DAQ-2024-007733

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DAQC-401-24
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, 2024

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

INSPECTION DATE: April 17, 2024

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

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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. 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 1501001005, Dated January 22, 2020; last
revision August 26, 2021
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.

Status:
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)

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

I.B Permitted Activity(ies).

Status:
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)

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

Status:
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))

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

Status:
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))

The permit expires January 22, 2025. Application for renewal is due July 25, 2024.

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I.E Application Shield.

Status:
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))

Application for renewal is due July 25, 2024.

I.F Severability.

Status:
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))

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

Status:
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))

In compliance – Emission inventory was paid as invoiced.

I.H No Property Rights.

Status:
This permit does not convey any property rights of any sort, or any exclusive privilege.
(R307-415-6a(6)(d))

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

I.I Revision Exception.

Status:
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))

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

Status:
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))

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

I.K Certification.

Status:
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. All application forms, reports, or compliance certifications submitted
pursuant to this permit did contain certification as to its truth, accuracy, and completeness,
by a responsible official as defined in R307-415-3. The certification received prior to this
inspection did state that, based on information and belief formed after reasonable inquiry,
the statements and information in the document are true, accurate, and complete.

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;

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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;

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 29, 2024
(due April 1, 2024), 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)
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I.M.2.c The applicable requirements of the Acid Rain Program, consistent with the CAA
Section 408(a). (R307-415-6f(3)(c))

I.M.2.d

Status:
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))

N/A – See section III of this permit.

I.N Emergency Provision.

I.N.1 An "emergency" is any situation arising from sudden and reasonably unforeseeable events
beyond the control of the source, including acts of God, which situation requires immediate
corrective action to restore normal operation, and that causes the source to exceed a
technology-based emission limitation under this permit, due to unavoidable increases in
emissions attributable to the emergency. An emergency shall not include noncompliance to
the extent caused by improperly designed equipment, lack of preventive maintenance,
careless or improper operation, or operator error. (R307-415-6g(1))

I.N.2 An emergency constitutes an affirmative defense to an action brought for noncompliance
with such technology-based emission limitations if the affirmative defense is demonstrated
through properly signed, contemporaneous operating logs, or other relevant evidence that:

I.N.2.a An emergency occurred and the permittee can identify the causes of the emergency.
(R307-415-6g(3)(a))

I.N.2.b The permitted facility was at the time being properly operated. (R307-415-6g(3)(b))

I.N.2.c During the period of the emergency the permittee took all reasonable steps to
minimize levels of emissions that exceeded the emission standards, or other
requirements in this permit. (R307-415-6g(3)(c))

I.N.2.d The permittee submitted notice of the emergency to the Director within two
working days of the time when emission limitations were exceeded due to the
emergency. This notice must contain a description of the emergency, any steps
taken to mitigate emissions, and corrective actions taken. This notice fulfills the
requirement of Provision I.S.2.c below. (R307-415-6g(3)(d))

I.N.3 In any enforcement proceeding, the permittee seeking to establish the occurrence of an
emergency has the burden of proof. (R307-415-6g(4))

I.N.4

Status:
This emergency provision is in addition to any emergency or upset provision contained in
any other section of this permit. (R307-415-6g(5))

No emergencies were reported in the past year.

I.O Operational Flexibility.

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

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I.P Off-permit Changes.

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

I.Q Administrative Permit Amendments.

Administrative permit amendments are governed by R307-415-7e.
I.R Permit Modifications.

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

These are statements of fact and not inspection items (I.O through I.R).

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.

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

Status:
Additional record keeping requirements, if any, are described in Section II, Special
Provisions.

In compliance – Required records were made available at the time of the inspection.

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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:

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

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

Environmental Protection Agency, Region VIII
Office of Partnerships and Regulatory Assistance Air and Radiation Program (mail
code 8P-AR)
1595 Wynkoop Street
Denver, CO 80202-1129
Phone: [phone]

In compliance – 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

Status:
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))

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

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I.U Inventory Requirements.

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

In compliance – The annual 2023 emission inventory was submitted and shows in
review in the SLEIS database.

