DAQ-2024-007737

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DAQC-394-24
Site ID 10237 (B1)

MEMORANDUM

TO: FILE – PACIFICORP – Hunter Power Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Joseph Randolph, Environmental Scientist

DATE: April 29, 2024

SUBJECT: FULL COMPLIANCE EVALUATION, Major, Emery County,
FRS #UT0000004901500101

INSPECTION DATE: April 17, 2024

SOURCE LOCATION: 2 Miles South on Utah Highway 10, Castle Dale, Utah

MAILING ADDRESS: P.O. Box 569, Castle Dale, Utah 84513

SOURCE CONTACT: Terry Guthrie, Senior Engineer: 435-748-6059
P.O. Box 569, Castle Dale, UT 84513
Jay Howard, Sr. Environmental Analyst

OPERATING STATUS: Operating

PROCESS DESCRIPTION: PacifiCorp’s Hunter site consists of three coal-fired electric steam
generating units. The boiler fuel systems consist of coal handling and
fuel oil (diesel) for boiler cold starts after downtime and main boiler
flame stabilization:

Coal enters the plant via covered conveyors or by trucks from the
adjacent Energy West coal prep plant and is poured into coal mills where
it is pulverized to a talcum powder consistency. Pipes carry the
pulverized coal to the boiler burners where it ignites in a large fireball.
Bottom ash left from the coal combustion process (clinkers), collect at
the bottom of the boiler, which are crushed and slurried away. Fly ash,
also a combustion by-product, is removed by capturing the particulate
matter (PM) on electrostatic precipitators (ESP) or a baghouse. The
sulfur dioxide remaining in the hot flue gas from the combustion process
is removed at the scrubber by neutralizing the acid gases with a slake
lime shower.

For steam production, water is gradually pre-heated to raise the
temperature before it enters the boiler. As the water passes through the
steel tubes in the boiler wall, it is transformed to steam at approximately
1000 degrees F and at a pressure of 2,400 psi. This high-pressure steam
blows on fan blades of the turbine generator, spinning them at 3600

0 ( 8
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RPM. The generator, a magnet spinning within a coil of wire, turns the
energy of motion into electricity. Transformers step up voltage from
24,000 to 345,000 volts, first to the step-up unit on site and then for
transmission to distant recipients.

The used boiler steam is condensed, stored, and recycled. Cooling water
lowers the heat of the steam at the condenser and is carried to the cooling
towers where it is further cooled by evaporation.

The facility has continuous emission monitors (CEM) and continuous
opacity monitoring (COM) in the emission exit stacks. Further, a fugitive
dust plan is in effect to control fugitive dust emissions at the coal storage
and handling areas, landfill, and on access roads.

APPLICABLE REGULATIONS:

Title V Permit #1500101004, last revised November 19, 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

SECTION I: GENERAL PROVISIONS

I.A Federal Enforcement.

All terms and conditions in this permit, including those provisions designed to limit the
potential to emit, are enforceable by the EPA and citizens under the Clean Air Act of
1990 (CAA) except those terms and conditions that are specifically designated as "State
Requirements". (R307-415-6b)

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

I.B Permitted Activity(ies).

Except as provided in R307-415-7b(1), the permittee may not operate except in
compliance with this permit. (See also Provision I.E, Application Shield)

Status: In compliance. See status of each condition below for more specific details.
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I.C Duty to Comply.

I.C.1 The permittee must comply with all conditions of the operating permit. Any permit
noncompliance constitutes a violation of the Air Conservation Act and is grounds for any
of the following: enforcement action; permit termination; revocation and reissuance;
modification; or denial of a permit renewal application. (R307-415-6a(6)(a))

I.C.2 It shall not be a defense for a permittee in an enforcement action that it would have been
necessary to halt or reduce the permitted activity in order to maintain compliance with the
conditions of this permit. (R307-415-6a(6)(b))

I.C.3 The permittee shall furnish to the Director, within a reasonable time, any information that
the Director may request in writing to determine whether cause exists for modifying,
revoking and reissuing, or terminating this permit or to determine compliance with this
permit. Upon request, the permittee shall also furnish to the Director copies of records
required to be kept by this permit or, for information claimed to be confidential, the
permittee may furnish such records directly to the EPA along with a claim of
confidentiality. (R307-415-6a(6)(e))

I.C.4 This permit may be modified, revoked, reopened, and reissued, or terminated for cause.
The filing of a request by the permittee for a permit modification, revocation and
reissuance, or termination, or of a notification of planned changes or anticipated
noncompliance shall not stay any permit condition, except as provided under R307-415-
7f(1) for minor permit modifications. (R307-415-6a(6)(c))

Status: In compliance. It appears that all conditions have been complied with.

I.D Permit Expiration and Renewal.

I.D.1 This permit is issued for a fixed term of five years and expires on the date shown under
"Enforceable Dates and Timelines" at the front of this permit. (R307-415-6a(2))

I.D.2 Application for renewal of this permit is due on or before the date shown under
"Enforceable Dates and Timelines" at the front of this permit. An application may be
submitted early for any reason. (R307-415-5a(1)(c))

I.D.3 An application for renewal submitted after the due date listed in I.D.2 above shall be
accepted for processing, but shall not be considered a timely application and shall not
relieve the permittee of any enforcement actions resulting from submitting a late
application. (R307-415-5a(5))

I.D.4 Permit expiration terminates the permittee's right to operate unless a timely and complete
renewal application is submitted consistent with R307-415-7b (see also Provision I.E,
Application Shield) and R307-415-5a(1)(c) (see also Provision I.D.2). (R307-415-7c(2))

Status: In compliance. This permit was revised November 19, 2021, and expires September
4, 2025. The application for renewal deadline has not passed (March 25, 2025).

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I.E Application Shield.

If the permittee submits a timely and complete application for renewal, the permittee's
failure to have an operating permit will not be a violation of R307-415, until the Director
takes final action on the permit renewal application. In such case, the terms and
conditions of this permit shall remain in force until permit renewal or denial. This
protection shall cease to apply if, subsequent to the completeness determination required
pursuant to R307- 415-7a(3), and as required by R307-415-5a(2), the applicant fails to
submit by the deadline specified in writing by the Director any additional information
identified as being needed to process the application. (R307-415-7b(2))

Status: In compliance. This permit was issued November 19, 2021, and expires September 4,
2025. The application for renewal deadline has not passed.

I.F Severability.

In the event of a challenge to any portion of this permit, or if any portion of this permit is
held invalid, the remaining permit conditions remain valid and in force. (R307-415-6a(5))

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

I.G Permit Fee.

I.G.1 The permittee shall pay an annual emission fee to the Director consistent with
R307-415-9. (R307-415-6a(7))

I.G.2 The emission fee shall be due on October 1 of each calendar year or 45 days after the
source receives notice of the amount of the fee, whichever is later. (R307-415-9(4)(a))

Status: In compliance. Permit fees have been paid as invoiced.

I.H No Property Rights.

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

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

I.I Revision Exception.

No permit revision shall be required, under any approved economic incentives,
marketable permits, emissions trading and other similar programs or processes for
changes that are provided for in this permit. (R307-415-6a(8))

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

I.J Inspection and Entry.

I.J.1 Upon presentation of credentials and other documents as may be required by law, the
permittee shall allow the Director or an authorized representative to perform any of the
following:
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I.J.1.a Enter upon the permittee's premises where the source is located or emissions
related activity is conducted, or where records are kept under the conditions of
this permit. (R307-415-6c(2)(a))

I.J.1.b Have access to and copy, at reasonable times, any records that must be kept
under the conditions of this permit. (R307-415-6c(2)(b))

I.J.1.c Inspect at reasonable times any facilities, equipment (including monitoring and
air pollution control equipment), practice, or operation regulated or required
under this permit. (R307-415-6c(2)(c))

I.J.1.d Sample or monitor at reasonable times substances or parameters for the purpose
of assuring compliance with this permit or applicable requirements. (R307-415-
6c(2)(d))

I.J.2 Any claims of confidentiality made on the information obtained during an inspection
shall be made pursuant to Utah Code Ann. Section 19-1-306. (R307-415-6c(2)(e))

Status: In compliance. Entry into the source was allowed for inspection and a records
review.

