DAQ-2024-004253

1

DAQC-006-24
Site ID 10327 (B4)

MEMORANDUM

TO: STACK TEST FILE – INTERMOUNTAIN POWER SERVICE CORPORATION

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Robert Sirrine, Environmental Scientist

DATE: January 3, 2024

SUBJECT: Source: Coal Fired Boiler Unit 1
Contact: Mike Utley, 435-864-6489
Location: 850 West Brush Wellman Road, Delta, Millard County, UT
Test Contractor: IPSC Personnel – In-House Test
FRS ID #: UT0000004902700010
Permit/AO#: Title V operating permit 2700010006 dated November 21, 2023
Subject: Review of Stack Test Protocol dated November 16, 2023

On January 3, 2024, Utah Division of Air Quality (DAQ) received a protocol for stack emissions testing
of the IPSC Boiler Unit 1 located in Delta, Utah. Testing is scheduled to be performed January 9-10,
2024, to determine compliance with 40 CFR, Part 63, Subpart UUUUU, and permit Condition II.B.2.h for
PM and HCl emissions.

PROTOCOL CONDITIONS:

1. RM 1 used to determine sample velocity traverses; OK
2. RM 2 used to determine stack gas velocity and volumetric flow rate; OK
3. RM 3B used to determine dry molecular weight of the gas stream; OK
4. RM 4 used to determine moisture content; OK
5. RM 5 used to determine particulate emissions; OK
6. RM 26A used to determine HCl concentration of emissions; OK
7. RM 19 used to convert emissions concentration to lb/mmBtu/hr; OK
DEVIATIONS: No deviations were noted.

CONCLUSION: The protocol appears to be acceptable.

RECOMMENDATION: Send attached protocol review and test date confirmation notice.

ATTACHMENTS: Stack test protocol dated November 16, 2023.

Intermountain Power Service Corporation

November 16, 2023

Mr. Bryce Bird, Director
Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, Utah 84114-4820

Attention: COMPLIANCE SECTION

Reference: Operating Permit #2700010005
Dear Director Bird:
Mercury Air Toxic Standards (MATS) Ongoing Performance Particulate (PM)
and Hydrogen Chloride (HCl) Testing of Intermountain Generating Station (IGS)
Unit 1 Boiler Stack

Please find attached the site-specific performance test plan which includes the test protocol for the PM and
HCl testing of the IGS Unit 1 Boiler Stack. Testing is required by our Title V Operating Permit, Section
II.B.2.h.1., and 40 CFR §63. The test plan and protocol have been modified from the initial testing to more
accurately represent only those requirements applicable to the IGS under MATS.

IPSC personnel will perform the required testing on January 9 and 10, 2024.

Based on information and belief formed after reasonable inquiry, I certify that the statements and
information in the document are true, accurate, and complete. If you have any questions or comments,
please contact Vicki Lyman, IPSC Environmental Technical Analyst, at [phone].

Sincerely,

Jon A. Finlinson
President and Chief Operations Officer
VL/HBI:he
cc: Shudeish Mahadev, LADWP w/Attachment
Katherine Rubin, LADWP w/Attachment
Andrea Villarin, LADWP w/Attachment
Mike Utley

Attachment: Site-specific Performance Test Plan

850 West Brush Wellman Road, Delta, Utah, 84624 / Telephone: [phone] / FAX: [phone] / Fed. I.D. #87-0388573

Intermountain Generating Station
Unit 1

Site-Specific Performance Test Plan
(Filterable PM and HCl)

40 CFR Part 63, Subpart UUUUU

Prepared by:

Intermountain Power Service Corporation
Intermountain Generating Station
Delta, UT

