the duration in hours of generator usage. The permittee
may rely upon hour meters to determine monthly diesel engine operational run times from which
to calculate monthly mass emissions.

(c) For research farm pump engine, emissions shall be calculated by multiplying the SO2 and NOx
emission factor from the latest edition of EPA's emission factors compilation AP-42 or Tier IV
emission factors and hours of operation. Records documenting generator usage shall be kept in a
log, that shall include date the pump is used and the duration in hours of pump usage. The
permittee may rely upon hour meters to determine monthly diesel engine operational run times
from which to calculate monthly mass emissions.

(d) The permittee shall calculate new 12-month NOx and SO2 emissions by the twentieth day of
each month using data from the previous 12 months. Records of emissions shall be kept for all
periods when the plant is in operation. [R307-405-21(1)]

II.B.1.g.2 Recordkeeping:

The results of monitoring shall be kept in accordance with Provision I.S.1 of this permit. In
addition, permittee shall comply with 40 CFR Subpart 52.21(aa)(13), Recordkeeping
Requirements for PALs. [R307-405-21(1)]

19
II.B.1.g.3 Reporting:

In addition to the reporting requirement described in Provision I.S.2 of this permit, the permittee
shall comply with 40 CFR Subpart 52.21(aa)(14), Reporting and notification requirements for
PALs. [R307-405-21(1)]

Status: In compliance – Plant-wide applicability limitations (PAL) for the rolling 12-month period ending
March 30, 2024, were:

Pollutant Limit (Tons) Actual Emissions (Tons)
Plant-wide SO2 3,105 1006
Plant-wide NOX/ 7,971 3771
Plant-wide NOX/SIP 6,604 3771

PAL Semi Annual Reports were received on time. The PAL limits are updated from the EPA
website after the quarterly submittals are posted. CEM quarterly reports are reviewed by the DAQ
CEM specialist.

II.B.2 Conditions on Boiler Unit #1 (EU #1).

II.B.2.a Condition:

Emissions of SO2 shall be no greater than 0.12 lb/MMBtu heat input (595 lb/hr) on 30-day rolling average
except during periods of startup, shutdown, maintenance/planned outage, or malfunction. [Origin: DAQE-
AN102380032-21, SIP Section IX.H.23.e.vi]. [40 CFR 60 Subpart D, R307-401-8, SIP IX.H.23.e]

II.B.2.a.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring system
for measuring SO2 emissions. The permittee shall determine compliance by periodic monitoring
using procedures in 40 CFR Part 60.45, Emission and fuel monitoring (subparagraphs (a), (e),
and (f)) and 60.13(e)).

(b) Each continuous emission monitoring system shall meet the requirements in 40 CFR Part 75,
Appendix A, Specification and Test Procedures as outlined below:
(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2 of
Appendix A of 40 CFR Subpart 75)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, may be used to fulfill the 40 CFR 60.13(d)(1) continuous emission monitor data quality
assurance requirements.

20
II.B.2.a.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices; and all
other information required by applicable portions of 40 CFR Part 60, Subparts A and D recorded
in a permanent form suitable for inspection. (40 CFR 60.7(f))

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative (40 CFR 60.7(b)). (origin: 40 CFR 60.7(b) & (f) and R307-415-6a(3)(B)(ii))).

II.B.2.a.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and (d) and 40
CFR 60.45(g), Reporting requirements. A data assessment report required by Appendix F,
Procedure 1, Section 7 to 40 CFR Part 60, or by 40 CFR 75 Appendix B, shall be submitted with
the excess emission report.

(b) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program.

(c) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director (permitting
authority) shall also be submitted to USEPA, Region VIII, if requested by EPA. (40 CFR 60.4
and 60.7(c))

(d) The reports required in paragraphs a, b, and c above are considered prompt notification of
permit deviations required in provision I.S.2.c of this permit if all information required by
provision I.S.2.c is included in the report. (origin: 40 CFR 60.4, 60.7(c), and 60.45(g)).

Status: In compliance – Reviewed records indicated SO2 0.05 lb/MMBtu and 168 lb/hr for the last 30-day
rolling average. CEM quarterly reports are submitted and reviewed by the DAQ CEM specialist.
The DAQ CEM coordinator oversees the state’s CEM program and determines compliance with
this condition.

II.B.2.b Condition:

Emissions of NOx shall be no greater than 0.26 lb/MMBtu heat input (1,290 lb/hr) on 30-day rolling
average except during periods of startup, shutdown, maintenance/planned outage, or malfunction. [Origin:
DAQE-AN102380032-21]. [40 CFR 60 Subpart D, R307-401-8]

II.B.2.b.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring system
for measuring nitrogen oxides emissions. The permittee shall determine compliance by periodic
monitoring using procedures in 40 CFR Part 60.45, Emission and fuel monitoring (subparagraphs
(a), (e), and (f)) and 60.13(e).

21
(b) Each continuous emission monitoring system shall meet the requirements in 40 CFR Part 75,
Appendix A, Specification and Test Procedures as outlined below:
(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2 of
Appendix A of 40 CFR Subpart 75)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, may be used to fulfill the 40 CFR 60.13(d)(1) continuous emission monitor data quality
assurance requirements.

II.B.2.b.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices; and all
other information required by applicable portions of 40 CFR Part 60, Subparts A and D recorded
in a permanent form suitable for inspection. (40 CFR 60.7(f))

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative (40 CFR 60.7(b)). (origin: 40 CFR 60.7(b) & (f) and R307-415-6a(3)(B)(ii))).

II.B.2.b.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and (d) and 40
CFR 60.45(g), Reporting requirements. A data assessment report required by Appendix F,
Procedure 1, Section 7 to 40 CFR Part 60, or by 40 CFR 75 Appendix B, shall be submitted with
the excess emission report.

(b) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program.

(c) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director (permitting
authority) shall also be submitted to USEPA, Region VIII, if requested by EPA. (40 CFR 60.4
and 60.7(c))

(d) The reports required in paragraphs a, b, and c above are considered prompt notification of
permit deviations required in provision I.S.2.c of this permit if all information required by
provision I.S.2.c is included in the report. (Origin: 40 CFR 60.4, 60.7(c), and 60.45(g)).

Status: In compliance – Reviewed records indicated NOx of 0.19 lb/MMBtu and 463 lb/hr for the last
30-day rolling average. CEM quarterly reports are submitted and reviewed by the DAQ CEM
specialist. The DAQ CEM coordinator oversees the state’s CEM program and determines
compliance with this condition.

22
II.B.2.c Condition:

Emissions of PM10 shall not be greater than 74 lb/hr except during periods of startup, shutdown,
maintenance/planned outage or malfunction. [Origin: DAQE-AN102380032-21]. [40 CFR 60 Subpart D,
R307-401-8].

II.B.2.c.1 Monitoring:

(a) Stack testing to show compliance with the PM emission limitations shall be performed as
specified below:
(1) Testing and Frequency. Emissions shall be tested each year. The source may also be tested at
any time if directed by the Director.
(2) Notification. The permittee shall provide a notification of the test date at least 30 days before
the test. A pretest conference shall be held, if directed by the Director, between the permittee, the
tester, and the Director.
(3) Method 5B shall be used for PM emission or other EPA-approved testing method, as
acceptable to the Director. The back half condensables shall also be tested using the referenced
method 202. The back half condensables shall not be used for compliance demonstration but shall
be used for inventory purposes.

(b) Opacity shall be used as a performance indicator of the baghouse to provide a reasonable
assurance of compliance with the PM emission limitation as specified below:
(1) Measurement Approach: Opacity is measured directly by COMS installed in each baghouse
outlet duct.
(2) Indicator Range:
(A) An excursion is defined as a 24-hour daily average opacity value greater than the baseline
level of 5%. Annually, the permittee should develop a new excursion level during annual
performance test using the modified method under 60.48Da(o)(2)(iii) and (iv) (NSPS Subpart
Da). The new value of the opacity excursion level shall be determined by averaging all of the 6-
minute average opacity values from the COMS measurements recorded during each of the test
run intervals conducted for the performance test plus 2.5 percent, or a total opacity value of 5.0%,
whichever is greater.
(B) Excursions trigger a baghouse inspection, corrective actions and a reporting requirement. The
permittee must initiate investigation of the relevant equipment and control systems within 24
hours of the first discovery of the high opacity incident and take the appropriate corrective action
as soon as practicable to adjust control settings or repair equipment to reduce the measured 24-
hour average opacity to a level below the baseline opacity level. If the measured 24-hour average
opacity remains at a level greater than the opacity baseline level after seven boiler operating days,
a new particulate matter performance test will be conducted to establish a new opacity baseline
value. This new performance test will be conducted within 60 days of the date that the measured
24-hour average opacity was first determined to exceed the baseline opacity level unless a waiver
is granted by the Director. (40 CFR 60.8Da(o)(2)(iv) and (vi))
(3) Performance Criteria:
(A) Data Representativeness: Measurements made by COMS shall provide a direct indicator of
the baghouse performance. COMS shall be installed and operated in accordance with 40 CFR
Part 60, Appendix B, Performance Specification 1 and R307-170.
(B) QA/QC Practices and Criteria: COMS shall be operated, calibrated, and maintained to meet
40 CFR 60, Appendix B, Performance Specification 1.
(C) Monitoring Frequency: Opacity shall be monitored continuously with opacity values
averaged every minute.

23
(D) Data Collection Procedure: Opacity data shall be recorded and stored electronically.
(E) Averaging Period: Use continuous opacity data to calculate 6-minute averages and the 6-
minute averages to calculate the 24-hour daily average opacity.

II.B.2.c.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,

(a) The permittee shall maintain a file of all stack testing and all other information required by
permit provision I.S.1.

(b) The permittee shall maintain a file of all COMS measurements, including performance testing
measurements, all COMS performance evaluations, all COMS calibration checks, all COMS
adjustments and maintenance, and all other information required by applicable portions of 40
CFR Part 60, Subparts A recorded in a permanent form suitable for inspection. (40 CFR 60.7(f))

(c) The permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40 CFR 64
(such as data used to document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions). Instead of paper records, the permittee may maintain records
on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche,
provided that the use of such alternative media allows for expeditious inspection and review, and
does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b))

(d) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; or any malfunction of the air pollution control
equipment.