I.V Title IV and Other, More Stringent Requirements

Status:
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))

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 and 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 and 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.

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

II.A.9 Ash Haul Road (dirt) (EU #10a)
Unpaved ash haul road. No unit-specific applicable requirements.

II.A.10 Ash Haul Road (paved) (EU #10b)
Paved ash haul road. No unit-specific applicable requirements.

II.A.11 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.12 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.13 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.14 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.15 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.16 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.17 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.18 Oil Storage Area (EU #22)
Storage area for oil storage drums. No unit-specific applicable requirements.

II.A.19 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.20 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.21 Miscellaneous Electrical Equipment (EU #25)
Fugitive emission units including transformer insulating oil. No unit-specific
applicable requirements.
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II.A.22 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.23 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.

II.A.24 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.25 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.26 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.27 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.28 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.29 Ash Unloader for Unit #1 (EU #32)
Equipment for unloading ash from silos and into trucks for transport to the ash landfill.
No unit-specific applicable requirements

II.A.30 Ash Unloader for Unit #2 (EU #33)
Equipment for unloading ash from silos and into trucks for transport to the ash landfill.
No unit-specific applicable requirements

II.A.31 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.32 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.33 Central Accumulation Area (EU #36)
Area where hazardous waste is stored temporarily awaiting disposal. No unit-specific
applicable requirements.

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II.A.34 Electro-hydraulic Control Reservoirs (EU #37)
Two 400 gallon tanks that store lubricating oil. No unit-specific applicable
requirements.

II.A.35 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.36 Paint Storage Areas (EU #40)
Various storage areas for sealed paint containers. No unit-specific applicable
requirements.

II.A.37 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.38 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.39 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.40 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.41 Unit #2 Fabric filter Group (EU #45)
One fabric filter for fly ash silo bin vent.

II.A.42 Unit #2 Fabric filters Group (EU #46)
Includes a total of five fabric filters, one fabric filters for each of the two waste
lime/limestone day bin vents, one fabric filters for each of the two lime/limestone silo
day bin vents, and one fabric filter for lime/limestone silo vent.

II.A.43 Research Farm 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.44

II.A.45

Load-out Conveyor (EU# 48)
Gypsum load-out conveyor

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

15
II.A.46

II.A.47

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

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

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.14/15 are no longer in use. Painting is no longer conducted in-house,
but rather contracted out. Therefore, paint is no longer stored on-site (item
II.A.36). II.A.42 only three of five listed fabric filters are in use; the waste lime
silo filters are not installed. Finally, it should be noted that the ash unloader for
unit #1 (item II.A.29) is synonymous with the hi carbon ash silo (item II.A.46)
and the ash unloader for unit #2 (item II.A.30) is synonymous with the feed ash
silo (item II.A.47). The research farm pump is moved off site (II.A.43). Salt River
has a standalone permit for its equipment located on this site.

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-AN102380029-18]. [R307-205-5]

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

Status:
Reporting:

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

In compliance – On April 13, 2020, PacifiCorp submitted an updated Fugitive
Dust Control Plan (FDCP) for its Huntington Plant. The plan has been reviewed
and deemed acceptable.

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]

16
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

Status:
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.

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-AN102380029-18]. [R307-203-1(1)]

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.

17
II.B.1.c.3

Status:
Reporting:

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

In compliance – According to a monthly report provided by Sinclair Wyoming
Refining Company low sulfur fuel (LSD) 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-AN102380029-18]. [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.

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

Status:
Reporting:

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

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.

18
II.B.1.e Condition:

Visible emissions shall be no greater than 20 percent opacity unless otherwise specified in this
permit. [Origin: DAQE-AN102380029-18][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.

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-AN102380029-18]. [40
CFR 60 Subpart A, R307-401-8(2)]

II.B.1.f.1 Monitoring:

Records required for this permit condition will serve as monitoring.

19
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

Status:
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.