CONTENTS
SECTION 1 – SITE-SPECIFIC TEST PLAN OVERVIEW .................................................... 1-1
1.1 INTRODUCTION ........................................................................................................................... 1-1
1.2 OBJECTIVE OF SITE-SPECIFIC TEST PLAN ............................................................................ 1-1
SECTION 2 – AFFECTED FACILITY AND MATS COMPLIANCE .................................... 2-1
2.1 DESCRIPTION OF FACILITY ....................................................................................................... 2-1
2.2 FACILITY ORGANIZATION ........................................................................................................ 2-2
2.3 MATS COMPLIANCE LIMITS ..................................................................................................... 2-3
2.4 MATS COMPLIANCE STRATEGY SUMMARY ....................................................................... 2-3
SECTION 3 – FILTERABLE PM TEST PLAN ....................................................................... 3-1
3.1 INITIAL & SUBSEQUENT PM COMPLIANCE FOR MATS ..................................................... 3-1
3.1.1 Ongoing Notification and Test Schedule (Filterable PM)……………………………………………….3-1
3.1.2 Test Program Summary (Filterable PM)…………………………………………………………………3-2
3.1.3 Test Methods Summary (Filterable PM)……...………………………………………………………… 3-3
3.1.3.1 EPA Reference Method 1 ................................................................................................................. 3-3
3.1.3.2 EPA Reference Method 2 ................................................................................................................. 3-5
3.1.3.3 EPA Reference Method 3B ............................................................................................................... 3-5
3.1.3.4 EPA Reference Method 4 ................................................................................................................. 3-6
3.1.3.5 EPA Reference Method 5 ................................................................................................................. 3-6
3.1.4 Additional Data Collection Requirements……………………………………………………………….3-6
3.1.5 Quality Assurance Activities (Filterable PM).…………………………………………………………...3-7
3.1.6 Example Calculations (Filterable PM)…………………………………………………………………...3-7
3.1.7 Notification of Compliance Status (PM)…………………………………………………………………3-8
3.2 CONTINUOUS PM COMPLIANCE FOR MATS ........................................................................ 3-8
SECTION 4 – HCL TEST PLAN ................................................................................................ 4-1
4.1 INITIAL HCL COMPLIANCE FOR MATS.................................................................................. 4-1
4.1.1 Ongoing Notification and Test Schedule (HCl)………………………………………………………….4-1
4.1.2 Test Program Summary (HCl)…………………………………………………………………………...4-1
4.1.3 Test Methods Summary (HCl)…………………………………………………………………………...4-2
4.1.3.1 EPA Reference Method 1 ................................................................................................................. 4-2
4.1.3.2 EPA Reference Method 2 ................................................................................................................. 4-3
4.1.3.3 EPA Reference Method 3B ............................................................................................................... 4-3
4.1.3.4 EPA Reference Method 4 ................................................................................................................. 4-3
4.1.3.5 EPA Reference Method 26A ............................................................................................................ 4-3
4.1.4 Additional Data Collection Requirements……………………………………………………………….4-4
4.1.5 Quality Assurance Activities (HCl)……………………………………………………………………...4-4
4.1.6 Calculations (HCl)……………………………………………………………………………………….4-4
4.1.7 Notification of Compliance Status (HCl)………………………………………………………………..4-5
4.2 CONTINUOUS HCl COMPLIANCE FOR MATS………………………………………………4-5

List of Tables

SECTION 2
Table 2-1. IGS Units 1 and 2 Subpart UUUUU Emission Limits ............................................................................ 2-3

SECTION 3
Table 3-1. Filterable PM Test Matrix ....................................................................................................................... 3-2
Table 3-2. Reference Method 1 Traverse Points ...................................................................................................... 3-3
Table 3-3. Traverse Point Locations in Inches ......................................................................................................... 3-3
Table 3-4. Unit Operating Parameters for Filterable PM Testing ............................................................................. 3-6

SECTION 4
Table 4-1. HCL Performance Test Matrix ................................................................................................................ 4-2
Table 4-2. Unit Operating Parameters for HCl Performance Testing ....................................................................... 4-4

List of Figures

SECTION 2
Figure 2-1. IGS Plant Process Flow Diagram ........................................................................................................... 2-1

SECTION 3
Figure 3-1. IGS Exhaust Flues and Stack Annulus ................................................................................................... 3-4
Figure 3-2. IGS Sample Level Orientation and Port Detail ...................................................................................... 3-5

1-1

SECTION 1
SITE-SPECIFIC TEST PLAN OVERVIEW

1.1 INTRODUCTION

This Site-Specific Test Plan (SSTP) has been developed by Intermountain Power Service
Corporation (IPSC) for its Intermountain Generating Station (IGS) Unit 1, in accordance with the
requirements set forth by the United States Environmental Protection Agency (USEPA) in Title
40 of Code of Federal Regulations (CFR) Part 63, Subpart UUUUU, National Emission
Standards for Hazardous Air Pollutants: Coal- and Oil-Fired Electric Utility Steam Generating
Units (i.e., the MATS Rule).

MATS affected sources are required to develop (and submit if requested or required) a site-
specific test plan for any performance tests used to demonstrate compliance. In accordance with
40 CFR §63.7(c), the test plan shall include a test program summary, the test schedule, data
quality objectives, and internal and external quality assurance activities associated with the
required performance tests. The State of Utah Division of Air Quality requires that a pre-test
protocol be submitted with notification of compliance testing. This document also stands as the
protocol for IGS MATS compliance testing specific to filterable particulate matter (PM) &
hydrochloric acid (HCl).

1.2 OBJECTIVE OF SITE-SPECIFIC TEST PLAN

IPSC recognizes that the reliability and acceptability of performance test data depends on the
completion of the activities stipulated in a comprehensive test plan. The primary objective of this
SSTP is to meet the requirements set forth by the MATS Rule [i.e. §63.10007(a)], and by
reference, §63.7(c) of the General Provisions.