II.B.2.c.3 Reporting:

(a) The monitoring report required in Provision I.S.2 of this permit shall include, at a minimum,
the following information, as applicable:

(1) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;

(2) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and span
or other daily calibration checks, if applicable).

24
(b) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status.

Status: In compliance – Montrose Air Quality Services conducted the stack tests for Unit #1 on April 4,
2024:
*The Unit 1 emission limit references PM10. However, PM10 sampling cannot be
performed on the stack due to the presence of water droplets. The total PM concentration is
used to show compliance with the PM10 limit. CAM information is submitted with the I.S.2
six-month reports.

Pollutant Limits (lb/hr) DAQ Results (lb/hr) Test Results (lb/hr)
PM10* 74 50 50

II.B.2.d Condition:

Visible emissions shall be no greater than 20 percent opacity (six-minute average) except for one six-
minute period per hour of not more than 27 percent opacity and except during periods of start-up,
shutdown, maintenance/planned outage, or malfunction. [Origin: DAQE-AN102380032-21]. [40 CFR 60
Subpart D, R307-401-8]

II.B.2.d.1 Monitoring:

(a) The permittee shall determine compliance with the visible emission limit by a continuous
opacity monitoring (COM) system installed and operated in accordance with 40 CFR 60.45,
Emission and fuel monitoring (subparagraphs (a) and (g)) and 60.13(e).

(b) Each continuous opacity monitoring system shall meet the following quality assurance
requirements:

(1) 40 CFR 60.13, Monitoring requirements (subparagraphs (d) and (f))
(2) 40 CFR Part 60, Appendix B, Performance Specification 1, Specifications and Test
Procedures for Opacity Continuous Emission Monitoring Systems in Stationary Sources
(3) R307-170, Continuous Emission Monitoring System Program.

II.B.2.d.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices; and all
other information required by applicable portions of 40 CFR Part 60, Subparts A and D recorded
in a permanent form suitable for inspection. (40 CFR 60.7(f))

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative (40 CFR 60.7(b)). (origin: 40 CFR 60.7(b) & (f) and R307-415-6a(3)(B)(ii)))

25
II.B.2.d.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and (d) and 40
CFR 60.45(g), Reporting requirements. A data assessment report required by Appendix F,
Procedure 3 to 40 CFR Part 60, or by 40 CFR 75 Appendix B, shall be submitted with the excess
emission report.

(b) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program.

(c) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director (permitting
authority) shall also be submitted to USEPA, Region VIII, if requested by EPA. (40 CFR 60.4
and 60.7(c))

(d) The reports required in paragraphs a, b, and c above are considered prompt notification of
permit deviations required in provision I.S.2.c of this permit if all information required by
provision I.S.2.c is included in the report. (origin: 40 CFR 60.4, 60.7(c), and 60.45(g)).

Status: In compliance – A COM is installed on Unit #1. Quarterly excess emission reports and quarterly
compliance reports are submitted and reviewed by the DAQ CEM specialist. Com readings during
the inspection were 6-minute average of 2% and 24 hour average of 1%. No visible emissions were
noted during the inspection.

II.B.2.e Condition:

Emission of CO shall be no greater than 0.34 lb/MMBtu (1,686 lb/hr) based on a 30-day rolling average
except during periods of startup, shutdown, maintenance/planed outage, or malfunction.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.2.e.1 Monitoring:

The emission of CO shall be monitored by continuous emission monitoring system (CEMS). The
permittee shall calibrate, maintain, and operate a CEMS as required by R307-170 to determine
compliance with CO concentration. The quality assurance requirements of R307-170, Continuous
Emission Monitoring Systems Program, shall be used to fulfill data quality assurance
requirements. The hourly average of CO emissions during boiler operating hours shall be
calculated every hour and the daily average shall be calculated using the hourly average data. The
daily average of CO emission shall be used to calculate 30-day rolling average.

II.B.2.e.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,

(a) The permittee shall maintain a file of all stack testing and all other information required by
permit provision I.S.1 in a permanent form suitable for inspection.

26
(b) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices; and all
other information required by applicable requirements of R307-170.

II.B.2.e.3 Reporting:

In addition to the reports required in Section I of this permit, the following reports shall be
submitted:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program.

(b) The reports required in paragraph a above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – The on-site daily air report indicated CO of 0.11 lb/MMBtu and 343 lb/hr for the
last 30-day rolling average, for Unit #1. A CO monitor is installed and operated. Quarterly reports
are submitted and reviewed by DAQ’s CEM specialist. This condition pertains to the state CEM
program which is evaluated by the DAQ CEM specialist.

II.B.2.f Condition:

At all times the permittee must operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the EPA Administrator
which may include, but is not limited to, monitoring results, review of operation and maintenance
procedures, review of operation and maintenance records, and inspection of the source. [Origin: 40 CFR
63.10000(b)]. [40 CFR 63 Subpart UUUUU]

II.B.2.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.f.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.10032(a) through (j), as applicable.
[40 CFR 63.10032]

The permittee shall document activities performed to assure proper operation and maintenance.

Records shall be maintained in accordance with 40 CFR 63.10033 and
Provision I.S.1 of this permit.

27
II.B.2.f.3 Reporting:

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

Status: In compliance – Maintenance activities are documented on a work order system in the SAP
database. Records and inspection of the site show that the Huntington Plant operates and maintains
Unit #1 in a manner consistent with safety and good air pollution control practices for minimizing
emissions. A preventative maintenance plan is in place and activities are documented.

II.B.2.g Condition:

(1) The permittee shall comply with the following requirements for each affected emission unit:

(a) The permittee shall comply with each emission limit and work practice standard in Tables 2 and 3 of
40 CFR 63 Subpart UUUUU for each EGU at the source, except as provided in paragraph (1)(d) of this
section ;

(b) The permittee shall comply with each operating limit in Table 4 of 40 CFR 63 Subpart UUUUU for
each affected EGU at the source;

(c) The permittee shall comply the emission and operating limits at all times except during periods of
startup and shutdown as defined in 40 CFR 63.10042. The permittee shall meet the work practice in Table
3 of 40 CFR 63 Subpart UUUUU during periods of startup, or shutdown as defined in 40 CFR 63.10042;

(d) The permittee may use emissions averaging as described in 40 CFR 63.10009 as an alternative to
meeting the requirements in (1)(a) of this section for filterable PM, SO2, HF, HCl, non-Hg HAP metals,
or Hg on an EGU-specific basis.

(2) As provided in 40 CFR 63.6(g), the Administrator may approve use of an alternative to the work
practice standards in this section;

(3) The permittee may use the alternate SO2 limit in Table 2 of 40 CFR 63 Subpart UUUUU only if the
affected coal-fired EGU:

(a) Has a system using wet or dry flue gas desulfurization technology and SO2 CEM installed on the unit;
and
(b) At all times, the permittee operates the wet and dry flue gas desulfurization technology installed on
the unit consistent with 40 CFR 63.10000(b)

[Origin: 40 CFR 63.9991, 63.10000(a), 63.10009, tables 2, 3, and 4]. [40 CFR 63 Subpart UUUUU]

II.B.2.g.1 Monitoring:

(a) General Compliance Requirement:

(1) The permittee shall conduct the initial performance testing for all pollutants in accordance
with 40 CFR 63.10000(c)(1)(i) through (vi), as applicable, to demonstrate compliance with the
applicable emission limits.

28
(2) If a continuous monitoring system (CMS) is used to demonstrate compliance with any
applicable emission limit, the permittee shall develop a site-specific monitoring plan for the CMS
in accordance to 40 CFR 63.10000(d)(1) through (5), as applicable, and submit this site-specific
monitoring plan, if requested, at least 60 days before the initial performance evaluation (where
applicable) of CMS. The permittee shall operate and maintain the CMS according to the site-
specific monitoring plan.

(3) The permittee shall perform periodic tune-up of EGU in accordance with 40 CFR
63.10021(e).

(b) Testing Requirements: the compliance performance test shall be conducted according to the
procedures described in 40 CFR 63.10005 for the initial compliance and according to the
procedures described in 40 CFR 63.10006 for continuous compliance. The permittee shall
conduct all required performance tests according to 40 CFR 63.10007

(c) Continuous Compliance:

(1) The permittee shall monitor and collect data according to 40 CFR 63.10020(b) through (d)
and the site-specific monitoring plan required by 40 CFR 63.10000(d), as applicable.

(2) The permittee shall demonstrate continuous compliance with each emissions limit, operating
limit, and work practice standard in Tables 2 through 4 to the Subpart UUUUU of 40 CFR 63 that
applies to the permittee, according to the monitoring specified in Tables 6 and 7 to Subpart
UUUUU of 40 CFR 63, and paragraphs 40 CFR 63.10021 (b) through (g).

(d) Alternate compliance monitoring for the EGU qualified as low emitting EGU (LEE):

The permittee may pursue the LEE option for filterable PM and Hg for the qualified LEE which
meets the requirement of 40 CFR 63.10005(h)

(1) Filterable PM: The permittee shall conduct a performance test at least once every 36 calendar
months to demonstrate continued LEE status.

(2) Hg: The permittee shall conduct a 30-day performance test using method 30B at least once
every 12 calendar months to demonstrate continued LEE status. (e) The permittee shall comply
with the applicable general provisions in 40 CFR 63.1-15 as identified in Table 9 of 40 CFR 63
Subpart UUUUU. [40 CFR 63.10040].

II.B.2.g.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.10032(a) through (j), as applicable.
[40 CFR 63.10032]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 9 of 40 CFR 63 Subpart UUUUU. [40 CFR 63.10040]

Records shall be maintained in accordance with 40 CFR 63.10033 and Provision I.S.1 of this
permit.

