DAQ-2025-002883

Huntington Power Plant
8 miles west of Huntington, Utah on Hwy. j I
P.O. Box 680
Huntington, Utah 84528
May 13,2025
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-4820
And
Director, USEPA Region Vlll
8 ENF-AT
1595 V[nkoop St.
Denver, CO 80202-1129
RE: MATS Quarterly Compliance Report,40 CFR 63 Subpart UUUUU, Huntington Power PIant
(Title V Permit #1501001006) Boiler Units 1 and 2.
Dear Mr. Bird:
Huntington Power Plant's Title V Permit Conditions 11.B.2.9.3 and 11.B.3.f.3 require the Huntington Plant to
submit Compliance Reports according to the requirements of 40 CFR S63.10031(b). This submittal
covers the period from January 1, 2025, to March 31,2025, and is intended to satisty those requirements.
I am authorized to make this submission on behalf of the owners and operators of the affected source or
affected units for which the submission is made. I certify under penalty of law that I have personally
examined, and am familiarwith, the statements and information submitted in this document and all its
attachments. Based on my inquiry of individuals with primary responsibility for obtaining the information, I
certify that the statements and information are to the best of my knowledge and betief true, accurate, and
complete. I am aware that there are significant penalties for submitting false statements and information,
or omitting statements and information, including the possibility of a fine or imprisonment.
Should you have any questions regarding this information, please contact Terry Guthrie, Hunter and
Huntington Plant Environmental Manager (435) 6874334 or me at (435) 6874211.
DEPARTMENT OF
ENVIHONMEI{IA OI,NTfiV
l'lAY 27 2025
DMSTON OF An q.nrmt
REVIEWED
Initials JBR Date 6/11/2025
Comp Status: Meets
File # 10238 Blue 2
see attachments
,*",/r? ,
Managing Director Hunter and Huntington Plant
Designated Authority
Enclosures: Mercury and Air Toxics Quarterly Compliance Report with attachments A thru C - Units 1
and2
cc: Youn Joo Kim - USEPA Region Vlll Menclosure
Josh Sewell- NTO Mo enclosure
Scarlet Jackson - NTO Wo enclosure
Russ \Mllson - Huntington Plant - Files
l%crFrEoRP
UAY ?1 ?,025
Huntington Power PIant
MATS Quarterly Compliance Report Unit 1
40 cFR 63.10031(e)
January L,2025 - March 3L,2025
AH DEPARTMENT
ENVIRONMENTAL OUALlTY
DIVISION OF AIR OUALlTY
Section 1.0 - Unit I Report Summary
Huntington Power Plant, 8 miles west of Huntington Utah on Hwy 3l
P.O. Box 680
Huntington, Utah 84528
Identification of eachhazardous air pollutant monitored at the affected source
I. Non-Mercury HAPS metals using a quarterly filterable particulate matter (PM) stack
test as a surrogate to demonstrate compliance. On April 3,2018 the Utah Department
of Environmental Quality - Division of Air Quality agreed that the Huntington Plant
Unit I met the requirements to quali[ as a low emitting EGU (LEE) unit. The
Huntington Plant submitted a summary table showing three years of quarterly test data.
Each particulate matter (PM) testing result was below one-half of the 0.030 lb/MMBtu
limit or 0.015 lbA4MBtu as required by the subpart.
II. Acid gases using sulfur dioxide (SOz) as a surrogate to demonstrate compliance by an
SOz continuous emissions monitoring system (CEMS).
III. Mercury (Hg), compliance demonstrated by an annual EPA Method 30B sorbent trap
test to re-confirm LEE status.
A brief description of the process unit
I. Huntington Unit I is an Electric Utility Steam Generating Unit, designed as a bottom
tangentially-fired boiler, designed by Babcock and Wilcox.
i. Rated Heat Input Capacity of 4,960 MMBtu/hr.
ii. The unit is equipped with the following add-on controls:
L Pulse Jet Fabric Filter (baghouse)
2. Wet Flue Gas Desulfurization (wet scrubber)
3. Low-NOx burner technology, with separated over-fire air
iii. Fuels used are sub-bituminous coal using #2 fuel oil for startup fuel when
needed.