This SSTP delineates the activities necessary to ensure that the performance test data are
complete, representative, precise and accurate. The following sections of this SSTP provide an
overview of the testing program and procedures that will be implemented at IGS to comply with
the requirements of Subpart UUUUU to 40 CFR Part 63 (i.e. the MATS Rule). This SSTP
includes separate sections for the performance testing that will be performed for filterable
particulate matter (PM) and hydrochloric acid (HCl). Under MATS, PM is an allowable
surrogate for non-mercury metals emissions compliance. HCl is an allowable surrogate for acid
gas emissions compliance. The IGS is therefore using these surrogates as allowed under MATS.

2-1

SECTION 2
AFFECTED FACILITY AND MATS COMPLIANCE

2.1 DESCRIPTION OF FACILITY

The IGS (Office of Regulatory Information System (ORIS) number is 6481) is located near
Delta, Utah. IGS includes two (2) dry bottom wall-fired subcritical boilers (Units 1 and 2) that
combust refined coal consisting of western bituminous and some subbituminous coal. Both units
are subject to 40 CFR Part 63, Subpart UUUUU (i.e., “steam generating units”). Units 1 and 2
are both equipped with low nitrogen oxides (NOx) burners and over-fire air (OFA) for NOx
control, fabric filters for particulate matter (PM) control, and use wet limestone for sulfur dioxide
(SO2) and acid gas control. Each boiler is served by a dedicated fiberglass flue suspended within
a single concrete chimney. The chimney is approximately 710 feet tall. The figure below
provides an overview of the plant process flow.

Figure 2-1. IGS Plant Process Flow Diagram

2-2

2.2 FACILITY ORGANIZATION

All performance testing will be performed by IPSC personnel. The summary below lists the
authorities and responsibilities at IGS:

Plant Owner: Intermountain Power Agency
10653 S. River Front Parkway, Suite 120
South Jordan, UT 84095

Operating Agent: Los Angeles Department of Water and Power
111 Hope St.
Los Angeles, CA 90012

Plant Operations and Contact: Intermountain Power Service Corporation
850 W. Brush Wellman Rd
Delta, UT 84624
435-864-4414

President and COO: Jon A. Finlinson
Project Manager: Mike Utley
Test Coordinator: Vicki Lyman
QA/QC Data: Trevor Johnson
Vicki Lyman

QA/QC Analytical Rick Moody
Team Members: Kyle Church
Trevor Johnson
Kirk Stevens

Regulatory Oversight: Utah Department of Environmental Quality
Utah Division of Air Quality
P.O. Box 144820
Salt Lake City, UT 84114-4820

2-3

2.3 MATS COMPLIANCE LIMITS

Consistent with Item 1 of Table 2 in Subpart UUUUU of 40 CFR Part 63, IGS is required to
comply with the filterable PM and HCl emission limits listed below in Table 2-1.

Table 2-1. IGS Unit 1 Subpart UUUUU Emission Limits
Plant Unit Pollutant MATS Compliance
Limit
LEE Qualification
Limit
IGS 1
Filterable
PM
0.03
lb/mmBtu
0.015
lb/mmBtu
HCl 0.002
lb/mmBtu
0.001
lb/mmBtu

2.4 MATS COMPLIANCE STRATEGY SUMMARY

Consistent with Item 1 of Table 2 in Subpart UUUUU of 40 CFR Part 63, IGS is required to
demonstrate compliance with the filterable PM and HCl emission limits listed in Table 2-1.
Unit 1 has qualified for low emitting EGU (LEE) Status for each of the pollutants listed in Table
2-1, as demonstrated by the results of previous performance tests on each unit in accordance with
the procedures set forth in 63.10005(h).

3-1

SECTION 3
FILTERABLE PM TEST PLAN

3.1 INITIAL & SUBSEQUENT PM COMPLIANCE FOR MATS

IPSC demonstrated initial compliance with the filterable PM emission limit of Subpart UUUUU
based upon an initial performance test performed on Units 1 and 2 in February 2015, prior to the
MATS compliance date of April 16, 2015. The source may demonstrate compliance with either
the heat input-based limit or the output based limit. In accordance with §63.10005(b)(1), test data
and results from a performance test conducted prior to April 16, 2015 may be used to
demonstrate initial compliance provided that it was conducted no more than 12 calendar months
prior to the compliance data and was conducted in accordance with the requirements in
§63.10007, and Table 5 of Subpart UUUUU.

The results of each quarterly performance test for three consecutive years demonstrated that
emissions were less than 50% of the applicable emissions limit; therefore, LEE Status was
acquired. Once LEE Status was achieved, the performance test frequency was reduced to once
every three years in accordance with §63.10006(b).

This section summarizes the notification requirements and test schedule, test program summary,
and data quality objectives as well as the quality assurance (QA) activities associated with the
PM performance tests.

3.1.1 Ongoing Notification and Test Schedule (Filterable PM)

In accordance with §63.10030 (d), a Notification of Intent to conduct each subsequent
performance test will be submitted at least 30 days before each subsequent performance test is
scheduled to begin.

The test schedule for ongoing performance tests for PM is outlined in the notification letter to
EPA, and the cover letter that accompanies the submittal of this document to the State of Utah.
It is anticipated that one full day will be required to complete the PM performance test on Unit 1.
Subsequent performance tests will be performed once every three years as required by
§63.10006(f).