29
II.B.2.g.3 Reporting:

The permittee shall submit an Initial Notification described in 40 CFR 63.10030 (b) and (c), as
applicable.

The permittee shall submit a Notification of Compliance Status summarizing the results of the
initial compliance demonstration according to 40 CFR 63.9(h)(2)(ii). The Notification of
Compliance Status report must contain all the information specified in 40 CFR 63.10030(e)(1)
through (7), as applicable.

The permittee shall submit the compliance report as required in 40 CFR 63.10031. The
compliance report shall contain the requirements as described in 40 CFR 63.10031(c)(1) through
(4) and Table 8 of 40 CFR 63 Subpart UUUUU semiannually according to the requirements in 40
CFR 63.10031(b).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 9 of 40 CFR 63 Subpart UUUUU. [40 CFR 63.10040]

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

Status: In compliance – Huntington’s Unit #1 is an existing coal-fired EGU. Huntington has a unit-single
stack configuration [40 CFR 63.10010(a)(1)]. CEMS are installed in the stack at locations
downstream of all emissions control devices, where the pollutant and diluents concentrations are
representative of the emissions that exit to the atmosphere.

Mercury LEE status was achieved in 2016. Testing was performed on March 26, 2024, through
April 30, 2024, to demonstrate compliance with the emission limits found in Title V permit
conditions. The DAQ-calculated test results are:

DAQ result Limit
0.01 lb/TBTU 1.2 lb/TBTU
0.5 lb/yr 29 lb/yr

PM LEE status was acknowledged by the DAQ on April 3, 2018. MATS PM test frequency is
reduced to once every 36 months. Last testing was completed March 19, 2024, with results of 0.010
lb/MMBtu (0.030 limit) and 0.10 lb/MW-hr (0.30 limit).

Huntington has converted to the neural network combustion optimization software. Thus, tune-ups
are due every 48 months. Unit #1 initial work practice standards were met on February 6, 2015.
Last Unit #1 tune-up was conducted on September 5, 2020, and December 14, 2022. Records were
available to confirm compliance.

The semi-annual compliance report required by Subpart UUUUU received on January 4, 2025, and
August 4, 2024. Quarterly reports are submitted and reviewed by DAQ’s CEM specialist.

II.B.2.h Condition:

Emissions of mercury shall be no greater than 6.5x10-7 lbs/MMBtu input based on an annual averaging
period beginning January 1 and ending December 31. [Origin: R307-424-4]. [R307-424-4]

30
II.B.2.h.1 Monitoring:

(a) The permittee shall install, calibrate, maintain and operate a continuous monitoring system for
measuring emissions in accordance with Appendix A to 40 CFR 63 Subpart UUUUU.

(b) Each continuous emission monitoring system shall meet the quality assurance requirements of
R307-170, Continuous Emission Monitoring Systems Program and Appendix A to 40 CFR 63
Subpart UUUUU.

(c) Alternate compliance monitoring for the EGU qualified as low emitting EGU (LEE): the
permittee may pursue the LEE option for the qualified LEE which meets the requirement of 40
CFR 63.10005(h). The permittee shall conduct a 30-day performance test using method 30B at
least once every 12 calendar months to demonstrate continued LEE status.

II.B.2.h.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices.

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.

II.B.2.h.3 Reporting:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program and comply with the reporting provision in
Appendix A to 40 CFR 63 Subpart UUUUU.

(b) Upon completion of each year's fourth quarterly report, an assessment shall be made for the
entire calendar year and reported to the Director within 30 days.

(c) The reports required in paragraph (a) above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – Unit #1 2024 mercury emission rate was 1.07 E-8 lbs/MMBtu which is less than the
limit of 6.5 E-7 lb/MMBtu. Mercury CEMS were discontinued upon achievement of Mercury LEE
status in 2016. The 12-calendar month Hg LEE test was completed on March 19, 2024. Outage
reports are submitted and maintained on-site. CEM unavailability reports are submitted with
MATS semiannual reports. The 2024 annual mercury assessment report was sent to DAQ as
required.

31
II.B.3 Conditions on Boiler Unit #2 (EU #2).

II.B.3.a Condition:

Visible emissions shall be no greater than 20 percent opacity (six-minute average) except for one six-
minute period per hour of not more than 27 percent opacity and except during periods of start-up,
shutdown, maintenance/planned outage, or malfunction. [Origin: DAQE-AN102380032-21].
[R307-201-1]

II.B.3.a.1 Monitoring:

(a) The permittee shall determine compliance with the visible emission limit by a continuous
opacity monitoring (COM) system installed and operated in accordance with 40 CFR 60.45,
Emission and fuel monitoring (subparagraphs (a) and (g)) and 60.13(e).

(b) Each continuous opacity monitoring system shall meet the following quality assurance
requirements:

(1) 40 CFR 60.13, Monitoring requirements (subparagraphs (d) and (f))
(2) 40 CFR Part 60, Appendix B, Performance Specification 1, Specifications and Test
Procedures for Opacity Continuous Emission Monitoring Systems in Stationary Sources
(3) R307-170, Continuous Emission Monitoring System Program.

II.B.3.a.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices;

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.

II.B.3.a.3 Reporting:

In addition to the reports required in Section I of this permit, the following reports shall be
submitted:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program.

(b) The reports required in paragraph a above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – A COM is installed on Unit #2. Quarterly access emission reports and quarterly
compliance reports are submitted and reviewed by the DAQ CEM specialist. Review of the daily air
report indicated opacity of 1% for six minute and 30-day averages.

32
II.B.3.b Condition:

Emissions of SO2 shall be no greater than 0.12 lb/MMBtu heat input for any 24-hour block average
except during periods of startup, shutdown, maintenance/planned outage, or malfunction. [Origin: DAQE-
AN102380032-21, SIP Section IX.H.23.e.vii]. [R307-401-8, SIP Section H.23.e.vii]
.
II.B.3.b.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring system
for measuring SO2 emissions. The permittee shall determine compliance by periodic monitoring
using procedures in 40 CFR Part 60.45, Emission and fuel monitoring (subparagraphs (a), (e),
and (f)) and 60.13(e).

(b) Each continuous emission monitoring system shall meet the requirements in 40 CFR Part 75,
Appendix A, Specification and Test Procedures as outlined below:
(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2 of
Appendix A of 40 CFR Subpart 75)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, may be used to fulfill the 40 CFR 60.13(d)(1) continuous emission monitor data quality
assurance requirements.

II.B.3.b.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices;

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.

II.B.3.b.3 Reporting:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program and comply with the reporting provisions in
40 CFR 75 Subpart G, and all the reporting provisions contained in Section I of this permit.

33
(b) The reports required in paragraph a above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – Reviewed records indicated a SO2 24-hour average of 0.04 lb/MMBtu. CEM
quarterly reports are submitted and reviewed by the DAQ CEM specialist. The DAQ CEM
coordinator oversees the state’s CEM program and determines compliance with this condition.

II.B.3.c Condition:

Emissions of NOx shall be no greater than 0.26 lb/MMBtu heat input for any 30 day rolling average
except during periods of startup, shutdown, maintenance/planned outage, or malfunction.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.3.c.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring system
for measuring nitrogen oxides emissions. The permittee shall determine compliance by periodic
monitoring using procedures in 40 CFR Part 60.45, Emission and fuel monitoring (subparagraphs
(a), (e), and (f)) and 60.13(e)).

(b) Each continuous emission monitoring system shall meet the requirements in 40 CFR Part 75,
Appendix A, Specification and Test Procedures as outlined below:
(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2 of
Appendix A of 40 CFR Subpart 75)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The quality assurance requirements of R307-170, Continuous Emission Monitoring Systems
Program, may be used to fulfill the 40 CFR 60.13(d)(1) continuous emission monitor data quality
assurance requirements.

II.B.3.c.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices;

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.

34
II.B.3.c.3 Reporting:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program and comply with the reporting provisions in
40 CFR 75 Subpart G, and all the reporting provisions contained in Section I of this permit.

(b) The reports required in paragraph a above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – Reviewed records indicated NOx 30-day average of 0.16 lb/MMBtu. CEM
quarterly reports are submitted and reviewed by the DAQ CEM specialist. The DAQ CEM
coordinator oversees the state’s CEM program and determines compliance with this condition.

II.B.3.d Condition:

Emissions of particulate matter (PM) shall be no greater than 70 lb/hr except during periods of startup,
shutdown, maintenance/planned outage, or malfunction. [Origin: DAQE-AN102380032-21].
[R307-401-8]

II.B.3.d.1 Monitoring:

(a) Stack testing to show compliance with the PM emission limitations shall be performed as
specified below:

(1) Testing and Frequency. Emissions shall be tested each year. The source may also be tested at
any time if directed by the Director.
(2) Notification. The permittee shall provide a notification of the test date at least 30 days before
the test. A pretest conference shall be held, if directed by the Director, between the permittee, the
tester, and the Director.
(3) Compliance determination procedures and stack test methods shall be performed according to
40 CFR 60 Subpart D, 60.46.

(b) Opacity shall be used as a performance indicator of the baghouse to provide a reasonable
assurance of compliance with the PM emission limitation as specified below:

(1) Measurement Approach:
Opacity is measured directly by a COM installed in the baghouse outlet duct.

(2) Indicator Range:
(A) An excursion is defined as a 24-hour daily average opacity value greater than the baseline
level of 5%. Annually, the permittee should develop a new excursion level during annual
performance test using the modified method under 60.48Da(o)(2)(iii) and (iv) (NSPS Subpart
Da). The new value of the opacity excursion level shall be determined by averaging all of the 6-
minute average opacity values from the COMS measurements recorded during each of the test
run intervals conducted for the performance test plus 2.5 percent, or a total opacity value of 5.0%,
whichever is greater.