II. Unit Category
i. Unit I is an existing coal-fired unit combusting non-low rank virgin coal
demonstrating compliance with the emission limits found in Table 2 to Subpart
UUUUU of Part 63
III. The emission and operating parameter limitationsi. Filterable PM quarterly stack testing demonstrating compliance with a 0.030
lbiMMBtu emission limit. The unit has demonstrated and achieved low
emitting EGU (LEE) status.
ii. SOz CEMS as a surrogate for acid gases reporting hourly averages in units of
lb/l\4MBtu demonstrating compliance with a 30 boiler-operating-day average
limit of 0.20 lb/MMBtu.
iii. Hg annual EPA Method 30B sorbent trap test reporting hourly averages in
units of lb/TBtu demonstrating compliance with a 30 boiler-operating-day
average of 1.2 Ib/TBtu.
A description of any changes in CMS, processes, or controls since the last reporting
period
No changes occurred during the reporting period that would affect compliance to MATS.
Recent performance test results
Table 1-2: Unit 1 Mercury LEE Test Results Summary
Test ID Test Date
Hg rate
(lb/TBtu)
MATS
Hg
Threshold
Unit Status
2024 06t30t2024 0.01 0.12
LEE Achieved.
Maintained with
0613012024 LEE test
Section 2.0 - Unit 1 MATS Compliance Report Root Data Elements
Table 2-1: Root Data Elements
2.1 Faciliw oRIS Code 8069
2.2 Faci tv Name Huntinston
2.3 Faci ty Reeistry Identifier (ORISPL)8069
2.4 Title 40 Part 63
2.5 Applicable Subpart UUUUU
Table 1-1: Unit I X'ilterable Particulate Matter LEE Test Results Summary
Test ID Test Date
Average
PM rate
(lb/mmBtu)
MATS
PM
Limit*
Average
PM
flblNlW-hr)
MATS
PM
Limit*
Unit Status
2024 03fi9/2024 0.010 0.030 0.r0 0.30
LEE
Achieved in
201 8.
Maintained
with
311912024
LEE test
tl-ow Emitter Limits are 0.015 IbA4M-BTU and 0.15 lbs/I\'IW-HR
2.6 Calendar Year 2025
2.7 Calendar Ouarter l tt Ouarter
2.8 Submission Comment (optional)See cover letter
Section 3.0 - Unit I Performance Stack Test Summary
For applicable elements of Appendix E Section 3.1-3.14, see stack testing reports submitted for the
quafter. Stack testing data is being provided in both .xml and .pdf formats.
Section 4.0 - Operating Limit Data (PM, CPMS, only)
No PM CPMS on unit. Section not applicable.
Section 5.0 - Unit I Performance Test Run Data
For applicable elements of Appendix E Section 5.1-5.8, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 6.0 - Unit 1 Conversion Parameters
For applicable elements of Appendix E Section 6.1-6.3, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 7 .0 - Unit I Quality Assurance Parameters
For applicable elements of Appendix E Section 7.1-7.3, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 8.0 - Averaging Group
Unit is not part of an averaging group.
Section 9.0 - Unit I Compliance Averages
Please see Attachment A-l which includes 30-boiler-operating-day average data for sulfur dioxide.
Section 10.0 - Unit I Information
Table 10-1: Unit Information
Section I 1.0 - Unit I Fuel Usage Information
Tabte l1-1 Quarterly Fuel Usage rnforiration
Month #2 Fuel Oil Burned (gallons)Sub-Bituminous Coal Burned (tons)
January 1,246 86,285
February 15,959 79,542
March 0.00 80,442
Total 1720s 246269
Note: No new fuel types were combusted during the reporting period.