3-2

3.1.2 Test Program Summary (Filterable PM)

Per §63.10007, IPSC will conduct performance testing for filterable PM in accordance with the
requirements of Table 5 to Subpart UUUUU. The performance test must be conducted while the
unit is operating at maximum normal operating load (nominally 90-110% of design capacity).
The performance test will be conducted at the mid-point of the chimney so as to minimize any
potential interference from flow disturbances upstream and downstream of the sampling location.
The performance test will consist of 3-runs conducted using EPA Reference Method 5 (RM-5)
with the exception that the front half filter temperature shall be maintained at 320º ±25ºF. A
minimum volume of 2 dry standard cubic meters (dscm) will be collected during each test run.

NOTE: For performance tests conducted to obtain, and/or to maintain, Low-Emitting
EGU (LEE) qualification, §63.10005(h)(2)(i) requires that the sample volume for each test run
be increased by a factor of two from the minimum volume specified in Subpart UUUUU Table 2.
Since Unit 1 has achieved LEE status, the performance tests will be conducted using a minimum
sample volume of 2 dscm.

The sampling port location and the number of traverse points will be selected using EPA Method
1. Velocity and volumetric flow rate, oxygen and carbon dioxide concentrations, and moisture
content will be determined using EPA Reference Methods 2, 3B, and 4 respectively. Table 3-1
below summarizes the test matrix and test methods that IPSC will use to meet these
requirements.

Table 3-1. Filterable PM Test Matrix
Sampling
Location
# of
Runs Sample Type/Pollutant Sampling
Method
Run
Time
(min)
Analytical
Method
Analytical
Laboratory
Outlet Stack
Midpoint NA Selection of Sample Ports
and Traverse Points
EPA
Method 1 NA Cyclonic (RM-1) IPSC
Outlet Stack
Midpoint 3 Stack Gas Velocity and
Volumetric Flow Rate
EPA
Method 2 120 Differential
Pressure (RM-2) IPSC
Outlet Stack
Midpoint 3 O2/CO2 EPA
Method 3B NA Orsat (RM-3B) IPSC
Outlet Stack
Midpoint 3 Moisture Content
in Stack Gases
EPA
Method 4 120 Gravimetric
(RM-4) IPSC
Outlet Stack
Midpoint 3
Non-sulfuric Acid
Particulate Matter from
Stationary Sources
EPA
Method 5 120 Gravimetric
(RM-5) IPSC

3-3

3.1.3 Test Methods Summary (Filterable PM)

The following sub-sections provide brief overviews of all the test methods that will be used at
IGS during the Filterable PM performance testing. Each of the test methods in Table 3-1 are
discussed. For more information on the test methods in their entirety, please see 40 CFR Part 60,
Appendix A.

3.1.3.1 EPA Reference Method 1

IPSC will be using Reference Method 1 (RM-1) for determination of the proper sampling points
for all performance testing. This method is applicable to gas streams flowing in ducts, stacks and
flues. In order to qualify as an acceptable sample location, there must be a minimum of two stack
or duct diameters between the location and any upstream flow disturbances; and a minimum of
one‐half diameters between the location and any downstream flow disturbances.

The location of each of the traverse points of the stack diameter are given below in Table 3-2.
Table 3-3 below shows the traverse point locations in inches from the outside of the ports. Each
exhaust stack has four sample ports located at 90o intervals. The ports are 6” diameter, 9” in
length, and do not project into the stack. IPSC will be using a twelve (12) point traverse for the
Filterable PM performance test as summarized in Table 3-3.

Table 3-2. Reference Method 1 Traverse Points
Traverse Point
Number
Percent of
Stack I.D.
Stack I.D.
inches
Product of
Column 2 and
3 Length
Port
Traverse Point
Location from
Outside Port
1 & 7 04.4 336 14.784 9" 23.784"
2 & 8 14.6 336 49.056 9" 58.056"
3 & 9 29.6 336 99.456 9" 108.456"
4 & 10 70.4 336 236.544 9" 245.544"
5 & 11 85.4 336 286.944 9" 295.944"
6 & 12 95.6 336 321.216 9" 330.216"
Because IPP has four ports 90 degrees around the stack, IPSC will be sampling from each port instead of going
all the way through the stack for the far points.

Table 3-3. Traverse Point Locations in Inches
Traverse Point Number Location from Outside Port in Inches
1, 4, 7, &10 23.784 = 23-3/4
2, 5, 8, & 11 58.056 = 58"
3, 6, 9, & 12 108.456 = 108-1/2

3-4

Figure 3-1 shows the sample port locations and appropriate stack dimensions for the outlet
stacks. The location of sampling ports and velocity traverse points comply with EPA Reference
Method 1 with respect to the stack diameter and the distance from the sampling ports to upstream
and downstream interferences to laminar flow. The sample ports are located at a platform 352’
above grade. The 28’ diameter exhaust stack is contained within an 80’ diameter annulus.
Sample ports are 8.96 stack diameters from the nearest upstream disturbance, and 12.72 stack
diameters from the nearest downstream disturbance. Figure 3-2 shows the sampling level with
the port orientation and port detail.