I.K Certification.

Any application form, report, or compliance certification submitted pursuant to this
permit shall contain certification as to its truth, accuracy, and completeness, by a
responsible official as defined in R307-415-3. This certification shall state that, based on
information and belief formed after reasonable inquiry, the statements and information in
the document are true, accurate, and complete. (R307-415-5d)

Status: In compliance. All applications, forms, reports, and compliance certifications
submitted pursuant to this permit contain certification as to truth, accuracy, and
completeness by a responsible official.

I.L Compliance Certification.

I.L.1 Permittee shall submit to the Director an annual compliance certification, certifying
compliance with the terms and conditions contained in this permit, including emission
limitations, standards, or work practices. This certification shall be submitted no later
than the date shown under "Enforceable Dates and Timelines" at the front of this permit,
and that date each year following until this permit expires. The certification shall include
all the following (permittee may cross-reference this permit or previous reports):
(R307-415-6c(5))

I.L.1.a The identification of each term or condition of this permit that is the basis of the
certification;

I.L.1.b The identification of the methods or other means used by the permittee for
determining the compliance status with each term and condition during the
certification period. Such methods and other means shall include, at a minimum,
the monitoring and related recordkeeping and reporting requirements in this
permit. If necessary, the permittee also shall identify any other material
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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 most recent annual certification was received March 29, 2024
(due date of April 1, 2024). The certification was reviewed by DAQ and found in
compliance with the requirements of this condition.

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)(a)(xiii) and Section 19-
2-110 prior to or at the time of issuance of this permit. (R307-415-6f(3)(b)

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

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I.M.2.d The ability of the Director to obtain information from the source under Utah
Code Ann. Section 19-2-120, and the ability of the EPA to obtain information
from the source under the CAA Section 114. (R307-415-6f(3)(d))

Status: Section III contains requirements determined to be not applicable to this source in
accordance with Provision I.M.

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

Status: In compliance. No emergency events were recorded or reported during the
12-month period preceding this inspection.

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I.O Operational Flexibility.

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

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

I.P Off-permit Changes.

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

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

I.Q Administrative Permit Amendments.

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

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

I.R Permit Modifications.

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

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

I.S Records and Reporting.

I.S.1 Records.

I.S.1.a The records of all required monitoring data and support information shall be
retained by the permittee for a period of at least five years from the date of the
monitoring sample, measurement, report, or application. Support information
includes all calibration and maintenance records, all original strip-charts or
appropriate recordings for continuous monitoring instrumentation, and copies of
all reports required by this permit. (R307-415-6a(3)(b)(ii))

I.S.1.b For all monitoring requirements described in Section II, Special Provisions, the
source shall record the following information, where applicable: (R307-415-
6a(3)(b)(i))

I.S.1.b.1 The date, place as defined in this permit, and time of sampling or
measurement.

I.S.1.b.2 The date analyses were performed.

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.

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I.S.1.b.6 The operating conditions as existing at the time of sampling or
measurement.

I.S.1.c Additional record keeping requirements, if any, are described in Section II,
Special Provisions.

I.S.2 Reports.

I.S.2.a Monitoring reports shall be submitted to the Director every six months, or more
frequently if specified in Section II. All instances of deviation from permit
requirements shall be clearly identified in the reports. (R307-415-6a(3)(c)(i))

I.S.2.b All reports submitted pursuant to Provision I.S.2.a shall be certified by a
responsible official in accordance with Provision I.K of this permit. (R307-415-
6a(3)(c)(i))

I.S.2.c The Director shall be notified promptly of any deviations from permit
requirements including those attributable to upset conditions as defined in this
permit, the probable cause of such deviations, and any corrective actions or
preventative measures taken. Prompt, as used in this condition, shall be defined
as written notification within the number of days shown under "Enforceable
Dates and Timelines" at the front of this permit. Deviations from permit
requirements due to breakdowns shall be reported in accordance with the
provisions of R307-107. (R307-415-6a(3)(c)(ii))

I.S.3 Notification Addresses.

I.S.3.a All reports, notifications, or other submissions required by this permit to be
submitted to the Director are to be sent to the following address or to such other
address as may be required by the Director:

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

I.S.3.b All reports, notifications or other submissions required by this permit to be
submitted to the EPA should be sent to one of the following addresses or to such
other address as may be required by the Director:

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

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

Status: In compliance. Records are kept as required. Monitoring reports have been
submitted every six months. Deviation reports have been submitted when necessary.

I.T Reopening for Cause.

I.T.1 A permit shall be reopened and revised under any of the following circumstances:

I.T.1.a New applicable requirements become applicable to the permittee and there is a
remaining permit term of three or more years. No such reopening is required if
the effective date of the requirement is later than the date on which this permit is
due to expire, unless the terms and conditions of this permit have been extended
pursuant to R307-415-7c(3), application shield. (R307-415-7g(1)(a))

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

I.T.1.c EPA or the Director determines that this permit must be revised or revoked to
assure compliance with applicable requirements. (R307-415-7g(1)(d))

I.T.1.d Additional applicable requirements are to become effective before the renewal
date of this permit and are in conflict with existing permit conditions. (R307-415-
7g(1)(e))

I.T.2 Additional requirements, including excess emissions requirements, become applicable to
a Title IV affected source under the Acid Rain Program. Upon approval by EPA, excess
emissions offset plans shall be deemed to be incorporated into this permit. (R307-415-
7g(1)(b))

I.T.3 Proceedings to reopen and issue a permit shall follow the same procedures as apply to
initial permit issuance and shall affect only those parts of this permit for which cause to
reopen exists. (R307-415-7g(2))

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

I.U Inventory Requirements.

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

Status: In compliance. Emission inventories have been submitted as required.

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I.V Title IV and Other, More Stringent Requirements

Where an applicable requirement is more stringent than an applicable requirement of
regulations promulgated under Title IV of the Act, Acid Deposition Control, both
provisions shall be incorporated into this permit. (R307-415-6a(1)(b))

Status: Not evaluated. 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 Steam Generating Unit #1 (Emission unit #1)
Nominal 480 MW gross capacity dry bottom, tangentially-fired boiler fired on subbituminous &
bituminous coal using distillate fuel oil during start-up & flame stabilization. System is equipped
with a low NOx burner/overfire air system (OFA), baghouse and SO2 Wet FGD (WFGD)
scrubber with no scrubber bypass. NSPS D

II.A.3 Steam Generating Unit #2 (Emission unit #2)
Nominal 480 MW gross capacity dry bottom, tangentially-fired boiler fired on subbituminous &
bituminous coal using distillate fuel oil during start-up & flame stabilization. System is equipped
with a low NOx burner/OFA, baghouse and SO2 WFGD scrubber (WFGD) with no scrubber
bypass. NSPS D

II.A.4 Subpart D Boilers, Units #1 & #2 (Emission unit #4)
Steam generating Units #1 and #2.

II.A.5 Steam Generating Unit #3 (Emission unit #3)
Nominal 495 MW gross capacity dry bottom, wall-fired boiler fired on subbituminous &
bituminous coal using distillate fuel oil during start-up & flame stabilization. System is equipped
with baghouse & SO2 FGD scrubber, and a low NOx burner/OFA. NSPS Da

II.A.6 Circulating Water Cooling Tower for Unit #1 (Emission unit #7)
Cooling tower for steam generating boiler #1. No unit-specific applicable requirements.

II.A.7 Circulating Water Cooling Tower for Unit #2 (Emission unit #8)
Cooling tower for steam generating boiler #2. No unit-specific applicable requirements.

II.A.8 Circulating Water cooling Tower for Unit #3 (Emission unit #9)
Cooling tower for steam generating boiler #3. No unit-specific applicable requirements.

II.A.9 Coal Pile (Emission unit #10)
Coal pile operations and associated fugitive emissions and fugitive dust No unit-specific
applicable requirements.

II.A.10 Coal Conveyors (Emission unit #11)
Coal transfer operations via conveyors.
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II.A.11 Unpaved Ash Haul Road (Emission unit #13a)
Dirt haul road for ash disposal. No unit-specific applicable requirements.

II.A.12 Paved Ash Haul Road (Emission unit #13b)
Paved haul road for disposal of ash. No unit-specific applicable requirements.