35
(B) Excursions trigger a baghouse inspection, corrective actions and a reporting requirement. The
permittee must initiate investigation of the relevant equipment and control systems within 24
hours of the first discovery of the high opacity incident and take the appropriate corrective action
as soon as practicable to adjust control settings or repair equipment to reduce the measured 24-
hour average opacity to a level below the baseline opacity level. If the measured 24-hour average
opacity remains at a level greater than the opacity baseline level after seven boiler operating days,
a new particulate matter performance test will be conducted to establish a new opacity baseline
value. This new performance test will be conducted within 60 days of the date that the measured
24-hour average opacity was first determined to exceed the baseline opacity level unless a waiver
is granted by the Director. (40 CFR 60.8Da(o)(2)(iv) and (vi))

(3) Performance Criteria:
(A) Data Representativeness: Measurements made by COM shall provide a direct indicator of the
baghouse performance. COM shall be installed and operated in accordance with 40 CFR Part 60,
Appendix B, Performance Specification 1 and R307-170.
(B) QA/QC Practices and Criteria: COM shall be operated, calibrated, and maintained to meet 40
CFR 60, Appendix B, Performance Specification 1.
(C) Monitoring Frequency: Opacity shall be monitored continuously with opacity values
averaged every minute.
(D) Data Collection Procedure: Opacity data shall be recorded and stored electronically.
I Averaging Period: Use continuous opacity data to calculate 6-minute averages and the 6-minute
averages to calculate the 24-hour daily average opacity.

II.B.3.d.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,

(a) The permittee shall maintain a file of all stack testing and all other information required by
permit provision I.S.1.

(b) The permittee shall maintain a file of all continuous opacity monitor (COM) measurements,
including performance testing measurements, all COM performance evaluations, all COM
calibration checks, all COM adjustments and maintenance, and all other information required by
applicable portions of 40 CFR Part 60, Subparts A and Db recorded in a permanent form suitable
for inspection. (40 CFR 60.7(f))

(c) The permittee shall maintain a file of the occurrence and duration of any excursion, corrective
actions taken, and any other supporting information required to be maintained under 40 CFR 64
(such as data used to document the adequacy of monitoring, or records of monitoring
maintenance or corrective actions). Instead of paper records, the permittee may maintain records
on alternative media, such as microfilm, computer files, magnetic tape disks, or microfiche,
provided that the use of such alternative media allows for expeditious inspection and review, and
does not conflict with other applicable recordkeeping requirements. (40 CFR 64.9(b))

(d) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; or any malfunction of the air pollution control
equipment.

36
II.B.3.d.3 Reporting:

(a) The monitoring report required in Provision I.S.2 of this permit shall include, at a minimum,
the following information, as applicable:

(1) Summary information on the number, duration and cause (including unknown cause, if
applicable) of excursions or exceedances, as applicable, and the corrective actions taken;

(2) Summary information on the number, duration and cause (including unknown cause, if
applicable) for monitor downtime incidents (other than downtime associated with zero and span
or other daily calibration checks, if applicable).

(b) The results of stack testing shall be submitted to the Director within 60 days of completion of
the testing. Reports shall clearly identify results as compared to permit limits and indicate
compliance status.

Status: In compliance – Montrose Air Quality Services conducted the stack tests for Unit #2 on April 9,
2024. The DAQ-calculated test results (DAQC-472-24) were:

Pollutant Limits (lb/hr) DAQ Results (lb/hr) Test Results (lb/hr)
PM 70 49.0 48.3

II.B.3.e Condition:

At all times the permittee must operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. Determination of whether such operation and
maintenance procedures are being used will be based on information available to the EPA Administrator
which may include, but is not limited to, monitoring results, review of operation and maintenance
procedures, review of operation and maintenance records, and inspection of the source. [Origin: 40 CFR
63.10000(b)].
[40 CFR 63 Subpart UUUUU]

II.B.3.e.1 Recordkeeping:

Records required for this permit condition will serve as monitoring.

II.B.3.e.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.10032(a) through (j), as applicable.
[40 CFR 63.10032]

The permittee shall document activities performed to assure proper operation and maintenance.

Records shall be maintained in accordance with 40 CFR 63.10033 and
Provision I.S.1 of this permit.

37
II.B.3.e.3 Reporting:

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

Status: In compliance – Maintenance activities are documented on a work order system in the SAP
database. Records and inspection of the site show that the Huntington Plant operates and maintains
Unit #2 in a manner consistent with safety and good air pollution control practices for minimizing
emissions. A preventative maintenance plan is in place and activities are documented.

II.B.3.f Condition:

(1) The permittee shall comply with the following requirements for each affected emission unit:

(a) The permittee shall comply with each emission limit and work practice standard in Tables 2 and 3 of
40 CFR 63 Subpart UUUUU for each EGU at the source, except as provided in paragraph (1)(d) of this
section ;

(b) The permittee shall comply with each operating limit in Table 4 of 40 CFR 63 Subpart UUUUU for
each affected EGU at the source;

(c) The permittee shall comply the emission and operating limits at all times except during periods of
startup and shutdown as defined in 40 CFR 63.10042. The permittee shall meet the work practice in Table
3 of 40 CFR 63 Subpart UUUUU during periods of startup, or shutdown as defined in 40 CFR 63.10042;

(d) The permittee may use emissions averaging as described in 40 CFR 63.10009 as an alternative to
meeting the requirements in (1)(a) of this section for filterable PM, SO2, HF, HCl, non-Hg HAP metals,
or Hg on an EGU-specific basis.

(2) As provided in 40 CFR 63.6(g), the Administrator may approve use of an alternative to the work
practice standards in this section;

(3) The permittee may use the alternate SO2 limit in Table 2 of 40 CFR 63 Subpart UUUUU only if the
affected coal-fired EGU:

(a) Has a system using wet or dry flue gas desulfurization technology and SO2 CEM installed on the unit;
and
(b) At all times, the permittee operates the wet and dry flue gas desulfurization technology installed on
the unit consistent with 40 CFR 63.10000(b)

[Origin: 40 CFR 63.9991, 63.10000(a), 63.10009, tables 2, 3, and 4]. [40 CFR 63 Subpart UUUUU]

II.B.3.f.1 Monitoring:

(a) General Compliance Requirement:

(1) The permittee shall conduct the initial performance testing for all pollutants in accordance
with 40 CFR 63.10000(c)(1)(i) through (vi), as applicable, to demonstrate compliance with the
applicable emission limits.

38
(2) If a continuous monitoring system (CMS) is used to demonstrate compliance with any
applicable emission limit, the permittee shall develop a site-specific monitoring plan for the CMS
in accordance to 40 CFR 63.10000(d)(1) through (5), as applicable, and submit this site-specific
monitoring plan, if requested, at least 60 days before the initial performance evaluation (where
applicable) of CMS. The permittee shall operate and maintain the CMS according to the site-
specific monitoring plan.

(3) The permittee shall perform periodic tune-up of EGU in accordance with 40 CFR
63.10021(e).

(b) Testing Requirements: the compliance performance test shall be conducted according to the
procedures described in 40 CFR 63.10005 for the initial compliance and according to the
procedures described in 40 CFR 63.10006 for continuous compliance. The permittee shall
conduct all required performance tests according to 40 CFR 63.10007

(c) Continuous Compliance:

(1) The permittee shall monitor and collect data according to 40 CFR 63.10020(b) through (d)
and the site-specific monitoring plan required by 40 CFR 63.10000(d), as applicable.

(2) The permittee shall demonstrate continuous compliance with each emissions limit, operating
limit, and work practice standard in Tables 2 through 4 to the subpart UUUUU of 40 CFR 63 that
applies to the permittee, according to the monitoring specified in Tables 6 and 7 to subpart
UUUUU of 40 CFR 63, and paragraphs 40 CFR 63.10021 (b) through (g).

(d) Alternate compliance monitoring for the EGU qualified as low emitting EGU (LEE):

The permittee may pursue the LEE option for filterable PM and Hg for the qualified LEE which
meets the requirement of 40 CFR 63.10005(h)

(1) Filterable PM: The permittee shall conduct a performance test at least once every 36 calendar
months to demonstrate continued LEE status.

(2) Hg: The permittee shall conduct a 30-day performance test using method 30B at least once
every 12 calendar months to demonstrate continued LEE status.

(e) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 9 of 40 CFR 63 Subpart UUUUU. [40 CFR 63.10040].

II.B.3.f.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.10032(a) through (j), as applicable.
[40 CFR 63.10032]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 9 of 40 CFR 63 Subpart UUUUU. [40 CFR 63.10040]

Records shall be maintained in accordance with 40 CFR 63.10033 and Provision I.S.1 of this
permit.

39
II.B.3.f.3 Reporting:

The permittee shall submit an Initial Notification described in 40 CFR 63.10030 (b) and (c), as
applicable.

The permittee shall submit a Notification of Compliance Status summarizing the results of the
initial compliance demonstration according to 40 CFR 63.9(h)(2)(ii). The Notification of
Compliance Status report must contain all the information specified in 40 CFR 63.10030(e)(1)
through (7), as applicable.

The permittee shall submit the compliance report as required in 40 CFR 63.10031. The
compliance report shall contain the requirements as described in 40 CFR 63.10031(c)(1) through
(4) and Table 8 of 40 CFR 63 Subpart UUUUU semiannually according to the requirements in 40
CFR 63.10031(b).

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 9 of 40 CFR 63 Subpart UUUUU. [40 CFR 63.10040]

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

Status: In compliance – Huntington’s Unit #2 is an existing coal-fired EGU. Huntington has a unit-single
stack configuration [40 CFR 63.10010(a)(1)]. CEMS are installed in the stack at locations
downstream of all emissions control devices, where the pollutant and diluents concentrations are
representative of the emissions that exit to the atmosphere.

Mercury LEE status was achieved in 2016. Testing was performed on March 26, 2024, through
April 29, 2024, to demonstrate compliance with the emission limits found in Title V permit
conditions. The DAQ-calculated test results (DAQC-561-24) are:

DAQ Results Limit
0.1 lb/TBTU 1.2 lb/TBTU
5.1 lb/yr 29 lb/hr

PM LEE status was acknowledged by the DAQ on April 3, 2018. MATS PM test frequency is
reduced to once every 36 months.