80 '
350 '
240 '
TESTING LEVEL
28 '28 '

Figure 3-1. IGS Exhaust Flues and Stack Annulus

3-5

Figure 3-2. IGS Sample Level Orientation and Port Detail

3.1.3.2 EPA Reference Method 2

IPSC will determine the stack gas velocity and volumetric flowrate using Reference Method 2
(RM-2). Velocity pressures are determined by traversing the test location with an S‐type pitot
tube. Temperatures are measured using a K‐type thermocouple with a calibrated digital
temperature indicator. The molecular weight and moisture content of the gases are determined to
permit the calculation of the volumetric flowrate. Sampling points utilized are determined using
RM-1.

3.1.3.3 EPA Reference Method 3B

IPSC will determine the carbon dioxide (CO2) and oxygen (O2) concentrations, excess air, and
dry molecular weight of the flue gas in the stack gas in accordance with Reference Method 3B
(RM-3B). RM-3B requires that a gas sample be extracted from the stack for analysis currently
with each of the three (3) Reference Method 5B (RM-5B) test runs. The integrated gas sample is
then analyzed via an Orsat for CO2 and O2. The nitrogen value is obtained by difference.

3-6

3.1.3.4 EPA Reference Method 4

IPSC will determine the flue gas moisture content in accordance with Reference Method 4 (RM-
4). In this application it will be used in the calculation of volumetric flow rate. A gas sample will
be extracted at a constant rate from the source. Moisture will be removed from the sample stream
by a series of pre‐weighed impingers immersed in an ice bath. A minimum of 21 dry standard
cubic feet of flue gas will be collected during each sample run.

3.1.3.5 EPA Reference Method 5

IPSC will determine the filterable PM using Reference Method 5 (RM-5) in accordance with the
requirements in Table 5 of 40 CFR Part 63, Subpart UUUUU. NOTE: RM 2‐4 will be performed
concurrently with, and as an integral part of these determinations. Flue gas is withdrawn
isokinetically from the source at traverse points determined per RM-1, and filterable PM will be
collected in the nozzle, probe liner, and on a glass fiber filter. The filterable PM will then be
gravimetrically determined and the results will be used to calculate the filterable PM
concentration.

The probe liner and filter are maintained at a temperature of 160 ± 14 °C (320 ± 25 °F). The
filter media for this testing will be quartz in order to minimize any adverse bias related to SO2
and/or SO3 acquisition as condensable particulate. These quartz filters are typically baked for 3
hours at 320 degrees (F) as is described in 40 CFR 60, Appendix A, Reference Method 5B (RM-
5B) in order to volatize any residual sulfate residue. However, as is specified in the MATS
modification to RM- 5, the filters will not be baked during the analysis portion of the program.
The filter will be analyzed at the site laboratory with strict adherence to RM-5. The gravimetric
analyses will be performed onsite by IPSC personnel.

3.1.4 Additional Data Collection Requirements

In order to meet the requirements of §63.10007(a)(2), certain boiler and fabric filter operating
data will be collected during the performance test. These data will help identify the expected
operating conditions for future tests as well as demonstrate the stability of the units and
representativeness of unit operations during each performance test. A summary of the unit
operating parameters that will be collected during the performance test is provided below in
Table 3-4.

Table 3-4. Unit Operating Parameters for Filterable PM Testing
Data Source Data Description Data Units
Boiler Data Gross Unit Load Megawatts (MW)
Fuel Type not low rank virgin coal
Fabric Filter Data Sectional Differential
Pressure Delta P
Scrubber Data Modules in Service # of Modules

3-7

3.1.5 Data Quality Objectives and Quality Assurance Activities (Filterable PM)

IPSC is committed to collecting quality data during all performance testing. The primary data
quality objective of the performance testing in this test plan is to collected data that are accurate
and representative of the unit operation.

In order to ensure all the data collected during the performance test is of acceptable quality, IPSC
will strictly follow all of the quality assurance (QA) activities that are required for each of the
test methods that will be used (e.g. leak checks, dry gas meter calibrations, pitot tube
calibrations, temperature sensor calibrations, etc.). Each Reference Method (RM) has its own set
of detailed QA activities. For details regarding the exact QA activities and performance
specification, please see each of the RMs that are listed in this test plan. For more information
about the RMs to be used during the performance test and all of the specific QA activities and
performance specifications, please see each specific RM which can be found in 40 CFR Part 60,
Appendix A. IPSC personnel will perform all of the QA activities required and ensure that all of
the performance specifications are met.