II.A.13 Ash Landfill (Emission unit #14)
Ash landfill operations and associated fugitive emissions and fugitive dust. No unit-specific
applicable requirements.

II.A.14 #1 Emergency Diesel Generator for Unit #1 (Emission unit #15)
Emergency diesel generator (1050 hp) for Unit #1, Constructed prior to December 19, 2002. No
unit- specific applicable requirements.

II.A.15 #2 Emergency Diesel Generator for Unit #2 (Emission unit #16)
Emergency diesel generator (1050 hp) for Unit #2, Constructed prior to December 19, 2002. No
unit-specific applicable requirements.

II.A.16 #3 Emergency Diesel Generator for Unit #3 (Emission unit #17)
Emergency diesel generator (915 hp) for Unit #3, Constructed prior to December 19, 2002. No
unit- specific applicable requirements.

II.A.17 #1 Emergency Diesel Fire Pump #1 (Emission unit #18)
Emergency diesel fire pump #1 (229 hp). It is Tier 3 certified and was installed on December 1,
2011). Subject to 40 CFR 60 Subpart IIII.

II.A.18 #2 Emergency Diesel Fire Pump #2 (Emission unit #19)
Emergency diesel fire pump #2 (235hp). Constructed prior to December 19, 2002. Subject to
NESHP ZZZZ

II.A.19 Coal Silo System Exhauster for Unit #1 (Emission unit #21)
Exhauster and centrifugal dust collector for Unit #1 coal silos distribution system. No unit-
specific applicable requirements.

II.A.20 Coal Silo System Exhauster for Unit #2 (Emission unit #22)
Exhauster and centrifugal dust collector for Unit #2 coal silo distribution system. No unit-specific
applicable requirements.

II.A.21 Coal Silo System Exhauster for Unit #3 (Emission unit #23)
Exhauster and centrifugal dust collector for Unit #3 coal silo distribution system. No unit-specific
applicable requirements.

II.A.22 Lime Silo Bin Vents (water treatment plant) (Emission unit #24)
Bin vent dust collectors for lime storage silos for water treatment plant. No unit-specific
applicable requirements.

II.A.23 Lime Silo Bin Vents (SO2 scrubber) (Emission unit #27)
Bin vent dust collectors for scrubber lime silos for Units #1, #2, and #3. No unit-specific
applicable requirements.

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II.A.24 Distillate Fuel Oil Tanks (Emission unit #28)
Four 70,000-gallon tanks and the day tanks for the emergency diesel generators and fire pumps.
No unit- specific applicable requirements.

II.A.25 Lube Oil Storage Tanks (Emission unit #29)
Four 10,000-gallon tanks that store lubricating oil. No unit-specific applicable requirements.

II.A.26 Oil Storage Area (Emission unit #30)
Storage area for oil contained in closed 55-gallon drums. No unit-specific applicable
requirements.

II.A.27 Electro-hydraulic Control Reservoirs (Emission unit #31)
Three 400-gallon hydraulic oil reservoirs. No unit-specific applicable requirements.

II.A.28 Paved Access Road and Parking Area (Emission unit #32)
Paved access road from the plant entrance to the administration building and parking area. No
unit- specific applicable requirements.

II.A.29 Cold Degreasing Operations (Emission unit #33)
"Bench-top" cold degreasing units using "Safety-Kleen" or other comparable degreasing agents.
No unit- specific applicable requirements.

II.A.30 Miscellaneous Electrical Equipment (Emission unit #34)
Fugitive emission units including transformer insulating oil. No unit-specific applicable
requirements.

II.A.31 Water Treatment Chemical Tanks (Emission unit #35)
Tank storage including aluminum sulfate, lime, sodium sulfite, soda ash, calcium hypochlorite,
sodium hydroxide, anti-scale, aqueous ammonia. No unit-specific applicable requirements.

II.A.32 Paint Storage Area (Emission unit #37)
Various storage areas for sealed paint containers. No unit-specific applicable requirements.

II.A.33 Boiler Feed Pump Lube Oil Conditioners (Emission unit #41)
Boiler feed pump lube oil conditioners. No unit-specific applicable requirements.

II.A.34 Lube Oil Conditioners (Emission unit #42)
Lube oil conditioners with vapor extractors. No unit-specific applicable requirements.

II.A.35 Lube Oil Reservoirs (Emission unit #43)
Lube oil reservoirs with vapor extractors. No unit-specific applicable requirements.

II.A.36 Diesel Refueling Stations and Storage Tanks (Emission unit #44)
Three 5,200-gallon aboveground diesel tanks and dispensing equipment to refuel vehicles and
mobile equipment. No unit-specific applicable requirements.

II.A.37 Truck Mounted Vacuum System (Emission unit #45)
Mobile truck mounted vacuum to clean up spilled material such as ash. No unit-specific
applicable requirements.

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II.A.38 Ash Unloader for Unit #1 (Emission unit #46)
Equipment for unloading ash from silos and into trucks for transport to the ash landfill. No unit-
specific applicable requirements.

II.A.39 Ash Unloader for Unit #2 (Emission unit #47)
Equipment for unloading ash from silos and into trucks for transport to the ash landfill. No unit-
specific applicable requirements.

II.A.40 Ash Unloader for Unit #3 (Emission unit #48)
Equipment for unloading ash from silos and into trucks for transport to the ash landfill. No unit-
specific applicable requirements.

II.A.41 Unleaded Gasoline Refueling Station and Storage Tank (Emission unit #39)
Gasoline refueling for fleet vehicles from a 5,200-gallon aboveground tank. No unit-specific
applicable requirements.

II.A.42 Gypsum Off-loading Conveyor (Emission unit #49)
Conveyor for off-loading spent reagent from scrubber system along with fabric control system for
control of fugitive emissions.

II.A.43 Refined Coal System (Emission unit #50)
A refined coal system will treat the coal with chemical M45-PC-A, including two storage silos,
conveyors, feed hoppers, product totes, pumps, piping and spray equipment.

Status: In compliance. No unapproved equipment was observed. II.a.11 haul road is paved,
and the only unpaved areas are part of an ash pile. II.A.32 Paint storage area no
longer used as all paint work is contracted out.

II.B Requirements and Limitations

The following emission limitations, standards, and operational limitations apply to the permitted
facility as indicated:

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

II.B.1.a 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. [R307-206]. [R307-206]

II.B.1.a.1 Monitoring:

Visible emission evaluation shall be conducted every six months if abrasive blasting
operations are conducted. Visible emission evaluation of abrasive blasting operations
shall be conducted in accordance with the following provisions:

(a) Visible emissions shall be measured 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.
15
(b) Emissions from unconfined blasting shall be read 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) Emissions from unconfined blasting employing multiple nozzles shall be judged as a
single source unless it can be demonstrated by the owner or operator that each nozzle,
evaluated separately, meets the emission and performance standards provided for in
R307-206.

(d) Emissions from confined blasting shall be read at the densest point after the air
contaminant leaves the enclosure.

II.B.1.a.2 Recordkeeping:

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

II.B.1.a.3 Reporting:

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

Status: In compliance. Only confined abrasive blasting was conducted during the 12-month
period preceding this inspection. Records have been kept.

II.B.1.b 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. [AO DAQE-AN102370028-18 and 40
CFR 60.11(d)]. [40 CFR 60, R307-401-8(2)]

II.B.1.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.1.b.2 Recordkeeping:

Records documenting scheduled and unscheduled maintenance shall be maintained. A
copy of all manufacturers' operating instructions or established maintenance practices for
pollution control equipment and pollution emitting equipment shall be kept on site. These
instructions shall be available to all employees who operate the equipment and shall be
made available to compliance inspectors upon their request.

16
II.B.1.b.3 Reporting:

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

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

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

Status: In compliance. The facility appeared to be maintained in a manner consistent with
good air pollution control practices for minimizing emissions. A preventative work
order system is in place utilizing SAP software. Annual projections of planned
outages have been submitted.

II.B.1.c Condition:

Visible fugitive dust emissions from haul-road traffic and mobile equipment in operational areas
shall not exceed 20% opacity. [AO DAQE-AN102370028-18]. [R307-401-8]

II.B.1.c.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.
Visible emission observation shall be performed at the frequency as required in the most
recently approved fugitive dust control plan to assure compliance of the 20% opacity
limitation.