Huntington has converted to the neural network combustion optimization software. Thus, tune-ups
are due every 48 months. Unit #1 initial work practice standards were met on February 6, 2015.
Unit #2 tune-ups were conducted December 4, 2023. Records were available to confirm compliance.

The semi-annual compliance reports required by Subpart UUUUU have been submitted to DAQ as
required and have been reviewed and are in main source file. Quarterly reports are submitted and
reviewed by DAQ’s CEM specialist.

II.B.3.g Condition:

Emissions of mercury shall be no greater than 6.5x10-7 lbs/MMBtu heat input based on an annual
averaging period beginning January 1 and ending December 31. [Origin: R307-424-4]. [R307-424-4]

40
II.B.3.g.1 Monitoring:

(a) The permittee shall install, calibrate, maintain and operate a continuous monitoring system for
measuring emissions in accordance with Appendix A to 40 CFR 63 Subpart UUUUU.

(b) Each continuous emission monitoring system shall meet the quality assurance requirements of
R307-170, Continuous Emission Monitoring Systems Program and Appendix A to 40 CFR 63
Subpart UUUUU.

(c) Alternate compliance monitoring for the EGU qualified as low emitting EGU (LEE): the
permittee may pursue the LEE option for the qualified LEE which meets the requirement of 40
CFR 63.10005(h). The permittee shall conduct a 30-day performance test using method 30B at
least once every 12 calendar months to demonstrate continued LEE status.

II.B.3.g.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous monitoring
system, monitoring device, and performance testing measurements; all continuous monitoring
system performance evaluations; all continuous monitoring system or monitoring device
calibration checks; adjustments and maintenance performed on these systems or devices.

(b) The permittee shall maintain records of the occurrence and duration of any startup, shutdown,
or malfunction in the operation of the unit; any malfunction of the air pollution control
equipment; or any periods during which a continuous monitoring system or monitoring device is
inoperative.

II.B.3.g.3 Reporting:

(a) The permittee shall submit notifications and reports to the Director as required by R307-170,
Continuous Emission Monitoring Systems Program and comply with the reporting provision in
Appendix A to 40 CFR 63 Subpart UUUUU.

(b) Upon completion of each year's fourth quarterly report, an assessment shall be made for the
entire calendar year and reported to the Director within 30 days.

(c) The reports required in paragraph (a) above are considered prompt notification of permit
deviations required in provision I.S.2.c of this permit if all information required by provision
I.S.2.c is included in the report.

Status: In compliance – Unit #2 2022 mercury emission rate was 8.60 E-8 lbs/MMBtu which is less than the
limit of 6.5 E-7 lb/MMBtu. Mercury CEMS were discontinued upon achievement of Mercury LEE
status in 2016. The 12-calendar month Hg LEE test was completed on April 24, 2024. Outage
reports are submitted and maintained on-site. CEM unavailability reports are submitted with
MATS semiannual reports. The 2024 annual mercury assessment report was sent to DAQ as
required. The most recent testing was completed March 16. 2024.

41
II.B.4 Conditions on Coal Conveyors (EU #8).

II.B.4.a Condition:

All coal conveyors and drop points shall be enclosed or covered. [Origin: DAQE-AN102380032-21].
[R307-401-8]

II.B.4.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.4.a.2 Recordkeeping:

A log shall be maintained for any periods of operation when the required enclosures or covers are
removed.

II.B.4.a.3 Reporting:

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

Status: In compliance – All coal conveyors and drop points are permanently covered.

II.B.5 Conditions on Emergency Fire Pump (diesel engine) (EU #14)

II.B.5.a Condition:

The permittee shall comply with the following operating limitations at all times for each emergency
affected emission unit:

(1) The permittee shall operate the affected emission unit according to the requirements in 40 CFR
63.6640(f)(1) through (4). In order for the engine to be considered an emergency stationary engine under
40 CFR 63 Subpart ZZZZ, any operation other than emergency operation, maintenance and testing,
emergency demand response, and operation in non-emergency situations for 50 hours per year, as
described in paragraphs 40 CFR 63.6640(f)(1) through (4), is prohibited. If the engine is not operated in
accordance with the requirements in paragraphs 40 CFR 63.6640(f)(1) through (4), it will not be
considered an emergency engine and shall meet all requirements for non-emergency engines.

(2) The permittee shall meet the following requirements at all times, except during periods of startup:
(a) Change oil and filter every 500 hours of operation or within 1 year + 30 days of the previous change,
whichever comes first.
(b) Inspect air cleaner every 1,000 hours of operation or within 1 year + 30 days of the previous
inspection, whichever comes first, and replace as necessary;
(c) Inspect all hoses and belts every 500 hours of operation or within 1 year + 30 days of the previous
inspection, whichever comes first, and replace as necessary.

(3) The permittee have the option to utilize an oil and filter analysis program as described in 40 CFR
63.6625(i) in order to extend the specified oil change requirement in paragraph (2)(a) of this condition.

42
(4) During periods of startup the permittee shall minimize the engine's time spent at idle and minimize the
engine's startup time to a period needed for appropriate and safe loading of the engine, not to exceed 30
minutes, after which time the non-startup emission limitations apply.

(5) The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as identified in
Table 8 of 40 CFR 63 Subpart ZZZZ.

[Origin: 40 CFR 63.6595(a)(1), 40 CFR 63.6602, 40 CFR 63.6605(a), 40 CFR 63.6625(h), 40 CFR
63.6640(f), 40 CFR 63.6665, 40 CFR 63 Subpart ZZZZ Table 2c, 40 CFR 63 Subpart ZZZZ Table 8]. [40
CFR 63 Subpart ZZZZ].

II.B.5.a.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[40 CFR 63.6625(f)]

If an emergency engine is operating during an emergency and it is not possible to shut down the
engine in order to perform the work practice requirements on the required schedule, or if
performing the work practice on the required schedule would otherwise pose an unacceptable risk
under Federal, State, or local law, the work practice can be delayed until the emergency is over or
the unacceptable risk under Federal, State, or local law has abated. The work practice shall be
performed as soon as practicable after the emergency has ended or the unacceptable risk under
Federal, State, or local law has abated. [40 CFR 63 Subpart ZZZZ Table 2c Footnote 1]

The permittee shall demonstrate continuous compliance by operating and maintaining the
stationary RICE and after-treatment control device (if any) according to the manufacturer's
emission-related written operation and maintenance instructions or develop and follow their own
maintenance plan which must provide to the extent practicable for the maintenance and operation
of the engine in a manner consistent with good air pollution control practice for minimizing
emissions. [40 CFR 63.6625(e), 40 CFR 63.6640(a), 40 CFR 63 Subpart ZZZZ Table 6]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

II.B.5.a.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

For each affected emission unit that does not meet the standards applicable to non-emergency
engines, the permittee shall keep records of the hours of operation of the engine that are recorded
through the non-resettable hour meter. The permittee shall document how many hours are spent
for emergency operation, including what classified the operation as emergency and how many
hours are spent for non-emergency operation. If the engines are used for demand response
operation, the permittee shall keep records of the notification of the emergency situation, and the
time the engine was operated as part of demand response. [40 CFR 63.6655(f)]

If additional hours are to be used for maintenance checks and readiness testing, the permittee
shall maintain records indicating that Federal, State, or local standards require maintenance and
testing of emergency RICE beyond 100 hours per year. [40 CFR 63.6640(f)(1)(ii)]

43
The permittee shall keep records that demonstrate continuous compliance with each applicable
operating limitation including, but not limited to, the manufacturer's emission-related operation
and maintenance instructions or the permittee-developed maintenance plan. [40 CFR 63.6655(d),
40 CFR 63 Subpart ZZZZ Table 6]

Records of the maintenance conducted shall be kept in order to demonstrate that the permittee
operated and maintained the affected emission unit and after-treatment control device (if any)
according to their own maintenance plan. [40 CFR 63.6655(e)]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in Table 8 of 40 CFR 63 Subpart ZZZZ. [40 CFR 63.6665]

Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.

II.B.5.a.3 Reporting:

The permittee shall report any failure to perform the work practice on the schedule required and
the Federal, State or local law under which the risk was deemed unacceptable. [40 CFR 63
Subpart ZZZZ Table 2c Footnote 1]

The permittee shall report each instance in which it did not meet an applicable operating
limitation in 40 CFR 63 Subpart ZZZZ Table 2c. These instances are deviations from the
operating limitations. These deviations shall be reported according to the requirements in 40 CFR
63.6650. [40 CFR 63.6640(b)]

The permittee shall submit each report in 40 CFR 63 Subpart ZZZZ Table 7 as applicable. [40
CFR 63.6650(a)]

If there are no deviations from any applicable operating limitations, the permittee shall submit a
compliance report semiannually for affected emission units according to the requirements of 40
CFR 63.6650(b)(1)-(5) that contains the information required in 40 CFR 63.6650(c)(1)-(3) and a
statement that there were no deviations from the operating limitations during the reporting period.
[40 CFR 63 Subpart ZZZZ Table 7.1.a]

If a deviation from any operating limitation occurs during the reporting period, the permittee shall
submit a compliance report semiannually according to the requirements of 40 CFR 63.6650(b),
(f) that contains the information required in 40 CFR 63.6650(c)(1)-(3), (d). [40 CFR 63 Subpart
ZZZZ Table 7.1.b]

If a malfunction occurs during the reporting period, the permittee shall submit a compliance
report semiannually according to the requirements of 40 CFR 63.6650(b) that contains the
information required in 40 CFR 63.6650(c)(1)-(4). [40 CFR 63 Subpart ZZZZ Table 7.1.c]

The permittee shall comply with the applicable general provisions in 40 CFR 63.1-15 as
identified in 40 CFR 63 Subpart ZZZZ Table 8. [40 CFR 63.6665]

The permittee shall also report each instance in which it did not meet the applicable requirements
in Table 8. [40 CFR 63.6640(e)]

44
There are no additional reporting requirements for this provision except those specified in Section
I of this permit.

Status: In compliance – Records are maintained for the emergency fire pump engine. According to the
non-resettable hour meter records, the engines operated for (see below) hours for the calendar year
2024. The Semi-Annual Compliance Reports, regarding the emergency fire pump, were submitted
to DAQ as required. No deviations were reported.