3.1.6 Example Calculations (Filterable PM)

The F-factor methodology detailed in Reference Method 19 (RM-19) will be used to convert
emissions concentrations from the performance testing to lb/mmBtu or lb/hr.

d
cd COFKCE
2
100=
Where:

E = Pollutant emission rate for the performance test run (lb/mmBtu)
K = 6.24 x 10-8 conversion factor for PM (lb-scm/mg-scf)
Cd = Average performance test reference method pollutant concentration, dry basis
(mg/dscm)
Fc = 1,800 for bituminous coal (scf CO2/mmBtu)
CO2d = Average performance test reference method CO2 value measured, dry basis (%)

QKCMwh=
Where:

Mh = Average PM mass emission rate for the performance test run (lb/hr)
K = 6.24 x 10-8 conversion factor for PM (lb-scm/mg-scf)
Cw = Average performance test reference method pollutant concentration, wet basis.
(mg/wscm)
Q = Average performance test reference method stack flow rate (scfh)

3-8

If compliance is based on the output-based limitation, the electrical output data will be used to
convert the measured emissions to lb/MWh.

MW
ME h
ho =
Where:

Eho = Electrical output-based mass emission rate (lb/MWh)
Mh = Average pollutant emission rate during the performance test run (lb/hr)
MW = Average gross megawatts (MW) measured during the performance test run

3.1.7 Notification of Compliance Status (PM)

In accordance with §63.10005(k), §63.10030(e) and §63.9(h)(2)(ii), a Notification of
Compliance Status will be submitted within sixty (60) days of completing the performance test.
The report must include a description of the source, a summary of the results, and an
identification of the emission limit and a comparison of the emission level to the 50 percent
emission limit threshold. The notification must include a certification of compliance and must be
signed by a responsible official.

3.2 CONTINUOUS PM COMPLIANCE FOR MATS

To demonstrate continuous compliance with the filterable PM emission limit of Subpart
UUUUU, IPSC will conduct performance testing, once every three years. The performance
testing will be conducted as detailed in Section 3.1.1 through 3.1.6 above.

NOTE: For performance tests conducted to obtain and/or to maintain Low-Emitting
EGU (LEE) qualification, §63.10005(h)(2)(i) requires that the sample volume for each test run
be increased by a factor of two from the minimum volume specified in Subpart UUUUU Table 2.
Since each unit is qualified as LEE, the performance tests will be conducted using a minimum
sample volume of 2 dscm.

Since the performance test results for three consecutive years were less than 50 percent of the
applicable emissions limit, the unit qualified for LEE status for filterable PM. Once LEE status
was obtained, IPSC must repeat the PM performance test once every 3 years. In accordance with
§63.10006(f), performance tests that are required every three years, must be started at least 1,050
calendar days, measured from the previous test’s end date. As detailed in §63.10006(h), if a
performance test shows emissions in excess of 50 percent of the emission limit, performance
tests must be conducted for a 3-year period to reapply for LEE status.

4-1

SECTION 4
HCL TEST PLAN

4.1 INITIAL & SUBSEQUENT HCL COMPLIANCE FOR MATS

IPSC demonstrated initial compliance with the filterable HCl emission limit of Subpart UUUUU
based upon an initial performance test performed on Units 1 and 2 in February 2015, prior to the
MATS compliance date of April 16, 2015. The source may demonstrate compliance with either
the heat input-based limit or the output based limit. In accordance with §63.10005(b)(1), test data
and results from a performance test conducted prior to April 16, 2015 may be used to
demonstrate initial compliance provided that it was conducted no more than 12 calendar months
prior to the compliance data and was conducted in accordance with the requirements in
§63.10007, and Table 5 of Subpart UUUUU.

The results of each quarterly performance test for three consecutive years demonstrated that
emissions were less than 50% of the applicable emissions limit; therefore, LEE Status was
acquired. Once LEE Status was achieved, the performance test frequency was reduced to once
every three years in accordance with §63.10006(b).

This section summarizes the notification requirements and test schedule, test program summary,
and data quality objectives as well as the quality assurance (QA) activities associated with the
HCl performance tests.

4.1.1 Ongoing Notification and Test Schedule (HCl)

In accordance with §63.10030 (d), a Notification of Intent to conduct each subsequent
performance test will be submitted at least 30 days before each subsequent performance test is
scheduled to begin.

The test schedule for ongoing performance tests for HCl is outlined in the notification letter to
EPA, and the cover letter that accompanies the submittal of this document to the State of Utah.
It is anticipated that one full day will be required to complete the HCl performance tests on Unit
1. Subsequent performance tests will be performed once every three years as required by
§63.10006(f).

4.1.2 Test Program Summary (HCl)

Per §63.10007, IPSC will conduct performance testing for HCl in accordance with the
requirements of Table 5 to Subpart UUUUU. Each performance test must be conducted while the
unit is operating at maximum normal operating load (nominally 90-110% of design capacity).
The performance test will be conducted at the mid-point of the chimney so as to minimize any
potential interference from flow disturbances upstream and downstream of the sampling location.
The performance test will consist of 3-runs conducted using EPA Reference Method 26A (RM-
26A). A minimum volume of 1.5 dry standard cubic meters (dscm) will be collected during each
test run.