II.B.1.c.2 Recordkeeping:

Records of measures as required in the fugitive dust control plan for minimizing fugitive
dust and the results of opacity observations shall be maintained as described in Provision
I.S.1 of this permit.

II.B.1.c.3 Reporting:

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

Status: In compliance. The facility contracts out road watering and maintains records of
applications. Records indicated watering during dry conditions of about one load
every fifteen minutes to one half hour. The most current dust plan is dated January
17, 2013.

17
II.B.1.d Condition:

A Risk Management Plan (RMP) developed in accordance with 40 CFR Part 68 shall be
submitted to the United States Environmental Protection Agency not later than the applicable date
in 40 CFR 68. [40 CFR Part 68]. [40 CFR 68]

II.B.1.d.1 Monitoring:

A copy of the Risk Management Plan shall be available upon request along with a copy
of the transmittal letter to EPA.

II.B.1.d.2 Recordkeeping:

A copy of the Risk Management Plan shall be available to the Director upon request
along with a copy of the transmittal letter to EPA.

II.B.1.d.3 Reporting:

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

Status: Not applicable. The facility is no longer required to keep a Risk Management Plan.
Any additional details should be obtained from the US EPA.

II.B.1.e 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. [40 CFR 82.150(b)]. [40 CFR 82 Subpart F]

II.B.1.e.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.e.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.e.3 Reporting:

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

Status: In compliance. The permittee certified compliance with this condition in the most
recent certification. All refrigerant work is contracted out.

18
II.B.1.f Condition:

Sulfur content of the fuel oil or diesel combusted shall be no greater than 0.0015 percent by
weight. [AO DAQE-AN102370028-18]. [R307-401-8]

II.B.1.f.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.

II.B.1.f.2 Recordkeeping:

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

II.B.1.f.3 Reporting:

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

Status: In compliance. Monthly certifications from the vendor (Sinclair’s Wyoming
refinery) are kept on record and indicated compliance.

II.B.1.g Condition:

Visible emissions shall be no greater than 20 percent opacity for all emission units unless
otherwise noted in this permit and for diesel engines as described in R307-201-3. [R307-201-3].
[R307-201-3]

II.B.1.g.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.

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

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

Status: In compliance. Monthly surveys have been performed and recorded.

II.B.1.h Condition:

The permittee shall develop, maintain, and implement a written Hunter Emissions Minimization
Plan (Hunter Plan) that describes, in detail, procedures for operating and maintaining the Units
#1, #2 and #3 boilers, including associated air pollution control and monitoring equipment, during
events of startup and shutdown. The Hunter Plan shall define the startup and shutdown events and
shall contain the minimum requirements as follows:

(1) Startup is defined as the period beginning with the introduction of fuel into the boiler and
ending no later than when two coal feeders have been placed in service and the flue gas
temperature at the outlet ducts to both sides of the baghouse outlet (Units #1, #2 or #3 boilers)
have reached a temperature of 220oF and less than 20 percent of the boiler heat input is being
furnished by fuel oil.

(2) Bypass of associated control equipment shall only be used to prevent loss of life, personal
injury, or severe property damage.

(3) Shutdown is defined as the period beginning 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 and ending when fuel flow to the boiler ceases.

(4) The Hunter Plan shall contain detailed steps to minimize, to the maximum extent practicable,
the frequency and duration of operation in startup or shutdown mode and shall be followed at all
times. This shall include, but not necessarily be limited to, careful and detailed design, planning,
operation, and maintenance so as to avoid unnecessary, preventable, or unreasonably frequent or
lengthy startup and shutdown.

(5) The duration of a boiler startup event shall not extend beyond 20 hours per startup period or
300 hours per year per boiler and 750 hours per year combined for the Unit #1, #2 and #3 boilers.

20
(6) During periods of startup and shutdown, the permittee shall operate and maintain the boilers,
including associated air pollution control and monitoring equipment, in accordance with
procedures specified in the Hunter Plan based on equipment manufacturer/plant operating
procedures.

(7) The permittee shall periodically revise the Hunter Plan for the affected source as necessary to
satisfy the requirements of this Condition or to reflect changes in equipment or procedures at the
affected source. Each such revision must be submitted to the Director. [ AO DAQE-
AN102370028-18]. [R307-401-8]

II.B.1.h.1 Monitoring:

Recordkeeping requirements required in this permit condition shall serve as monitoring
requirement.

II.B.1.h.2 Recordkeeping:

The permittee shall maintain records demonstrating that the procedures in the Hunter
Plan were followed. These records shall include the date and time of occurrence and
duration of each startup and shutdown, total hours of startup and shutdown every
calendar year for each boiler, emissions during startup and shutdown as well as other
pertinent information.

II.B.1.h.3 Reporting:

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

Status: In compliance. A Hunter Emissions Minimization Plan has been developed and
maintained. Records of startup events during calendar year 2023 were provided and
reviewed. No exceedances were documented. A total of 283 combined boiler startup
hours were recorded; 53.82 hours on Unit 1, 133.45 hours on Unit 2, and 95.97
hours on Unit 3.

II.B.1.i Condition:

The plant-wide applicability limitation (PAL) of SO2 emission shall be no greater than 5,537.5
tons per year and the PAL of NOx emission shall be no greater than 15,095 tons per year, based
on 12-month rolling total for the entire Hunter Plant from all point sources and fugitive emission.
The PAL limits shall be effective for ten years from July 13, 2018, and will expire on July 13,
2028. If the permittee applies for PAL renewal, the permittee shall submit an application in
accordance with 40 CFR Subpart 52.21(aa)(10) at least 6 months prior to, but no earlier than 18
months before July 13, 2028. If the permittee submits a complete application to renew the PAL
within this time period, 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)(i) through (v). [40 CFR Subpart 52.21(aa) and AO DAQE- AN102370028-18].
[R307-401-8]

21
II.B.1.i.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 a minimum, all reported NOx
and SO2 emissions, including emissions associated with startups, shutdowns, and
malfunctions, in pounds per hour, shall be summed to get monthly total emissions and
shall be calculated as follows:

(a) For Units #1, #2 and #3 main boiler stacks, the permittee's reporting to EPA's Acid
Rain Emissions data base for NOx and SO2 in pounds per hour obtained from the boilers'
CEM data shall be used to calculate NOx and SO2 emission rates. All reported NOx and
SO2 emissions, including emissions associated with startup, shutdowns, and
malfunctions, in pounds per hour, shall be summed to get monthly total emissions.

(b) For Units #1, #2 and #3 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 in accordance with 40 CFR part
52.21(aa)(12)(vi), hours of operation, and engine site rating or design rating. 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 and engine site rating or
design rating.

(c) For Units #1 and #2 emergency diesel-fired fire pumps, emissions shall be calculated
by multiplying the SO2 and NOx emission factor from the latest edition of EPA's
emission factors compilation AP-42 in accordance with 40 CFR part 52.21(aa)(12)(vi),
hours of operation, and engine site rating or design rating. Records documenting
generator usage shall be kept in a log, that shall include the date the pump is used and the
duration in hours of pump usage, and engine site rating or design rating.

(d) The permittee shall calculate new 12-month total 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.

II.B.1.i.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.

II.B.1.i.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.

Status: In compliance. 12-month rolling totals of SO2 and NOx emissions are kept and were
reviewed during this inspection. No exceedances of these limits were recorded.
During the 12-month period ending March 31, 2024; 1,633 tons SOX and 3,772 tons
of NOX were emitted. PAL reports have been submitted on time in the past year.

22
II.B.2 Conditions on Subpart D Boilers, Units #1 & #2 (Emission unit #4).

II.B.2.a Condition:

Emissions of particulate matter (PM) shall not be greater than 0.015 lb/MMBtu based on a 3-test
average from each boiler. [40 CFR 60.42 (a) and DAQE-AN102370028-18].
[40 CFR 60 Subpart D, R307-401-8]

II.B.2.a.1 Monitoring:

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

(1) Testing and Frequency. Emission 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 COMS installed in each
baghouse outlet duct.

(2) Indicator Range:

(i) 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.