Unit Maintenance hours Emergency hours
1 16.8 0
2 16.2 0
Fire pump 16.8 0

II.B.5.b Condition:

At all times the permittee shall operate and maintain any affected source, including associated air
pollution control equipment and monitoring equipment, in a manner consistent with safety and good air
pollution control practices for minimizing emissions. The general duty to minimize emissions does not
require the permittee to make any further efforts to reduce emissions if levels required by this standard
have been achieved. Determination of whether such operation 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, review of operation and maintenance procedures, review of operation and
maintenance records, and inspection of the source. [Origin: 40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)].
[40 CFR 63 Subpart ZZZZ]

II.B.5.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.5.b.2 Recordkeeping:

The permittee shall keep the records described in 40 CFR 63.6655(a)(1)-(5) as applicable. [40
CFR 63.6655(a)]

The permittee shall document activities performed to assure proper operation and maintenance.
Records shall be maintained in accordance with 40 CFR 63.6660 and Provision I.S.1 of this
permit.
II.B.5.b.3 Reporting:

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

Status: In compliance – Fire pump maintenance is conducted in-house on an annual basis. Records of the
maintenance are kept as hard copies and are entered into the SAP database. This is the same for all
units.

45
II.B.6 Conditions on Emission Units Subject to 40% Opacity Limit (EU #34).

II.B.6.a Condition:

Visible emissions shall be no greater than 40 percent opacity. [Origin: R307-201-3]. [R307-201-3]

II.B.6.a.1 Monitoring:

A visual opacity survey of each affected emission unit shall be performed on a monthly basis by
an individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. If
visible emissions other than steam are observed from an emission unit, an opacity determination
of that emission unit shall be performed by a certified observer within 24 hours of the initial
survey. The opacity determination shall be performed in accordance with 40 CFR 60, Appendix
A, Method 9. If opacity exceeds the limit, maintenance shall be performed on the affected unit to
correct the problem.

II.B.6.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination shall be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit. If excess visible emission is indicated, a notation
of the resulting maintenance activity shall also be made in the log, and shall include the date of
the maintenance request, the date the maintenance was performed, the type of maintenance
performed, and the name of the person responsible for the maintenance.

II.B.6.a.3 Reporting:

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

Status: In compliance – According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required.

II.B.7 Conditions on Coal handling and Blending Equipment (EU #41)

II.B.7.a Condition:

Visible emissions shall be no greater than 5 percent opacity for all conveyor transfer points and conveyor
drop points. [Origin: DAQE-AN102380032-21]. [40 CFR 60 Subpart Y, R307-401-8]

II.B.7.a.1 Monitoring:

An opacity determination shall be conducted once in each quarter that the affected emission unit
is operated. The opacity determination shall be conducted in accordance with 40 CFR 60,
Appendix A, Method 9.

46
II.B.7.a.2 Recordkeeping:

All data required by 40 CFR 60, Appendix A, Method 9 shall be maintained in accordance with
Provision I.S.1 of this permit.

II.B.7.a.3 Reporting:

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

Status: In compliance – According to the source, quarterly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required. See status of
condition II.B.4.a.

II.B.7.b Condition:

Visible emissions shall be no greater than 10 percent opacity for the truck unloading hopper, radial
stacker and all screens. [Origin: DAQE-AN102380032-21]. [40 CFR 60 Subpart Y, R307-401-8]

II.B.7.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month that the
unit operates, by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.7.b.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.7.b.3 Reporting:

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

Status: In compliance – According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required.

47
II.B.8 Conditions on Unit 1 Coal Mill Reject Material Drops (EU #42).

II.B.8.a Condition:

Visible emissions shall be no greater than 20 percent opacity for the conveyor belt. [Origin: 40 CFR Part
60, Subpart Y]. [40 CFR 60 Subpart Y]

II.B.8.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month that the
unit operates, by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

II.B.8.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.8.a.3 Reporting:

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

Status: In compliance – According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required.

II.B.9 Conditions on Unit 2 Coal Mill Reject Material Drops (EU #43).

II.B.9.a Condition:

Visible emissions shall be no greater than 20 percent opacity for the conveyor belt. [Origin: 40 CFR 60,
Subpart Y]. [40 CFR 60 Subpart Y]

II.B.9.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month that the
unit operates, by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

48
II.B.9.a.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.9.a.3 Reporting:

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

Status: In compliance – According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required.

II.B.10 Conditions on Real Time Coal Analyzer (EU #44).

II.B.10.a Condition:

There shall be no visible emissions at the Real-Time coal analyzer and all conveyor transfer points and
conveyor drop points associated for the Real-Time coal analyzer equipment.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.10.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month that the
unit operates, by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, corrective actions are required to bring the visible emissions
down to zero within 24 hours of the initial observation.

II.B.10.a.2 Recordkeeping:

A log of the visual inspections and corrective actions, if required, shall be maintained including
the date and time of each inspection and the name of the person making the inspection or
corrective actions.

II.B.10.a.3 Reporting:

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

Status: In compliance – According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and that maintenance is performed when required.

49
II.B.11 Conditions on Unit #2 Fabric filters Group (EU #46).

II.B.11.a Condition:

Visible emissions shall be no greater than 10 % opacity from each affected unit.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.11.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed on a weekly basis by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any visible
emissions are observed, an opacity determination of that emission unit shall be performed by a
certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the
initial observation.

II.B.11.a.2 Recordkeeping:

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

II.B.11.a.3 Reporting:

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

Status: In compliance – The weekly fugitive emission checklist was provided, for review, at time of the
inspection. The checklist indicated that VEOs are conducted when emissions are observed, and
maintenance is performed when required.

II.B.12 Conditions on Water Pump Engine (EU #47)

II.B.12.a Condition:

The affected emission unit shall comply with the emission standards for new engine in 40 CFR 60.4201,
as applicable.

If the permittee conducts performance tests on the affected emission unit, they shall meet the not-to-
exceed (NTE) standards as indicated in 40 CFR 60.4212. The performance test must be conducted
according to the in-use testing procedures in 40 CFR part 1039, subpart F, for stationary CI ICE with a
displacement of less than 10 liters per cylinder, and according to the procedures in 40 CFR part 1042,
subpart F, for stationary CI ICE with a displacement of greater than or equal to 10 liters per cylinder and
less than 30 liters per cylinder. [Origin: 40 CFR 60.4204(b) and 40 CFR 60.4212].
[40 CFR 60 Subpart IIII]

II.B.12.a.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in 40
CFR 60.4204(b) for the same model year and maximum engine power. The engine must be
installed and configured according to the manufacturer's emission-related specifications, except
as specified below. (Origin: 40 CFR 60.4211(c))

50
If the permittee does not install, configure, operate, and maintain affected emission units and
control devices according to the manufacturer's emission-related written instructions, or changes
emission-related settings in a way that is not permitted by the manufacturer, the permittee shall
demonstrate compliance as follows:

(a) Keep a maintenance plan and records of conducted maintenance to demonstrate compliance;
and

(b) To the extent practicable, maintain and operate the engine in a manner consistent with good
air pollution control practice for minimizing emissions; and

(c) If the permittee does not install and configure the engine and control device according to the
manufacturer's emission-related written instructions, or changes the emission-related settings in a
way that is not permitted by the manufacturer, the permittee shall conduct an initial performance
test to demonstrate compliance with the applicable emission standards within 1 year of such
action. (Origin: 40 CFR 60.4211(g)(1)). [40 CFR 60 Subpart IIII]

II.B.12.a.2 Recordkeeping:

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

II.B.12.a.3 Reporting:

Reports shall be submitted as specified in Section I of this permit.

Status: In compliance – Maintenance activities are tracked and recorded electronically. This engine is only
operated during the summer months. This unit is a portable unit and is used in several sections of
the plant.

II.B.12.b Condition:

The permittee shall purchase diesel fuel that meets the following standards of 40 CFR 1090.305 for
non-road diesel fuel:
(1) Sulfur content no greater than 15 ppm (0.0015 percent) by weight and
(2) A minimum cetane index of 40 or a maximum aromatic content of 35 volume percent.
[Origin: 40 CFR 60.4207(b)]. [40 CFR 60 Subpart IIII]

II.B.12.b.1 Monitoring:

Records required for this permit condition will serve as monitoring requirement.

II.B.12.b.2 Recordkeeping:

For each fuel load received, the permittee shall maintain either fuel receipt records or other
documentation showing fuel meets the specifications of ASTM D975 for the cetane index and
sulfur content for Grades No. 1-D S15 or 2-D S15 diesel.

The permittee shall maintain documentation demonstrating compliance with the condition. These
records shall be maintained in accordance with Provision I.S.1. of this permit. [40 CFR 60
Subpart IIII]

51
II.B.12.b.3 Reporting:

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

Status: In compliance. Records show that only low sulfur diesel (LSD) and diesel with a minimum cetane
index of 40 is purchased.

II.B.13 Conditions on Load-out Conveyor (EU# 48)

II.B.13.a Condition:

The gypsum load-out conveyors shall be covered. The gypsum material shall be transported along the
conveyors until stack-out occurs onto a concrete pad at the conveyor discharge location. The concrete pad
shall consist of a fabric enclosure vented only through the open side used for the loading process. [Origin:
DAQE-AN102380032-21]. [R307-401-8]

II.B.13.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.13.a.2 Recordkeeping:

A log shall be maintained for any periods of operation when the required enclosures or covers are
removed or when the gypsum materials are not transported along the conveyors.

II.B.13.a.3 Reporting:

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

Status: In compliance – According to the source the gypsum load-out conveyors are covered and
discharged to a concrete pad that has a three-sided fabric enclosure. It is reported that there have
been no periods when the enclosure has been removed or when gypsum materials are not
transported along the conveyors. Compliance certification reports (CCRs) are conducted weekly.