4-2

NOTE: For performance tests conducted to obtain and/or to maintain Low-Emitting
EGU (LEE) qualification, §63.10005(h)(2)(i) requires that the sample volume for each test run
be increased by a factor of two from the minimum volume specified in Subpart UUUUU Table 2.
Since Unit 1 has achieved LEE status, the performance test will be conducted using a minimum
sample volume > 1.5 dscm.

The sampling port location and the number of traverse points will be selected using EPA
Reference Method 1. Velocity and volumetric flow rate, oxygen and carbon dioxide
concentrations, and moisture content will be determined using EPA Reference Methods 2, 3B,
and 4 respectively. Table 4-1 below summarizes the test matrix and test methods that IPSC will
use to meet these requirements.

Table 4-1. HCL Performance Test Matrix
Sampling
Location
# of
Runs Sample Type/Pollutant Sampling
Method
Run
Time
(min)
Analytical
Method
Analytical
Laboratory
Outlet Stack
Midpoint NA Selection of Sample Ports
and Traverse Points
EPA
Method 1 NA Cyclonic (RM-1) IPSC
Outlet Stack
Midpoint 3 Stack Gas Velocity and
Volumetric Flow Rate
EPA
Method 2 120 Differential
Pressure (RM-2) IPSC
Outlet Stack
Midpoint 3 O2/CO2 EPA
Method 3B NA Orsat (RM-3B) IPSC
Outlet Stack
Midpoint 3 Moisture Content
in Stack Gases
EPA
Method 4 120 Gravimetric
(RM-4) IPSC
Outlet Stack
Midpoint 3
Determination of
Hydrogen Halide and
Halogen Emissions from
Stationary Sources
EPA
Method 26A 120
Ion
Chromatography
(RM-26A)
IPSC

4.1.3 Test Methods Summary (HCl)

The following sub-sections provide brief overviews of all the test methods that will be used at
IGS during the HCl performance testing. Each of the test methods in Table 4-1 are discussed.
For more information on the test methods in their entirety, please see 40 CFR Part 60, Appendix
A. All of the test methods used for the HCl performance testing will be the same as the Filterable
PM testing, except the HCl performance testing will use RM 26A rather than RM 5.

4.1.3.1 EPA Method 1

IPSC will be using Reference Method 1 (RM-1) for determination of the proper sampling points
for all performance testing. This method is applicable to gas streams flowing in ducts, stacks and
flues. In order to qualify as an acceptable sample location, there must be a minimum of two stack
or duct diameters between the location and any upstream flow disturbances; and a minimum of
one‐half diameters between the location and any downstream flow disturbances.

4-3

The sample points for the HCl performance testing will be the same as those summarized in
Tables 3-2 and 3-3 of Section 3 of this SSTP. These sampling points are the same for both the
HCl and the Filterable PM performance testing.

4.1.3.2 EPA Method 2

IPSC will determine the stack gas velocity and volumetric flowrate using Reference Method 2
(RM-2). Velocity pressures are determined by traversing the test location with an S‐type pitot
tube. Temperatures are measured using a K‐type thermocouple with a calibrated digital
temperature indicator. The molecular weight and moisture content of the gases are determined to
permit the calculation of the volumetric flowrate. Sampling points utilized are determined using
RM-1.

4.1.3.3 EPA Method 3B

IPSC will determine the carbon dioxide (CO2) and oxygen (O2) concentrations, excess air, and
dry molecular weight of the flue gas in the stack gas in accordance with Reference Method 3B
(RM-3B). RM-3B requires that a gas sample be extracted from the stack for analysis currently
with each of the three (3) Reference Method 5B (RM-5B) test runs. The integrated gas sample is
then analyzed via an Orsat for CO2 and O2. The nitrogen value is obtained by difference.

4.1.3.4 EPA Method 4

IPSC will determine the flue gas moisture content in accordance with Reference Method 4 (RM-
4). In this application it will be used in the calculation of volumetric flow rate. A gas sample will
be extracted at a constant rate from the source. Moisture will be removed from the sample stream
by a series of pre‐weighed impingers immersed in an ice bath. A minimum of 21 dry standard
cubic feet of flue gas will be collected during each sample run.

4.1.3.5 EPA Method 26A

IPSC will determine the HCl concentration of the flue gas using Reference Method 26A (RM-
26A) in accordance with the requirements in Table 5 of 40 CFR Part 63, Subpart UUUUU.
NOTE: RM 2‐4 will be performed concurrently with, and as an integral part of these
determinations.