(ii) 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))

23
(3) Performance Criteria:

(i) 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.

(ii) QA/QC Practices and Criteria: COMS shall be operated, calibrated, and maintained to
meet 40 CFR 60, Appendix B, Performance Specification 1.

(iii) Monitoring Frequency: Opacity shall be monitored continuously with opacity values
averaged every minute.

(iv) Data Collection Procedure: Opacity data shall be recorded and stored electronically.

(v) 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.a.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.a.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:

24
(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. The most recent emission testing data available shows the test was
conducted on February 13-14, 2024. Results were submitted to DAQ and audited in
DAQC-276-24. DAQ calculated particulate emissions from Unit 1 were 0.003
lb/MMBtu, and Unit 2 were 0.005 lb/MMBtu.

II.B.2.b Condition:

Emissions of NOx shall be no greater than 0.70 lb/MMBtu heat input for any 3-hour period as
determined by the arithmetic average of three contiguous one-hour periods [40 CFR 60.44(a)(3),
60.45(g)(3), 60.8(c), and DAQE-AN102370028-18]. [40 CFR 60 Subpart D, R307-401-8]

II.B.2.b.1 Monitoring:

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

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

(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

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

II.B.2.b.2 Recordkeeping:

(a) The permittee shall maintain a file of all measurements, including continuous
monitoring system, monitoring device, and performance testing measurements; all
continuous monitoring system performance evaluations; all continuous monitoring
system or monitoring device calibration checks; adjustments and maintenance performed
on these systems or devices; and all other information required by applicable portions of
40 CFR Part 60, Subparts A and D recorded in a permanent form suitable for inspection.
25
(b) The permittee shall maintain records of the occurrence and duration of any startup,
shutdown, or malfunction in the operation of the unit; any malfunction of the air pollution
control equipment; or any periods during which a continuous monitoring system or
monitoring device is inoperative.

II.B.2.b.3 Reporting:

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

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

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

(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.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. NOx
lb/MMBtu three-hour readings at inspection were 0.138 Unit 1, 0.164 Unit 2, and
Unit 3 offline.

II.B.2.c Condition:

Emissions of NOx shall be no greater than 0.26 lb/MMBtu heat input for a 30-day rolling average
[40 CFR 60.44(a), 60.45(g), 60.8(c), and DAQE-AN102370028-18].
[40 CFR 60 Subpart D, R307-401-8]

II.B.2.c.1 Monitoring:

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

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

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

26
(d) A 30-day rolling average shall be calculated every day for NOx emissions by using
daily average emission rates.

II.B.2.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; 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.

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

II.B.2.c.3 Reporting:

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

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

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

(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.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. NOx
lb/MMBtu thirty-day readings at inspection were 0.173 Unit 1, 0.162 Unit 2, and
0.287 Unit 3.

II.B.2.d Condition:

Emissions of SO2 shall be no greater than 1.2 lb/MMBtu heat input for any 3-hour period as
determined by the arithmetic average of three contiguous one-hour average [40 CFR 60.43(a),
60.45(g), 60.8(c), and DAQE-AN102370028-18]. [40 CFR 60 Subpart D, R307-401-8]

II.B.2.d.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system for measuring sulfur dioxide 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).

27
(b) Each continuous emission monitoring system shall meet the following requirements
in 40 CFR Part 75, Appendix A, Specification and Test Procedures

(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

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

II.B.2.d.2 Recordkeeping:

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

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

II.B.2.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 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.

(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.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. SO2
lb.MMBtu three-hour readings at inspection were 0.083 Unit 1, 0.084 Unit 2, and
Unit 3 offline.

28
II.B.2.e Condition:

Emissions of SO2 shall be no greater than 0.12 lb/MMBtu heat input for a 30-day rolling average.
[40 CFR 60.8(c) and DAQE-AN102370028-18]. [40 CFR 60 Subpart D, R307-401-8]

II.B.2.e.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system for measuring sulfur dioxide 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). (c) Each continuous emission
monitoring system shall meet the following requirements: 40 CFR Part 75, Appendix A,
Specification and Test Procedures

(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(b) 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.

(c) A 30-day rolling average shall be calculated every day for SO2 emissions by using
daily average emission rates.

II.B.2.e.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.

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

II.B.2.e.3 Reporting:

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

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

29
(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.

(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.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. SO2
ln/MMBtu Thirty-day readings at inspection were 0.083 Unit 1, 0.089 Unit 2, and
0.091 Unit 3.

II.B.2.f Condition:

Visible emissions shall be no greater than 20 percent opacity (six-minute average) except during
periods of startup, shutdown, and malfunction and except for one 6-minute period per hour of not
more than 27 percent opacity. During startup and shutdown events, the permittee shall
demonstrate compliance with the requirements under Provision II.B.1.h of this permit.
[40 CFR 60.42(a)(2), 60.45(g)(1), 60.8(c), 60.11(c), and R307-201-3].
[40 CFR 60 Subpart D, R307-201-3]

II.B.2.f.1 Monitoring:

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

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

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

II.B.2.f.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.

(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.

30
II.B.2.f.3 Reporting:

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

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

(c) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director
(permitting authority) shall also be submitted to USEPA, Region VIII, if requested. (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: Not evaluated. COM and CEM requirements are evaluated by DAQ’s CEM
specialist. Opacity (6 minute) readings during inspection were: 3.8 - Unit 1,
4.4 - Unit 2, and Unit 3 offline.

II.B.2.g Condition:

Emissions of SO2 shall be no greater than 20 percent of the potential combustion concentration
based on the average inlet and average outlet SO2 emissions determined as the arithmetic average
of all hourly emission rates for the 30 successive boiler operating days. [DAQE-AN102370028-
18]. [R307-401-8]

II.B.2.g.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system, and record the output of the system, for measuring sulfur dioxide emissions. The
permittee shall determine compliance with the SO2 reduction limit by periodic
monitoring using procedures in 40 CFR Part 60.46a, Compliance provision
(subparagraph (c), (d), (e), (g) and (h)), 60.47a, Emission monitoring (subparagraph (b),
(d), (e), (f), (g), (h), (i) and (j)), and 60.48a, Compliance determination procedures and
methods (subparagraph (c)).

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

(c) The quality assurance requirements of R307-170, Continuous Emission Monitoring
Systems Program, may be used to fulfill the 40 CFR 60.13(d)(1) continuous emission
monitor data quality assurance requirements.
31
(d) An "as-fired" fuel testing program (upstream of coal pulverizers) meeting the
requirements of Method 19 (40 CFR Part 60 Appendix A) may be used as an alternative
method to determine potential sulfur dioxide emissions in place of a continuous sulfur
dioxide emission monitor at the inlet to the sulfur dioxide control device. The permittee
shall prepare a quality assurance (QA) plan for the coal sampling equipment, coal
custody procedures, and laboratory analysis. Method 19 and ASTM QA procedures shall
be used as part of the plan.

II.B.2.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; 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.

(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.

(c) The permittee shall maintain records demonstrating adherence to the fuel testing
program QA plan if fuel testing is performed.

II.B.2.g.3 Reporting:

(a) The permittee shall report 30-day periods during which the SO2 reduction
requirement was not met in the next NSPS 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) The reports required in paragraphs (a) and (b) 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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist.

II.B.2.h Condition:

Emissions of CO shall be no greater than 0.34 lb/MMBtu heat input for a 30-day rolling average
and no greater than 3990 lb/hr for an 8-hour block average. [DAQE-AN102370028-18].
[R307-401-8]

32
II.B.2.h.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
shall be calculated every hour and the 8-hour block average and daily average shall be
calculated using the hourly average data. The daily average of CO emission shall be used
to calculate 30-day rolling average.

II.B.2.h.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,
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.h.3 Reporting:

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

(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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. The
initial stack test has been performed. The 30 Day lb/MMBtu during inspection were
0.14 Unit 1, 0.02 Unit 2 and .001 Unit 3(shutdown).

II.B.2.i 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. [40 CFR 63.10000(b)]. [40 CFR 63 Subpart UUUUU]

33
II.B.2.i.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.2.i.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.i.3 Reporting:

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

Status: In compliance. The facility appeared to be maintained in a manner consistent with
good air pollution control practices for minimizing emissions. A preventative work
order system is in place utilizing SAP software. Annual projections of planned
outages have been submitted.