II.B.13.b Condition:

Visible emissions shall be no greater than 10% opacity at the conveyor drop point for the gypsum load-
out system. [Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.13.b.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month that the
unit operates, by an individual trained on the observation procedures of 40 CFR 60, Appendix A,
Method 9. The individual is not required to be a certified visible emissions observer (VEO). If
any visible emissions are observed, an opacity determination of that emission unit shall be
performed by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24
hours of the initial observation.

52
II.B.13.b.2 Recordkeeping:

A log of the visual opacity survey(s) shall be maintained in accordance with Provision I.S.1 of
this permit. If an opacity determination is indicated, a notation of the determination will be made
in the log. All data required by 40 CFR 60, Appendix A, Method 9 shall also be maintained in
accordance with Provision I.S.1 of this permit.

II.B.13.b.3 Reporting:

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

Status: In compliance – According to the source monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and maintenance is performed when required.

II.B.14 Conditions on Reverse Osmosis Soda Ash Silo (EU #49)

II.B.14.a Condition:

Visible emissions shall be no greater than 20 % opacity from each affected unit.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.14.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any visible
emissions are observed, an opacity determination of that emission unit shall be performed by a
certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the
initial observation.

II.B.14.a.2 Recordkeeping:

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

II.B.14.a.3 Reporting:

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

Status: In compliance – According to the source monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and maintenance is performed when required.

53
II.B.15 Conditions on Hi Carbon Ash Silo (EU #50)

II.B.15.a Condition:

Visible emissions shall be no greater than 20 % opacity from each affected unit.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.15.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any visible
emissions are observed, an opacity determination of that emission unit shall be performed by a
certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the
initial observation.

II.B.15.a.2 Recordkeeping:

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

II.B.15.a.3 Reporting:

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

Status: In compliance – According to the source monthly visual observations are conducted. The VEO log
was provided, for review, at the time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and maintenance is performed when required.

II.B.16 Conditions on Feed Ash Silo (EU #51)

II.B.16.a Condition:

Visible emissions shall be no greater than 20 % opacity from each affected unit.
[Origin: DAQE-AN102380032-21]. [R307-401-8]

II.B.16.a.1 Monitoring:

A visual observation of each affected emission unit shall be performed once each month by an
individual trained on the observation procedures of 40 CFR 60, Appendix A, Method 9. The
individual is not required to be a certified visible emissions observer (VEO). If any visible
emissions are observed, an opacity determination of that emission unit shall be performed by a
certified VEO in accordance with 40 CFR 60, Appendix A, Method 9 within 24 hours of the
initial observation.

II.B.16.a.2 Recordkeeping:

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

54
II.B.16.a.3 Reporting:

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

Status: In compliance - According to the source, monthly visual observations are conducted. The VEO log
was provided, for review, at time of the inspection. The log indicated that VEOs are conducted
when emissions are observed, and maintenance is performed when required.

II.C Emissions Trading.

Not applicable to this source.

II.D Alternative Operating Scenarios.

Not applicable to this source.

II.E Source-specific Definitions.

The following definitions apply to the permittee. They include terms not defined in state or federal rules
or clarify or expand on existing definitions.

Startup. Start-up means the setting in operation of an affected facility for any purpose. For these units,
startup begins with introduction of fuel into the boiler. Startup ends when the unit is in stable operation
with three pulverizers and coal feeders in service, and when the following operating parameters are met:
(1) the temperature of both inlets to the electrostatic precipitator or fabric filter baghouse reach 220oF, and
(2) less than 10 percent of the boiler's heat input is being furnished by fuel oil.

Shutdown. Shutdown means the cessation of operation of an affected facility for any purpose. For this
permitted source, shutdown begins when the unit load or output is reduced with the intent of removing the
unit from service, or when the unit trips as the result of a sudden and unforeseen failure or malfunction.
Shutdown ends when the feeding of fuel to the boiler ceases.

Downtime. Downtime is that time between the end of shutdown and the beginning of startup in which the
affected source has temporarily ceased operation.

Maintenance Outage. The removal of equipment from service availability to perform work on specific
components that can be deferred beyond the end of the next weekend, but requires the equipment be
removed from service before the next planned outage. Typically, a Maintenance Outage may occur
anytime during the year, have a flexible start date, and may or may not have a predetermined duration.

Planned Outage. Removing the equipment from service availability for inspection and/or general
overhaul of one or more major equipment groups. This outage usually is scheduled well in advance.

Status: For informational purposes only.

55
SECTION III: PERMIT SHIELD

The following requirements have been determined to be not applicable to this source in accordance with
Provision I.M, Permit Shield:

III.A. 40 CFR, Part 60, Subpart O (NSPS for Sewage Treatment Plants)

This regulation is not applicable to the Permitted Source for the following reason(s): an affected
facility as defined in these regulations (incinerator that combusts wastes > 10% of sewage sludge or
> 2205 lb/day of sewage sludge) is not located at this source.

III.B. 40 CFR, Part 60, Subpart OOO (Non-metallic mineral processing)

This regulation is not applicable to the Permitted Source for the following reason(s): the process of
crushing and grinding nonmetallic minerals is not performed at this source.

III.C. 40 CFR, Part 60, Subpart Da (NSPS for Electric Utility Steam Generating Units for Which
Construction is Commenced After September 18, 1978)

This regulation is not applicable to the Boiler Unit #1 (EU #1) for the following reason(s): this unit
was constructed prior to September 18, 1978.

III.D. 40 CFR, Part 60, Subpart D (NSPS for Fossil-Fuel-Fired Steam Generators for Which Construction
is Commenced After August 17, 1971)

This regulation is not applicable to the Boiler Unit #2 (EU #2) for the following reason(s): this unit
was constructed prior to August 17, 1971.

III.E. 40 CFR, Part 60, Subpart Da (NSPS for Electric Utility Steam Generating Units for Which
Construction is Commenced After September 18, 1978)

This regulation is not applicable to the Boiler Unit #2 (EU #2) for the following reason(s): this unit
was constructed prior to September 18, 1978.

III.F. 40 CFR, Part 60, Subparts K, Ka, Kb (NSPS/ Volatile Organic Liquid Storage Vessels)

This regulation is not applicable to the Distillate Fuel Oil Tanks (EU #20) for the following
reason(s): Subpart K, 60.111(b) and Ka, 60.111a(b) state that the standard does not apply to Nos. 2
through 6 fuel oils or diesel fuel oil. Subpart Kb is not applicable because the tanks were
constructed prior to 1984.

III.G. 40 CFR, Part 60, Subparts K, Ka, Kb (NSPS/ Volatile Organic Liquid Storage Vessels)

This regulation is not applicable to the Gasoline Vehicle Refueling Station and Tanks (EU # for the
following reason(s): the two 1,500 gallons gasoline tanks have a capacity below the applicability
criteria of any of the three standards.

III.H. 40 CFR, Part 63, Subpart Q (NESHAP for Industrial Process Cooling Towers)

This regulation is not applicable to the Unit #1 Cooling Towers (EU #5) for the following reason(s):
the cooling towers are not operated with chromium-based water treatment chemicals.
56
III.I. 40 CFR, Part 63, Subpart Q (NESHAP for Industrial Process Cooling Towers)

This regulation is not applicable to the Unit #2 Cooling Towers (EU #6) for the following reason(s):
the cooling towers are not operated with chromium-based water treatment chemicals.

Status: For informational purposes only.

SECTION IV: ACID RAIN PROVISIONS

IV.A Utah Acid Rain Program Authority.

Authority to implement the Acid Rain Program is contained in R307-417, Permits:
Acid Rain Sources, and R307-415-6a(4), Standard permit requirements [for operating
permits].

Status: For informational purposes only.

IV.B Permit Requirements.

IV.B.1 The designated representative of the source and each affected unit at the source shall:

IV.B.1.a Submit a complete Acid Rain permit application (including a compliance
plan) under R307-417 and 40 CFR Part 72 in accordance with the deadlines
specified in 40 CFR 72.30; and

IV.B.1.b Submit in a timely manner any supplemental information that the Director
determines is necessary in order to review an Acid Rain permit application
and issue or deny an Acid Rain permit;

IV.B.2 The owners and operators shall:

IV.B.2.a Operate each affected unit at the source in compliance with a complete Acid
Rain permit application or a superseding Acid Rain permit issued by the
Director; and

IV.B.2.b Have an Acid Rain Permit.

Status: In compliance – The source is part of the Acid Rain program.

IV.C Sulfur Dioxide Requirements.

IV.C.1 The owners and operators of each affected unit at the source shall:

IV.C.1.a Hold allowances, as of the allowance transfer deadline, in the unit's
compliance subaccount (after deductions under 40 CFR 73.34(c)) not less
than the total annual emissions of sulfur dioxide for the previous calendar year
from the unit; and

IV.C.1.b Comply with the applicable Acid Rain emissions limitations for sulfur
dioxide.

57
IV.C.2 Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for
sulfur dioxide shall constitute a separate violation of the Act.

IV.C.3 An affected unit shall be subject to the requirements under Provision IV.C.1. of the
sulfur dioxide requirements as follows:

IV.C.3.a Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or

IV.C.3.b Starting on the later of January 1, 2000 or the deadline for monitor
certification under 40 CFR Part 75, an affected unit under 40 CFR 72.6(a)(3).

IV.C.4 Allowances shall be held in, deducted from, or transferred among Allowance Tracking
System accounts in accordance with the Acid Rain Program.

IV.C.5 An allowance shall not be deducted in order to comply with the requirements under
Provision IV.C.1.a. of the sulfur dioxide requirements prior to the calendar year for
which the allowance was allocated.

IV.C.6 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
is a limited authorization to emit sulfur dioxide in accordance with the Acid Rain
Program. No provision of the Acid Rain Program, the Acid Rain permit application,
the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no
provision of law shall be construed to limit the authority of the United States to
terminate or limit such authorization.

IV.C.7 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
does not constitute a property right.