In RM-26A, flue gas is withdrawn isokinetically from the source at traverse points determined
per RM-1, and filterable PM will be collected on a particulate filter as well as absorbing
solutions. Following the particulate filter, acidic and alkaline absorbing solutions collect the
gaseous hydrogen halides and halogens, respectively. The hydrogen halides are solubilized in
the acidic solution and form chloride (Cl-), bromide (Br-), and fluoride (F-) ions. The halogens
have very little solubility in the acidic solution and pass through the alkaline solutions where
they are absorbed. The Cl- ions formed in the acidic solution are then measured using ion
chromatography (IC). The amount of Cl- ions measured from the acid solution by IC are then
used to determine the HCl concentration of the effluent. The IC analyses will be performed in an
onsite laboratory by IPSC personnel.

4-4

4.1.4 Additional Data Collection Requirements

In order to meet the requirements of §63.10007(a)(2), certain boiler and control device operating
data will be collected during each performance test. These data will help identify the expected
operating conditions for future tests as well as demonstrate the stability of the units and
representativeness of unit operations during each performance test. A summary of the unit
operating parameters that will be collected during each performance test is provided below in
Table 4-2.

Table 4-2. Unit Operating Parameters for HCl Performance Testing
Data Source Data Description Data Units
Boiler Data Gross Unit Load Megawatts (MW)
Fuel Type Bituminous Coal
Fabric Filter Data Compartments in Service # of Compartments
Scrubber Data Modules in Service # of Modules

4.1.5 Data Quality Objectives and Quality Assurance Activities (HCl)

IPSC is committed to collecting quality data during all performance testing. The primary data
quality objective of the performance testing in this test plan is to collected data that are accurate
and representative of unit operations.

In order to ensure all the data collected during the performance tests are of acceptable quality,
IPSC will strictly follow all of the quality assurance (QA) activities that are required for each of
the test methods that will be used (e.g. leak checks, dry gas meter calibrations, pitot tube
calibrations, temperature sensor calibrations, etc.). Each Reference Method (RM) has its own set
of detailed QA activities. For details regarding the exact QA activities and performance
specification, please see each of the RMs that are listed in this test plan. For more information
about the RMs to be used during these performance tests and all of the specific QA activities and
performance specifications, please see each specific RM which can be found in 40 CFR Part 60,
Appendix A. IPSC personnel will perform all of the QA activities required and ensure that all of
the performance specifications are met.

4.1.6 Calculations (HCl)

The F-factor methodology detailed in EPA Method 19 will be used to convert emissions
concentration to lb/mmBtu or lb/hr.

d
cd COFKCE
2
100=
Where:

E = Pollutant emission rate for the performance test run (lb/mmBtu)
K = 6.24 x 10-8 conversion factor for HCl (lb-scm/mg-scf)

4-5

Cd = Average performance test reference method pollutant concentration, dry basis
(mg/dscm)
Fc = 1,800 for bituminous coal (scf CO2/mmBtu)
CO2d = Average performance test reference method CO2 value measured, dry basis (%)

QKCMwh=
Where:

Mh = Average HCl mass emission rate for the performance test run (lb/hr)
K = 6.24 x 10-8 conversion factor for HCl (lb-scm/mg-scf)
Cw = Average performance test reference method pollutant concentration, wet basis.
(mg/wscm)
Q = Average performance test reference method stack flow rate (scfh)

If compliance is based on the output-based limitation, the electrical output data will be used to
convert the measured emissions to lb/MWh.

MW
ME h
ho =
Where:

Eho = Electrical output-based mass emission rate (lb/MWh)
Mh = Average HCl mass emission rate for the hour (lb/hr)
MW = Average gross megawatts (MW) measured for the hour

4.1.7 Notification of Compliance Status (HCl)

In accordance with §63.10005(k), §63.10030(e) and §63.9(h)(2)(ii), a Notification of
Compliance Status will be submitted within sixty (60) days of completing t he performance test.
The notification must include a certification of compliance and must be signed by a responsible
official.

4.2 CONTINUOUS HCl COMPLIANCE FOR MATS

To demonstrate continuous compliance with the filterable PM emission limit of Subpart
UUUUU, IPSC will conduct performance testing, once every three years, on each unit. The
performance testing will be conducted as detailed in Section 4.1.1 through 4.1.6 above.

NOTE: For performance tests conducted to obtain and/or to maintain Low-Emitting
EGU (LEE) qualification, §63.10005(h)(2)(i) requires that the sample volume for each test run
be increased by a factor of two from the minimum volume specified in Subpart UUUUU Table 2.
Since each unit is qualified as LEE, the performance tests will be conducted using a minimum
sample volume of 1.5 dscm.

4-6

Since the performance test results for three consecutive years were less than 50 percent of the
applicable emissions limit, the unit qualifies for LEE status for HCl. With LEE status, IPSC
must repeat the HCl performance test once every three years. In accordance with §63.10006(f),
performance tests that are required every three years, must be started at least 1,050 calendar
days, measured from the previous test’s end date. As detailed in §63.10006(h), if a performance
test shows emissions in excess of 50 percent of the emission limit, performance tests must be
conducted for a 3-year period to reapply for LEE status.