II.B.2.j Condition:

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

(a) Emission of filterable particulate matter (PM) shall be no greater than 3.0E-02 lb/MMBtu;

(b) Emission of sulfur dioxide (SO2) shall be no greater than 2.0E-01 lb/MMBtu;

(c) Emission of mercury (Hg) shall be no greater than 1.2E0 lb/TBtu;

(d) The permittee shall conduct a tune-up of the EGU burner and combustion controls at least
each 36 calendar months, or each 48 calendar months if neural network combustion optimization
software is employed;

(e) The permittee shall comply with the emission limits at all times except during periods of
startup and shutdown. The permittee shall meet the work practice in Table 3(3) and (4) of 40 CFR
63 Subpart UUUUU during periods of startup, or shutdown;

(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;

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

34
II.B.2.j.1 Monitoring:

(a) General Compliance Requirement:

(1) Filterable PM: The permittee shall demonstrate compliance through performance
stack testing repeated quarterly;

(2) SO2: The permittee shall demonstrate continuous compliance through use of a SO2
CEMs in accordance with 40 CFR Subpart 75;

(3) Hg: The permittee shall demonstrate continuous compliance through use of a Hg
CEMs in accordance with appendix A to 40 CFR 63 Subpart UUUUU. The permittee
shall operate and maintain the CEMs according to the site-specific monitoring plan as
required in 40 CFR 63.10000(d)(5)(i) through (vii);

(4) 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 43 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 43 CFR 63.10020(b)
through (d) and the site-specific monitoring plan required by 40 CFR 63.10000(d).

(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].

II.B.2.j.2 Recordkeeping:

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

35
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.j.3 Reporting:

The permittee shall submit a Notification of Compliance Status summarizing the results
of the initial compliance demonstration according to 40 CFR 63.9(h)(2)(ii). The
Notification of Compliance Status report must contain all the information specified in 40
CFR 63.10030(e)(1) through (7), as applicable.
The permittee shall submit the compliance report as required in 40 CFR 63.10031. The
compliance report shall contain the requirements as described in 40 CFR 63.10031(c)(1)
through (4) and Table 8 of 40 CFR 63 Subpart UUUUU semiannually according to the
requirements in 40 CFR 63.10031(b).

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

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

Status: In compliance. The permittee has attained LEE status for Mercury and PM on Units 1 and 2.
Mercury is tested using Method 30B every 12 calendar months. 40 CFR 63.10031(f)(6) requires this
test report be submitted to EPA only thru the ECMPS client tool. Hg rate calculations are
submitted to DAQ annually in the report required by II.B.2.k and II.B.3.i.

Semi-annual Subpart UUUUU reports have been submitted and summarize these tests as well as
boiler tune-ups. SO2 is monitored by CEM.

The annual Mercury Method 30B was completed in November 2023. Results are listed in
DAQC-1361-23 as follows:

Source Test Date RM/Pollutant DAQ Result Test Result Limit

Unit 1 10/25-11/28 RM 30B/HG 1.1E-8 lb/MMBtu 1.0E-8 lb/MMBtu 6.5E-7 lb/MMBtu
0.01 lb/TBtu 0.01 lb/TBtu 1.2 lb/TBtu
0.0001 lb/GW-hr 0.0001 lb/GW-hr 0.013 lb/GW-hr
0.5 lbs/yr* 0.6 lbs/yr* 29 lbs/yr*
0.4 lbs/yr** 0.4 lbs/yr** 29 lbs/yr**

Unit 2 10/25-11/28 RM 30B/HG 1.9E-8 lb/MMBtu 1.7E-8 lb/MMBtu 6.5E-7 lb/MMBtu
0.02 lb/TBtu 0.02 lb/TBtu 1.2 lb/TBtu
0.0002 lb/GW-hr 0.0002 lb/GW-hr 0.013 lb/GW-hr
0.6 lbs/yr* 0.7 lbs/yr* 29 lbs/yr*
0.7 lbs/yr** 0.7 lbs/yr** 29 lbs/yr**

36
Unit 3 10/25-11/28 RM 30B/HG 5.7E-8 lb/MMBtu 5.4E-8 lb/MMBtu 6.5E-7 lb/MMBtu
0.05 lb/TBtu 0.05 lb/TBtu 1.2 lb/TBtu
0.0006 lb/GW-hr 0.0006 lb/GW-hr 0.013 lb/GW-hr
2.7 lbs/yr* 2.6 lbs/yr* 29 lbs/yr*
2.3 lbs/yr** 2.3 lbs/yr** 29 lbs/yr**

*Emission rate calculated based on maximum electrical output per year
**Emission rate calculated based on maximum heat input per year

II.B.2.k Condition:

Emissions of mercury shall be no greater than 6.5E-07 lb/MMBtu heat input based on an annual
averaging period beginning January 1st and ending December 31st. [R307-424-4]. [R307-424-4]

II.B.2.k.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.k.2 Recordkeeping:

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

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

II.B.2.k.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.

37
(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. PacifiCorp has obtained LEE status and monitors Hg emissions
using option (c). Annual reports have been submitted and include emission rate
calculations. See Condition II.B.2.j for test results.

II.B.3 Conditions on Steam Generating Unit #3 (Emission unit #3).

II.B.3.a Condition:

Emissions of particulate matter (PM) shall not be greater than 0.02 lb/MMBtu heat input based on
a 6- hour test average. [40 CFR 60.42Da(a), 60.48Da(c), and DAQE-AN102370028-18].
[40 CFR 60 Subpart Da, R307-401-8]

II.B.3.a.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 Da, 60.50a(b) and (e).

(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:

(i) An excursion is defined as a 24-hour daily average opacity value greater than the
baseline level of 5.33% . 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.

38
(ii) 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:

(i) 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.

(ii) QA/QC Practices and Criteria: COMS shall be operated, calibrated, and maintained to
meet 40 CFR 60, Appendix B, Performance Specification 1.

(iii) Monitoring Frequency: Opacity shall be monitored continuously with opacity values
averaged every minute.

(iv) Data Collection Procedure: Opacity data shall be recorded and stored electronicall y.

(v) 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.a.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))
39
(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.3.a.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 with stack testing requirements. CEM and COM requirements are
evaluated by DAQ’s CEM specialist. The stack test was completed on November 1,
2023, and reviewed under DAQC-1315-23 as follows:

Source Test Date DAQ Result Test Result Limit

Unit 3 11/01/2023 0.007 lb/MMBtu 0.006 lb/MMBtu 0.02 b/MMBtu

CAM reports have been submitted on time.

II.B.3.b Condition:

Emissions of SO2 shall be no greater than 0.12 lb/MMBtu heat input based on a 30-day rolling
average as determined by the arithmetic average of all hourly emission rates for the 30 successive
boiler operating days. [40 CFR 60.43Da and DAQE-AN102370028-18]. [40 CFR 60 Subpart Da,
R307-401-8]

II.B.3.b.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system, and record the output of the system, for measuring sulfur dioxide emissions. The
permittee shall determine compliance in accordance with 40 CFR Part 60.48a,
Compliance provision (subparagraph (c), (d), (e), (g) and (h)), 60.49a, Emission
monitoring (subparagraph (b), (d), (e), (f), (g), (h), (i) and (j)), and 60.50a, Compliance
determination procedures and methods (subparagraph (c)).

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

(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The permittee shall implement a Quality Control program according to 40 CFR Part
75, Appendix B, Procedure 1, Quality Control Program and Appendix B, Procedure 2,
Frequency of Testing except Procedure 2.1.5, Procedure 2.2.3 and Procedure 2.3.2, which
define the out-of control periods for the daily, quarterly, semiannual and annual
assessments, respectively. The following requirements shall be used to define the out-of-
control criteria for the emission data:

(1) 40 CFR Part 60, Appendix F, Procedure 4.3, Criteria for Excessive Calibration Drift
(2) 40 CFR Part 60, Appendix F, Procedure 5.2, Excessive Audit Inaccuracy
(3) 40 CFR Part 60, Appendix F, Procedure 6, Calculations for CEMS Data Accuracy.