Status: In compliance – The source is part of the Acid Rain program.

IV.D Nitrogen Oxides Requirements.

The owners and operators for each affected at the source shall be compliance with the
applicable Acid Rain emissions limitations for nitrogen dioxide.

Status: In compliance – The source is part of the Acid Rain program.

IV.E Monitoring Requirements.

IV.E.1 The owners and operators and, to the extent applicable, designated representative of
each affected unit at the source shall comply with the monitoring requirements as
provided in 40 CFR Parts 74, 75, and 76.

IV.E.2 The emissions measurements recorded and reported in accordance with 40 CFR Part
75 shall be used to determine compliance by the unit with the Acid Rain emissions
limitations and emissions reduction requirements for sulfur dioxide and nitrogen
oxides under the Acid Rain Program.

58
IV.E.3 The requirements of 40 CFR Parts 74 and 75 shall not affect the responsibility of the
owners and operators to monitor emissions of other pollutants or other emissions
characteristics at the unit under other applicable requirements of the Act and other
provisions of the operating permit for the source.

Status: In compliance – Acid Rain monitoring and reporting is performed.

IV.F Recordkeeping and Reporting Requirements.

IV.F.1 Unless otherwise provided, the owners and operators for each affected unit at the
source shall keep on site at the source each of the following documents for a period of
5 years from the date the document is created. This period may be extended for cause,
at any time prior to the end of 5 years, in writing by the Administrator, USEPA, or
Director:

IV.F.1.a The certificate of representation for the designated representative for the
source and each affected unit at the source and all documents that demonstrate
the truth of the statements in the certificate of representation, in accordance
with 40 CFR 72.24; provided that the certificate and documents shall be
retained on site at the source beyond such 5-year period until such documents
are superseded because of the submission of a new certificate of
representation changing the designated representative;

IV.F.1.b All emissions monitoring information, in accordance with 40 CFR Part 75;

IV.F.1.c Copies of all reports, compliance certifications, and other submissions and all
records made or required under the Acid Rain Program; and,

IV.F.1.d Copies of all documents used to complete an Acid Rain permit application
and any other submission under the Acid Rain Program or to demonstrate
compliance with the requirements of the Acid Rain Program.

IV.F.2 The designated representative of each affected unit at the source shall submit the
reports and compliance certifications required under the Acid Rain Program, including
those under 40 CFR Part 72 Subpart I and 40 CFR Part 75.

Status: In compliance – Acid Rain reporting is performed.

IV.G Excess Emissions Requirements.

IV.G.1 The designated representative of an affected unit that has excess emissions in any
calendar year shall submit a proposed offset plan to the Administrator, USEPA, as
required under 40 CFR Part 77.

IV.G.2 The owners and operators of an affected unit that has excess emissions in any calendar
year shall:

IV.G.2.a Pay without demand the penalty required, and pay upon demand the interest
on that penalty, to the Administrator, USEPA, as required by 40 CFR Part 77;
and

59
IV.G.2.b Comply with the terms of an approved offset plan, as required by 40 CFR Part
77.

Status: In compliance – No excess emissions were reported.

IV.H Liability.

IV.H.1 Any person who knowingly violates any requirement or prohibition of the Acid Rain
Program, a complete Acid Rain permit application, an Acid Rain permit, or a written
exemption under R307-417, 40 CFR 72.7 or 40 CFR 72.8, including any requirement
for the payment of any penalty owed to the United States, shall be subject to
enforcement pursuant to section 113(c) of the Act.

IV.H.2 Any person who knowingly makes a false, material statement in any record,
submission, or report under the Acid Rain Program shall be subject to criminal
enforcement pursuant to section 113(c) of the Act and 18 U.S.C. 1001.

IV.H.3 No permit revision shall excuse any violation of the requirements of the Acid Rain
Program that occurs prior to the date that the revision takes effect.

IV.H.4 Each affected source and each affected unit shall meet the requirements of the Acid
Rain Program.

Status: For informational purposes only.

IV.I Effect on Other Authorities.

IV.H.5 Any provision of the Acid Rain Program that applies to an affected source (including
a provision applicable to the designated representative of an affected source) shall also
apply to the owners and operators of such source and of the affected units at the
source.

IV.H.6 Any provision of the Acid Rain Program that applies to an affected unit (including a
provision applicable to the designated representative of an affected unit) shall also
apply to the owners and operators of such unit. Except as provided under 40 CFR
72.44 (Phase II repowering extension plans) and 40 CFR 76.11 (NOx averaging
plans), and except with regard to the requirements applicable to units with a common
stack under 40 CFR part 75 (including 40 CFR 75.16, 75.17, and 75.18), the owners
and operators and the designated representative of one affected unit shall not be liable
for any violation by any other affected unit of which they are not owners or operators
or the designated representative and that is located at a source of which they are not
the owners and operators, owners or operators, or the designated representative.

IV.H.7 Each violation of a provision of 40 CFR Parts 72, 73, 74, 75, 76, 77, and 78 by an
affected source or affected unit, or by an owner or operator or designated
representative of such source or unit, shall be a separate violation of the Act.

Status: For informational purposes only.

60
No provision of the Acid Rain Program, an Acid Rain permit application, an Acid
Rain permit, or a written exemption under 40 CFR 72.7 or 72.8 shall be construed as:

IV.I.1 Except as expressly provided in Title IV of the Act, exempting or excluding the
owners and operators and, to the extent applicable, the designated representative from
compliance with any other provision of the Act, including the provisions of Title I of
the Act relating to applicable National Ambient Air Quality Standards or the Utah
State Implementation Plan;

IV.I.2 Limiting the number of allowances, a unit can hold; provided, that the number of
allowances held by the unit shall not affect the source's obligation to comply with any
other provisions of the Act;

IV.I.3 Requiring a change of any kind in any State law regulating electric utility rates and
charges, affecting any State law regarding such State regulation, or limiting such State
regulation, including any prudence review requirements under such State law;

IV.I.4 Modifying the Federal Power Act or affecting the authority of the Federal Energy
Regulatory Commission under the Federal Power Act; or,

IV.I.5 Interfering with or impairing any program for competitive bidding for power supply in
a State in which such program is established.

Status: For informational purposes only.

EMISSION INVENTORY: Huntington Power Plant’s 2023 Total Emission Inventory Summary:

CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
Pollutant Code/CAS # Pollutant Name Emissions (tons, excluding tailpipe)
Tailpipe Emissions (tons)
Total Emissions (tons)*
PM10-PRI PM10 Primary (Filt + Cond) 426.6168 0.17814 426.79494
PM10-FIL PM10 Filterable 358.31509 <.00001 358.31509
PM25-PRI PM2.5 Primary (Filt + Cond) 195.40868 0.17279 195.58147
PM25-FIL PM2.5 Filterable 127.10538 <.00001 127.10538
PM-CON PM Condensible 68.29848 <.00001 68.29848
SO2 Sulfur Dioxide 1,057.14986 0.005 1,057.15486
NOX Nitrogen Oxides 4,350.38756 3.40495 4,353.79252
VOC Volatile Organic Compounds 47.45398 0.26665 47.72063
CO Carbon Monoxide 2,762.41361 1.39208 2,763.80569
7439921 Lead 0.02457 <.00001 0.02457
NH3 Ammonia 0.50732 <.00001 0.50732

61
HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
Pollutant Code/CAS # Pollutant Name Is VOC/PM? Total Emissions
(tons)*
75070 Acetaldehyde (HAP) VOC 0.00002
107028 Acrolein (HAP) VOC 0.06918
7440360 Antimony (HAP) PM 0.00924
7440382 Arsenic (HAP) PM 0.01121
71432 Benzene (HAP) VOC 0.03965
7440417 Beryllium (HAP) PM 0.00123
117817 Bis(2-Ethylhexyl)Phthalate (HAP) VOC 0.04743
106990 1,3-Butadiene (HAP) VOC <.00001
7440439 Cadmium (HAP) PM 0.0044
532274 2-Chloroacetophenone (HAP) VOC 0.00534
7440473 Chromium (HAP) PM 0.05517
7440484 Cobalt (HAP) PM 0.00712
57125 Cyanide (HAP) PM 1.9748
132649 Dibenzofuran (HAP) VOC 0.05534
77781 Dimethyl Sulfate (HAP) VOC 0.03793
121142 2,4-Dinitrotoluene (HAP) VOC 0.00534
106934 Ethylene Dibromide (HAP) VOC 0.00098
50000 Formaldehyde (HAP) VOC 0.01148
7647010 Hydrochloric Acid (HAP) - 4.56702
7664393 Hydrogen Fluoride (HAP) - 3.37499
7439965 Manganese (HAP) PM 0.08629
7439976 Mercury (HAP) - 0.00013
74839 Methyl Bromide (HAP) VOC 0.12636
74873 Methyl Chloride (HAP) VOC 0.31916
60344 Methylhydrazine (HAP) VOC 0.13425
75092 Methylene Chloride (HAP) - 0.23193
91203 Naphthalene (HAP) VOC 0.00003
7440020 Nickel (HAP) PM 0.05129
130498292 PAH, total (HAP) PM 0.00003
123386 Propionaldehyde (HAP) VOC 0.09882
7782492 Selenium (HAP) PM 0.22335
108883 Toluene (HAP) VOC 0.00004
1330207 Xylenes (Mixed Isomers) (HAP) VOC 0.00003
246 Polycyclic Organic Matter (HAP) VOC 0.00024
*Rounded to 5 digits past the decimal point. Note that where rounding results in 0, <.00001 is indicated.

62
PREVIOUS ENFORCEMENT
ACTIONS: November 10, 2022 – Warning – Late submission of Title V certification

COMPLIANCE STATUS &
RECOMMENDATIONS: PacifiCorp Huntington Power Plant should be found in compliance with
the Title V permit. No further action is recommended.

HPV STATUS: N/A

COMPLIANCE
ASSISTANCE: None

RECOMMENDATION FOR
NEXT INSPECTION: Inspect as usual

ATTACHMENT: VEO Form