In compliance – Maintenance activities are documented on a work order system in
the SAP database. The annual projection of planned outages, dated January 3,
2024, 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- AN102380031-19].
[R307-401-8, R307-405-21(1)]

II.B.1.g.1 Monitoring:

SO2 and NOx emissions shall be monitored in accordance with 40 CFR part
52.21(aa)(12), 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
20
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]

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]

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]

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 3,105 844
Plant-wide NOX/ 7,971 3385
Plant-wide NOX/SIP 6,604 3385

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.

21
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-AN102380029-18]. [40 CFR 60 Subpart D,
R307-401-8(1)(a)(BACT)]

II.B.2.a.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:

▪ Installation and Measurement Location
▪ Equipment Specifications (except the requirement for a low range in
2.1.1.2 of Appendix A of 40 CFR Subpart 75)
▪ Performance Specifications
▪ Data Acquisition and Handling Systems
▪ 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.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)
and (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.
22
(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 0.06 lb/MMBtu and 108 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-AN102380029-18]. [40 CFR 60 Subpart D,
R307-401-8(1)(a)(BACT)]

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).

(b) Each continuous emission monitoring system shall meet the requirements in 40 CFR
Part 75, Appendix A, Specification and Test Procedures as outlined below:

▪ Installation and Measurement Location
▪ Equipment Specifications (except the requirement for a low range in
2.1.1.2 of Appendix A of 40 CFR Subpart 75)
▪ Performance Specifications
▪ Data Acquisition and Handling Systems
▪ 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
23
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)
and (f) and R307-415-6a(3)(B)(ii)))

II.B.2.b.3

Status:
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))

In compliance – Reviewed records indicated NOx of 0.21 lb/MMBtu and 360 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.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-AN102380029-18]. [40 CFR 60
Subpart D, R307-401-8(1)(a)(BACT)]

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.

24
(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.

25
(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).

26
(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 February 21, 2023:

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

II.B.2.d

*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 (DAQC-452-23).
CAM information is submitted with the I.S.2 six-month reports. The last report
was dated May 22, 2023. Testing was done February 23, 2024, with no results at
time of memo.

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-
AN102380029-18]. [40 CFR 60 Subpart D, R307-401-8(1)(a)(BACT)]

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:

● 40 CFR 60.13, Monitoring requirements (subparagraphs (d) and (f))

● 40 CFR Part 60, Appendix B, Performance Specification 1, Specifications and
Test Procedures for Opacity Continuous Emission Monitoring Systems in
Stationary Sources

● 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
27
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)
and (f) and R307-415-6a(3)(B)(ii)))

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. COMS readings during the inspection were 6 minute average of 2%
and 24 hour average of 1%. DAQ inspector Method 9 reading on Unit #1 was 0%
(see VEO sheet).

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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

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.

28
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.

(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

Status:
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.

In compliance – The on-site daily air report indicated CO of 0.04 lb/MMBtu and
84 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.

29
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.

II.B.2.f.3

Status:
Reporting:

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

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
30
(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.

(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 you, 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.

31
(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.

II.B.2.g.3

Status:
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.

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 22,
2023, through April 25, 2023, to demonstrate compliance with the emission limits
found in Title V permit conditions. The DAQ-calculated test results are:

32
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 pending.

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 #1 tune-ups were 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 24, 2023, and August 2, 2023. 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]

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.

33
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 2023 mercury emission rate was 0.0068 lbs/TBTU
(6.8x10-9 lbs/MMBtu) which is less than the limit of 6.8x10-7 lbs/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, with results
pending (see condition above). Outage reports are submitted and maintained
on-site. CEM unavailability reports are submitted with MATS semiannual
reports. The 2023 annual mercury assessment report was sent to DAQ as
required.

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-
0102380029-18]. [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:

● 40 CFR 60.13, Monitoring requirements (subparagraphs (d) and (f))

● 40 CFR Part 60, Appendix B, Performance Specification 1, Specifications and
Test Procedures for Opacity Continuous Emission Monitoring Systems in
Stationary Sources

● R307-170, Continuous Emission Monitoring System Program

34
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.

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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

II.B.3.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).