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; and all other information required by applicable portions of
40 CFR Part 60, Subparts A and Da recorded in a permanent form suitable for inspection.

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

II.B.3.b.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and
(d) and 40 CFR 60.51Da, Reporting requirements. A data assessment report required by
Appendix F, Procedure 1, Section 7 to 40 CFR Part 60 shall be submitted with the excess
emission report.

(b) Relative Accuracy Test Audit notifications shall be made in accordance with R307-
170, Continuous Emission Monitoring System Program.

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

(d) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director shall
also be submitted to USEPA, Region VIII, if requested.

41
(e) The reports required in paragraphs (a), (b), (c), and (d) 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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. Unit 3
was offline during this inspection. The lb/MMBtu SO2 30-Day reading during
inspection was 0.091.

II.B.3.c Condition:

Emissions of SO2 shall be no greater than 10 percent of the potential combustion concentration
based on the average inlet and average outlet SO2 emissions determined as the arithmetic average
of all hourly emission rates for the 30 successive boiler operating days. [40 CFR 60.43Da,
60.48Da, and DAQE- AN102370028-18]. [40 CFR 60 Subpart Da, R307-401-8]

II.B.3.c.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system, and record the output of the system, for measuring sulfur dioxide emissions. The
permittee shall determine compliance in accordance with 40 CFR Part 60.48Da,
Compliance provision (subparagraph (c), (d), (e), (g) and (h)), 60.49Da, Emission
monitoring (subparagraph (b), (d), (e), (f), (g), (h), (i) and (j)), and 60.50Da, Compliance
determination procedures and methods (subparagraph (c)).

(b) SO2 inlet monitor shall meet the following requirements:
(1) 40 CFR Part 60, Appendix B, Specifications and Test Procedures for SO2 and NOx
Continuous Emission monitoring Systems in Stationary Sources
(2) 40 CFR Part 60, Appendix F, Quality Assurance Procedures

(c) The permittee shall implement a Quality Control program for the SO2 outlet monitors
according to 40 CFR Part 75, Appendix B, Procedure 1, Quality Control Program and
Appendix B, Procedure 2, Frequency of Testing except Procedure 2.1.5, Procedure 2.2.3
and Procedure 2.3.2, which define the out of control periods for the daily, quarterly,
semiannual and annual assessments, respectively. The following requirements shall be
used to define the out-of-control criteria for the emission data:
(1) 40 CFR Part 60, Appendix F, Procedure 4.3, Criteria for Excessive Calibration Drift
(2) 40 CFR Part 60, Appendix F, Procedure 5.2, Excessive Audit Inaccuracy
(3) 40 CFR Part 60, Appendix F, Procedure 6, Calculations for CEMS Data Accuracy

(d) An "as-fired" fuel monitoring system (upstream of coal pulverizers) meeting the
requirements of Method 19 (40 CFR Part 60 Appendix A) may be used as an alternative
method to determine potential sulfur dioxide emissions in place of a continuous sulfur
dioxide emission monitor at the inlet to the sulfur dioxide control device.

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
42
on these systems or devices; and all other information required by applicable portions of
40 CFR Part 60, Subparts A and Da recorded in a permanent form suitable for inspection.

(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 excess emission reports required by 40 CFR 60.7(c) and
(d) and 40 CFR 60.51Da, Reporting requirements. A data assessment report required by
Appendix F, Procedure 1, Section 7 to 40 CFR Part 60 shall be submitted with the excess
emission report.

(b) Relative Accuracy Test Audit notifications shall be made in accordance with R307-
170, Continuous Emission Monitoring System Program.

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

(d) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director shall
also be submitted to USEPA, Region VIII, if requested.

(e) The reports required in paragraphs (a), (b), (c), and (d) 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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist.

II.B.3.d Condition:

Visible emissions shall be no greater than 20 percent opacity (six-minute average) except during
periods of startup, shutdown, and malfunction and except for one 6-minute period per hour of not
more than 27 percent opacity. During startup and shutdown events, the permittee shall
demonstrate compliance with the requirements under Provision II.B.1.h of this permit.
[60.42Da(b), 60.11(c), and DAQE- AN102370028-18]. [40 CFR 60 Subpart Da, R307-203-3,
R307-401-8]

II.B.3.d.1 Monitoring:

(a) The permittee shall determine compliance with the visible emission limit by periodic
monitoring using a continuous opacity monitoring (COM) system installed and operated
in accordance with 40 CFR 60.49a, Emission monitoring (subparagraphs (a), (e), (f), and
(i)), and 60.13, Monitoring requirements (subparagraphs (e) and (h)).

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

(1) 40 CFR 60.13, Monitoring requirements (subparagraphs (d) and (f))
43
(2) 40 CFR Part 60, Appendix B, Performance Specification 1, Specifications and Test
Procedures or Opacity Continuous Emission Monitoring Systems in Stationary Sources
(3) R307-170, Continuous Emission Monitoring System Program.

II.B.3.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 Da recorded in a permanent form suitable for inspection.

(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.d.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and
(d) and 40 CFR 60.51Da, Reporting requirements. A data assessment report required by
Appendix F, Procedure 1, Section 7 to 40 CFR Part 60 shall be submitted with the excess
emission report.

(b) Relative Accuracy Test Audit notifications shall be made in accordance with R307-
170, Continuous Emission Monitoring System Program.

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

(d) A copy of all reports required by 40 CFR Part 60 to be submitted to the Director shall
also be submitted to USEPA, Region VIII, if requested.

(e) The reports required in paragraphs (a), (b), (c), and (d) 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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. Unit 3
was offline during this inspection.

II.B.3.e Condition:

Emissions of CO shall be no greater than 0.2 lb/MMBtu heat input for a 30-day rolling average
and no greater than 2406 lb/hr for an 8-hour block average after the startup of the new low NOx
burner/OFA. [DAQE-AN102370028-18]. [R307-401-8]

44
II.B.3.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
shall be calculated every hour and the 8-hour block average and daily average shall be
calculated using the hourly average data. The daily average of CO emission shall be used
to calculate 30-day rolling average.

II.B.3.e.2 Recordkeeping:

In addition to the recordkeeping requirement described in Provision I.S.1 of this permit,
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.3.e.3 Reporting:

(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: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. The
initial stack test has been performed. Unit 3 was offline during this inspection. The
30-day CO lb/MMBtu reading was 0.074.

II.B.3.f Condition:

Emissions of NOx shall be no greater than 0.34 lb/MMBtu based on a 30-day rolling average as
determined by the arithmetic average of all hourly emission rates for the 30 successive boiler
operating days. [40 CFR 60.44Da and DAQE-AN102370028-18]. [40 CFR 60 Subpart Da, R307-
401-8]

II.B.3.f.1 Monitoring:

(a) The permittee shall install, calibrate, maintain, and operate a continuous monitoring
system, and record the output of the system, for measuring nitrogen oxides emissions.
The permittee shall determine compliance in accordance with 40 CFR Part 60.48Da,
Compliance provision (subparagraphs (b), (c), (e), (g) and (h), 60.49Da, Emission
monitoring (subparagraphs (c), (d), (e), (f), (g), (h), (i), and (j)), and 60.50Da,
Compliance determination procedures and methods (subparagraph (d)).

45
(b) Each continuous emission monitoring system shall meet the following requirements:
40 CFR Part 75 Appendix A, Specification and Test Procedures,

(1) Installation and Measurement Location
(2) Equipment Specifications (except the requirement for a low range in 2.1.1.2)
(3) Performance Specifications
(4) Data Acquisition and Handling Systems
(5) Calibration Gas

(c) The permittee shall implement a Quality Control program according to 40 CFR Part
75 Appendix B, Procedure 1, Quality Control Program, and Appendix B, Procedure 2,
Frequency of Testing, except Procedure 2.1.5, Procedure 2.2.3 and Procedure 2.3.2,
which define the out-of control periods for the daily, quarterly, semiannual and annual
assessments, respectively. The following requirements shall be used to define the out-of-
control criteria for the emission data:

(1) 40 CFR Part 60, Appendix F, Procedure 4.3, Criteria for Excessive Calibration Drift
(2) 40 CFR Part 60, Appendix F, Procedure 5.2, Excessive Audit Inaccuracy
(3) 40 CFR Part 60, Appendix F, Procedure 6, Calculations for CEMS Data Accuracy.