Section Data Element Plant Data
10.I Unit ID;Unit 1
10.2 Date of Last Tune-up; and February 17|e,2025.
10.3 Emergency Bypass Information.No emergency bypass occurred during quarter
Section 12.0 and 13.0 - Unit I Malfunction, Deviations, and Monitoring
Downtime Information
Table 12-1 Monitoring Equipment Manufacturer and Model number
Pollutant Manufacturer Model Number
Sulfur Dioxide Thermo 43iQ-ACN
Carbon Dioxide
(COz)'Thermo 4lOiQ-ACN
Table 12-2: Most Recent CMS Certification or Audit
U1 CEMS Analyzer Latest RATA Date Latest Linearity Date
Carbon Dioxide lCOz)31n12025 210412025
Sulfur Dioxide (SOz)3t1112025 2t04t2025
Table 12-3: Unit Operating Time During the Reporting Period
Ul Operating Period Hours of Unit Operation
l't Quarter, 2025 2,073.23
Table l2-4: Excess Emission Summary
I The COz analyzer is used as a diluent for calculating heat input based emission limits
5
Ul Excess Emissions
Summary PM SOz Hg
Total Hours of Exceedance 0 0 0
Exceedance percent of total
operating hours 0.001o 0.0%0.0%
Hours during startup and
shutdown 0 0 0
Hours during control equipment
problems 0 0 0
Hours during process hours 0 0 0
Hours during other know
problems 0 0 0
Hours during unknown causes 0 0 0
Emission L m t 0.030 0.20 1.2
Emission L mitation Unit lb/MMBtu lb/lr4MBtu lb/TBtu
Em ission lim itation averaging
period
Annual Stack
Testing
30 boiler
operating-day
Annual Stack
Testing
Table 12-5: CMS performance summalT
Ul CMS Performance Summara SOz
Downtime percent of total operating hours 2.94%
Total hour of CMS downtime 61
Hours due to monitoring equipment malfunctions 57
Hours due to non-monitoring equipment malfunctions 0
Hours due to quality assurance/quality control calibrations 3
Hours due to other known causes
Hours due to other unknown causes 0
For applicable elements of Appendix E Sections 12.1-12.3 and l3.l-13.5, see Attachments B and C.
No deviations from rule requirements occurred other than those stated on this report and aftachments.
Sections 14.0 through 30.0 - Reference Method Data
For applicable elements of Appendix E Sections l4-30, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 31.0 - Other Information for Each Test or Test Series
In accordance with section 31.0 and to provide reporting transparency, all stack testing data
relevant to compliance with Subpart UUUUU of Part 63 is being submitted in pdf format with
this quarterly compliance report.
Report Certification
Designated Authority certifuing the accuracy of the report:
Managing Director, Hunter and Huntington Plant
Designated Authority
\1.\ i \ (.)r1 11 1.1 1,, 1. .111i1,11 trrr. l(r'trLrt'l I lllini'lt()r1 l'r,rr r't l'l.tlti t tttl I
Attachments:
Attachment A: MATS 30-Day Rolling SOz lb/IvIMBtu Average Data
Attachment B: SOz Monitor Downtime Events Report
Attachment C: Excess Emissions Report
E$llEgN ru E ruref o uar r rv
[,AY 27 2025
DIVISION OFAIR OUALITY
7
l%crFrEoRP
H u ntington Power PIa nt
MATS Quarterly Compliance Report Unit 2
40 cFR 63.10031(e)
January 1,2025, to March 37,2025
urAH DFpAnruenriG-
E uV.|BO I'l M E tiiAt A UAL ITy
DIVISION OF AIR OUALITY
Section 1.0 - Unit 2 Report Summary
Name and address of the affected source
Huntington Power Plant, 6 miles west of Huntington Utah on Hwy 3l
P.O. Box 680
Huntington, Utah 84528
ldentification of each hazardous air pollutant monitored at the affected source
I. Non-Mercury HAPS metals using a quarterly filterable particulate matter (PM) stack
test as a surrogate to demonstrate compliance. On April3,20l8, the Utah Department
of Environmental Quality - Division of Air Quality agreed that the Huntington Plant
Unit 2 met the requirements to qualifo as a low emitting EGU (LEE) unit. The
Huntington Plant submiffed a summary table showing three years of quarterly test data.