(b) Each continuous emission monitoring system shall meet the requirements in 40
CFR Part 75, Appendix A, Specification and Test Procedures as outlined below:

▪ Installation and Measurement Location

▪ Equipment Specifications (except the requirement for a low range in
2.1.1.2 of Appendix A of 40 CFR Subpart 75)

35
▪ Performance Specifications

▪ Data Acquisition and Handling Systems

▪ 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

Status:
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.

In compliance – Reviewed records indicated no averages as unit two was coming
online during inspection. 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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

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).
36
(b) Each continuous emission monitoring system shall meet the requirements in 40
CFR Part 75, Appendix A, Specification and Test Procedures as outlined below:

▪ Installation and Measurement Location

▪ Equipment Specifications (except the requirement for a low range in
2.1.1.2 of Appendix A of 40 CFR Subpart 75)
▪ Performance Specifications

▪ Data Acquisition and Handling Systems

▪ 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.

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 no averages as unit two was coming
online during inspection. 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.

37
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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

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.

(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
38
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.

(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.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.

39
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 February 22, 2023. The DAQ-calculated test results were:

Pollutant Limits (lb/hr) DAQ Results (lb/hr) Test Results (lb/hr)
PM 70 44 44

See DAQC-452-23 for DAQ review. Most recent test was March 16, 2024, with
results pending.

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.

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

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]

41
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.

(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 you, 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].

42
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.

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.

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]

43

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

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 22,
2023, through April 25, 2023, to demonstrate compliance with the emission limits
found in Title V permit conditions. The DAQ-calculated test results are:

See DAQC-641-23 for latest test memo. PM LEE status was acknowledged by the
DAQ on April 3, 2018. MATS PM test frequency is reduced to once every 36
months. Most recent testing was concluded March 19, 2024, with results pending.

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
September 9, 2021. 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]

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
44
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

Status:
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.

In compliance – Unit #2 2023 mercury emission rate was .0033 lbs/TBTU (3.3x10-
9 lbs/MMBTU) which is less than the limit of 6.5x10-7 lbs/MMBtu. Mercury CEMS
were discontinued upon achievement of Mercury LEE status in 2016. Outage
reports are submitted and maintained on-site. CEM unavailability reports are
submitted with MATS semiannual reports. The 2023 annual mercury assessment
report was sent to DAQ as required. The most recent testing was completed
March 19, 2024, with results pending.

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-
AN102380029-18]. [R307-401-8(1)(a)(BACT)]

II.B.4.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

45
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). Any operation other than emergency operation, maintenance
and testing, emergency demand response, and operation in non-emergency situations for 50
hours per year, paragraphs 40 CFR 63.6640(f)(1) through (4), is prohibited. If the engine is not
operated in accordance with 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 annually, whichever comes first.

(b) Inspect air cleaner every 1,000 hours of operation or annually, whichever comes first;

(c) Inspect all hoses and belts every 500 hours of operation or annually, whichever comes first,
and replace as necessary.

(3) The permittee has the option to utilize an oil 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.

(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]

46
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 has the option of utilizing an oil analysis program in order to extend the
specified oil change requirement in accordance with 40 CFR 63.6625(i).

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)]

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]
47
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. [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)]

48
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 engine operated for 16.0
maintenance hours for the calendar year 2023. The Semi-Annual Compliance
Reports, regarding the emergency fire pump, were submitted to DAQ as
required. No deviations were reported.

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. [40 CFR 63 Subpart ZZZZ]
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.

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]

49
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 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-AN102380029-18]. [40 CFR 60 Subpart Y,
R307-401-8(1)(a)(BACT)]

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.

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.

50
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 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-AN102380029-18]. [40 CFR 60 Subpart Y,
R307-401-8(1)(a)(BACT)]

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 time of the inspection. The
log indicated that VEOs are conducted when emissions are observed, and that
maintenance is performed when required.

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]

51
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 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

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

52
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 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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

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 time of the inspection. The
log indicated that VEOs are conducted when emissions are observed, and that
maintenance is performed when required.

II.B.11 Conditions on Unit #2 Fabric filter Group (EU #45).

II.B.11.a Condition:

Visible emissions shall be no greater than 10 % opacity. [Origin: DAQE-AN102380029-18].
[R307-401-8(1)(a)(BACT)]

53
II.B.11.a.1 Monitoring:

(a) Measurement Approach: A visual observation of each affected unit shall be made
at least once each day using 40 CFR Part 60, Appendix A, Reference Method 22-like
procedures.

(b) Indicator Range: An excursion is defined as the presence of visible emissions. If
visible emissions are noted, a Method 9 VEO shall be conducted to determine the
percent opacity or maintenance shall be performed on the affected unit to correct the
problem within 24 hours of the initial observation.

(c) Performance Criteria:

(1) Data Representativeness: A visual observation shall be made on each applicable
emission point.

(2) QA/QC Practices and Criteria: The visual observer shall be familiar with Reference
Method 22 and follow Method 22-like procedures. The opacity determination shall be
conducted by a certified VEO in accordance with 40 CFR 60, Appendix A, Method 9.

(3) Monitoring Frequency: A Method 22-like observation shall be performed daily for
each affected unit. The observation shall be conducted for a period of no less than six
minutes.

(4). Data Collection Procedure: The observation shall be documented by the observer
and all data required by 40 CFR 60, Appendix A, Method 9 shall be maintained if the
opacity determination is conducted. (40 CFR 64.3)

II.B.11.a.2 Recordkeeping:

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

54
II.B.11.a.3 Reporting:

In addition to the reporting requirement described in Provision I.S.2 of this permit, the
monitoring report shall include, at a minimum, the following information, as
applicable:

(a) Summary information on the number, duration and cause (including unknown
cause, if applicable) of excursions or exceedances, as applicable, and the corrective
actions taken;(40 CFR 64.9(a)(2)(i))

Status: In compliance – According to the source, daily 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 that
maintenance is performed when required.

II.B.12 Conditions on Unit #2 Fabric filters Group (EU #46).

II.B.12.a Condition:

Visible emissions shall be no greater than 10 % opacity from each affected unit. [Origin:
DAQE-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

II.B.12.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.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:

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.

55
II.B.13 Conditions on Research Farm Water Pump Engine (EU #47)

II.B.13.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 to10 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.13.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))

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)).

II.B.13.a.2 Recordkeeping:

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

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II.B.13.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.13.b Condition:

The permittee shall purchase diesel fuel that meets the following standards of 40 CFR
80.510(b) 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.13.b.1 Monitoring:

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

II.B.13.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.

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

II.B.14 Conditions on Load-out Conveyor (EU# 48)

II.B.14.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-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

II.B.14.a.1 Monitoring:

Records required for this permit condition will serve as monitoring.

57
II.B.14.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.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 the gypsum load-out conveyors are
covered and discharge 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.14.b Condition:

Visible emissions shall be no greater than 10% opacity at the conveyor drop point for the
gypsum load-out system. [Origin: DAQE-AN102380029-18]. [R307-401-8(1)(a)(BACT)]

II.B.14.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.14.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.14.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 time of the inspection. The log indicated that VEOs
are conducted when emissions are observed, and maintenance is performed when
required.

II.B.15 Conditions on Soda Ash Silo (EU #49)

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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 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 Hi Carbon Ash Silo (EU #50)

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.

59
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.B.17 Conditions on Feed Ash Silo (EU #51)

II.B.17.a Condition:

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

II.B.17.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.17.a.2 Recordkeeping:

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

II.B.17.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
(R307-415-6a(10))

Not applicable to this source.

II.D Alternative Operating Scenarios.
(R307-415-6a(9))

Not applicable to this source.

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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 220F, 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.

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)

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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 gallon 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.

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.

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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.

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.

63
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

Status:
An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
does not constitute a property right.

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

IV.D Nitrogen Oxides Requirements

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

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.

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;
64
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

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.

65
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.

IV.H.8 The owners and operators of a unit governed by an approved early election plan shall be
liable for any violation of the plan or 40 CFR 76.8 at that unit. The owners and operators
shall be liable, beginning January 1, 2000, for fulfilling the obligations specified in 40
CFR Part 77.

Status: For informational purposes only.

IV.I Effect on Other Authorities.

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,

66
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 2022 Total Emission Inventory Summary:

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