Each particulate matter (PM) testing result was below one-half of the 0.030 lbs/MMBtu
limit, or 0.015 lbs/MMBtu as required by the subpart.
II. Acid gases using sulfur dioxide (SOz) as a surrogate to demonstrate compliance by an
SOz continuous emissions monitoring system (CEMS).
III. Mercury (Hg), compliance demonstrated by an annual EPA Method 308 sorbent trap
test to re-confirm LEE status.
I.
A brief description of the process unit
Huntington Unit 2 is an Electric Utility Steam Generating Unit, designed as a bottom
tangentially-fired boiler, designed by Babcock and Wilcox.
i. Rated Heat Input Capacity of 4,960 MMBtu/hr.
ii. The unit is equipped with the following add-on controls:
l. Pulse Jet Fabric Filter (baghouse)
2. Wet Flue Gas Desulfurization (wet scrubber)
3. Low-NOx burner technology, with separated over-fire air
iii. Fuels used are sub-bituminous coal using #2 fuel oil for startup fuel when
needed.
Unit Category
i. Unit 1 is an existing coal-fired unit combusting non-low rank virgin coal
demonstrating compliance with the emission limits found in Table 2 to Subpart
UUUUU of Part 63
The emission and operating parameter limitations
i. Filterable PM quarterly stack testing demonstrating compliance with a 0.030
lb/Ir4MBtu emission limit. The unit has demonstrated and achieved low
emitting EGU (LEE) status.
ii. SOz CEMS as a surogate for acid gases reporting hourly averages in units of
lb/MMBtu demonstrating compliance with a 30 boiler-operating-day average
limit of 0.20 lb/\4MBtu.
II.
III.
iii. Hg annual EPA Method 30B sorbent trap test reporting hourly averages in
units of lb/TBtu demonstrating compliance with a 30 boiler-operating-day
average of 1.2 lb/TBtu.
A description of any changes in CMS, processes, or controls since the last reporting
period
No changes occurred during the reporting period that would affect compliance to MATS.
Recent perforrnance test results
Table l-1: Unit 2 Filterable Particulate Matter LEE Test Results Summary
Test ID Test Date
Average
PM rate
(lb/mmBtu)
MATS
PM
Limit*
Average
PM
(Ib/lv[W-hr)
MATS
PM
Limit*
Unit Status
2024 04109t2024 0.009 0.030 0.08 0.30
LEE
Achieved in
201 8.
Maintained
with
419t2024
LEE test
*Low Emitter Limits are 0.015 Ib/MM-BTU and 0.15 lbs/IVIW-HR
Table 1-2: Unit 2 Mercury LEE Test Results Summary
Test ID Test Date
Hg rate
(lb/TBtu)
MATS
Hg
Threshold
Unit Status
2024 0412912024 0.01 0.12
LEE Achieved.
Maintained with
4/2912024 LEE test
Section 2.0 - Unit 2 MATS Compliance Report Root Data Elements
Table 2-1: Root Data Elements
2.1 Faciliw ORIS Code 8069
2.2 Facil tv Name Huntinston
2.3 Faci tv Resistrv Identifier (ORISPL)8069
2.4 Title 40 Part 63
2.5 Applicable Subpart UUUUU
2.6 Calendar Year 2025
2.7 Calendar Ouarter l't Ouarter
2.8 Submission Comment (optional)See cover letter
Section 3.0 - Unit 2 Performance Stack Test Summary
For applicable elements of Appendix E Section 3.1-3.14, see stack testing reports submitted for the
quarter. Stack testing data is being provided in both .xml and .pdf formats.
Section 4.0 - Operating Limit Data (PM, CPMS, only)
No PM CPMS on unit. Section not applicable.
Section 5.0 - Unit 2 Performance Test Run Data
For applicable elements of Appendix E Section 5.1-5.8, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 6.0 - Unit 2 Conversion Parameters
For applicable elements of Appendix E Section 6.1-6.3, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 7 .0 - Unit 2 Quality Assurance Parameters
For applicable elements of Appendix E Section 7.1-7.3, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 8.0 - Averaging Group
Unit is not part of an averaging group.
Section 9.0 - Unit 2 Compliance Averages
Please see Attachment A-l which includes 30-boiler-operating-day average data for sulfur dioxide.
Section 10.0 - Unit 2 Information
Section I 1.0 - Unit 2 Fuel Usage Information
Table 11-l Quarterly Fuel Usage Information
Month #2 Fuel Oil Burned (gallons)Sub-Bituminous Coal Burned (tons)
January 1,805 78,974
February 0.0 84,563
March 0.0 72,063
Total 1,805 235,600
Note: No newfuel types were combusted during the reporting period.
Table 10-1: Unit Information
Section Data Element Plant Data
10.1 Unit ID Unit 2
10.2 Date of Last Tune-up Februarv 20.2025
10.3 Emergency Bypass Information.No emersencv bvoass occurred durinc ouarter
Section 12.0 and 13.0 - Unit 2 Malfunction, Deviations, and Monitoring
Downtime Information
Table 12-l Monitoring Equipment Manufacturer and Model number
Pollutant Manufacturer Model Number
Sulfur Dioxide Thermo 43iQ-ACN
Carbon Dioxide
lCOz)r
Thermo 4l0iQ-ACN
Table 12-2: Most Recent CMS Certification or Audit
U2 CEMS Analyzer Latest RATA Date Latest Linearity Date
Carbon Dioxide (COz)3^2t202s 21712025
Sulfur Dioxide (SOz)311212025 2171202s
Table l2-3: Unit Operating Time During the Reporting Period
U2 Operating Period Hours of Unit Operation
l't Quarter,2025 2,112.29
Table 12-4: Excess Emission Summary
I The COz malyzer is used as a diluent for calculating heat input based emission limits
5
U2 Excess Emissions
Summary PM SOz lrg
Total Hours of Exceedance 0 0 0
Exceedance percent of total
operating hours 0.004 0.0010 0.0%
Hours during startup and
shutdown 0 0 0
Hours during control equipment
problems 0 0 0
Hours during process hours 0 0 0
Hours during other know
problems 0 0 0
Hours during unknown causes 0 0 0
Emission Limit 0.030 0.20 1.2
Emission Limitation Unit lbs/MMBtu lbs/MMBtu lbs/TBtu
Emission limitation averaging
period
Annual Stack
Testing
30 boiler
operating-day
Annual Stack
Testing
Table 12-5: CMS performance summary
U2 CMS Performance Summary SOz
Downtime percent of total operating hours 0.43 %
Total hour of CMS downtime 9
Hours due to monitoring equipment malfunctions J
Hours due to non-monitoring equipment malfunctions 0
Hours due to quality assurance/quality control calibrations 6
Hours due to other known causes 0
Hours due to other unknown causes 0
For applicable elements of Appendix E Sections l2.l-12.3 and 13.1-13.5, see Attachments B and C.
No deviations from rule requirements occurred other than those stated on this report and attachments.
Sections 14.0 through 30.0 - Reference Method Data
For applicable elements of Appendix E Sections 14-30, see stack testing reports submitted for the quarter.
Stack testing data is being provided in both .xml and .pdf formats.
Section 31.0 - Other Information for Each Test or Test Series
In accordance with section 31.0 and to provide reporting transparency, all stack testing data
relevant to compliance with Subpart UUUUU of Part 63 is being submitted in pdf format with
this quarterly compliance report.
Report Certification
Managing Director, Hunter and Huntington Plant
Designated Authority
6
ity certiffing accuracy ofthe report:
\1.\ IS (.)r.r,nir't lr i t'r)t1:li.:rrr.' Ilr'Prrpl Illutiur,tl(rti l)outr l'liutt i rril l
Attachments:
Attachment A: MATS 30-Day Rolling SOz lb/TvIMBtu Average Data
Attachment B: SOz Monitor Downtime Events Report
Attachment C: Excess Emissions Report
l,AY 21 2025
DIVISTON OFAIR OUALITY