(d) A 30-day rolling average shall be calculated every day for NOx emissions by using
daily average emission rates.

II.B.3.f.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 Da recorded in a permanent form suitable for inspection.

(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.f.3 Reporting:

(a) The permittee shall submit excess emission reports required by 40 CFR 60.7(c) and
(d) and 40 CFR 60.51Da, Reporting requirements. A data assessment report required by
Appendix F, Procedure 1, Section 7 to 40 CFR Part 60 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 shall
also be submitted to USEPA, Region VIII, if requested. (40 CFR 60.4 and 60.7(c))

46
(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.

Status: Not evaluated. CEM requirements are evaluated by DAQ’s CEM specialist. The
initial stack test has been performed. Unit 3 was offline during this inspection. The
30-day NOx Lb/MMBtu reading was 0.287.

II.B.3.g 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. [40 CFR 63.10000(b)]. [40 CFR 63 Subpart UUUUU]

II.B.3.g.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.3.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 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.3.g.3 Reporting:

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

Status: In compliance. The facility appeared to be maintained in a manner consistent with
good air pollution control practices for minimizing emissions. A preventative work
order system is in place utilizing SAP software. Annual projections of planned
outages have been submitted.

47
II.B.3.h Condition:

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

(a) Emission of filterable particulate matter (PM) shall be no greater than 3.0E-02 lb/MMBtu;

(b) Emission of sulfur dioxide (SO2) shall be no greater than 2.0E-01 lb/MMBtu;

(c) Emission of mercury (Hg) shall be no greater than 1.2E0 lb/TBtu;

(d) The permittee shall conduct a tune-up of the EGU burner and combustion controls at least
each 36 calendar months, or each 48 calendar months if neural network combustion optimization
software is employed;

(e) The permittee shall comply with the emission limits at all times except during periods of
startup and shutdown. The permittee shall meet the work practice in Table 3(3) and (4) of 40 CFR
63 Subpart UUUUU during periods of startup, or shutdown;

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

II.B.3.h.1 Monitoring:

(a) General Compliance Requirement:

(1) Filterable PM: The permittee shall demonstrate compliance through performance
stack testing repeated quarterly;

(2) SO2: The permittee shall demonstrate continuous compliance through use of a SO2
CEMs in accordance with 40 CFR Subpart 75;

(3) Hg: The permittee shall demonstrate continuous compliance through use of a Hg
CEMs in accordance with appendix A to 40 CFR 63 Subpart UUUUU. The permittee
shall operate and maintain the CEMs according to the site-specific monitoring plan as
required in 40 CFR 63.10000(d)(5)(i) through (vii);

(4) 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 43 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 43 CFR 63.10020(b)
through (d) and the site-specific monitoring plan required by 40 CFR 63.10000(d).

(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
48
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].

II.B.3.h.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.

49
II.B.3.h.3 Reporting:

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

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

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

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

Status: In compliance with stack testing requirements. CEM requirements are evaluated by DAQ’s CEM
specialist.

See status of II.B.3.a above for PM emission testing results. SO2 is monitored by CEM. Hunter
Power Plant has attained LEE status for Mercury (see DAQC-346-17) and is using the alternate
compliance option listed under (d) of monitoring. Mercury is tested using Method 30B every 12
calendar months. 40 CFR 63.10031(f)(6) requires this test report be submitted to EPA only thru the
ECMPS client tool. Hg rate calculations are submitted to DAQ annually in the report required by
II.B.2.k and II.B.3.i. Semi-annual Subpart UUUUU reports have been submitted and summarize
these tests as well as boiler tune-ups.

The stack test was completed on November 28, 2023, and reviewed under DAQC-1361-23 as
follows:

Source Test Date DAQ Result Test Result Limit

Unit 3 10/25-11/28 5.7E-8 lb/MMBtu 5.4E-8 lb/MMBtu 6.5E-7 lb/MMBtu
0.05 lb/TBtu 0.05 lb/TBtu 1.2 lb/TBtu
0.0006 lb/GW-hr 0.0006 lb/GW-hr 0.013 lb/GW-hr
2.7 lbs/yr* 2.6 lbs/yr* 29 lbs/yr*
2.3 lbs/yr** 2.3 lbs/yr** 29 lbs/yr**

*Emission rate calculated based on maximum electrical output per year
**Emission rate calculated based on maximum heat input per year

II.B.3.i Condition:

Emissions of mercury shall be no greater than 6.5E-07 lb/MMBtu heat input based on an annual
averaging period beginning January 1st and ending December 31st. [R307-424-4]. [R307-424-4]

50
II.B.3.i.1 Monitoring:

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

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

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

II.B.3.i.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.i.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. PacifiCorp has obtained LEE status and monitors Hg emissions
using option (c). Annual reports have been submitted and include emission rate
calculations. See condition II.B.3.h above for test results.

51
II.B.4 Conditions on Coal Conveyors (Emission unit #11).

II.B.4.a Condition:

All coal conveyors and drop points, the live coal handling and storage shall be enclosed.
[DAQE- AN102370028-18] [R307-401-8].

II.B.4.a.1 Monitoring:

The permittee shall ensure the required covers are installed.

II.B.4.a.2 Recordkeeping:

A log shall be maintained for any periods of operation when the required 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 are enclosed.

II.B.5 Conditions on #1 Emergency Fire Pump (Emission unit #18)

II.B.5.a Condition:

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

The permittee shall operate the affected emission unit according to the requirements in 40 CFR
60.4211(f)(1) through (3). Each emergency affected emission unit shall not exceed 100 hours of
maintenance checks and readiness testing per year unless the permittee maintains records
indicating that Federal, State, or local standards require maintenance and testing of affected
emission units beyond 100 hours per year. There is no time limit on the use of emergency
stationary ICE in emergency situations. Emergency engines may operate up to 50 hours per year
in non-emergency situations, but those 50 hours are counted towards the 100 hours per year
provided for maintenance and testing. The 50 hours per year for non-emergency situations cannot
be used for peak shaving or to generate income for a facility to supply power to an electric grid or
otherwise supply non-emergency power as part of a financial arrangement with another entity.
Any operation other than emergency operation, maintenance and testing, and operation in non-
emergency situations for 50 hours per year, as permitted in 40 CFR 60.4211(f), is prohibited. If
the engine is not operated in accordance with paragraphs 40 CFR 60.4211(f)(1) through (3), it
will not be considered an emergency engine and shall meet all requirements for non-emergency
engines.

[40 CFR 60.4211(f)]. [40 CFR 60 Subpart IIII]

52
II.B.5.a.1 Monitoring:

The permittee shall install a non-resettable hour meter if one is not already installed.
[Origin: 40 CFR 60.4209(a)]. Records required for this permit condition will serve as
monitoring.

II.B.5.a.2 Recordkeeping:

Records of each affected emission unit shall be kept on a monthly basis in an operation
and maintenance log. Records shall distinguish between maintenance-related hours and
emergency used-related hours. If maintenance and testing beyond 100 hours per year and
required by Federal, State, or local standards, records of these standards shall also be
kept.

Records shall be maintained as described in Provision I.S.1 of this permit.

II.B.5.a.3 Reporting:

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

Status: In compliance. Generator use logs have been kept and showed no exceedances of
permitted limits.

II.B.5.b Condition:

Affected emission units with a displacement of less than 30 liters per cylinder shall comply with
the emission standards in Table 4 of 40 CFR 60 Subpart IIII, for all pollutants.

If the permittee conducts performance tests in-use on emergency stationary CI ICE with a
displacement of less than 30 liters per cylinder 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 40 CFR part 1042, subpart F, for stationary CI
ICE with a displacement of greater than or equal to 10 liters per cylinder and less than 30 liters
per cylinder. [40 CFR 60.4204(b) and 40 CFR 60.4212]. [40 CFR 60 Subpart IIII]

II.B.5.b.1 Monitoring:

The permittee shall comply by purchasing an engine certified to the emission standards in
40CFR 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. The permittee can only change those emission-
related settings that are permitted by the manufacturer. (Origin: 40 CFR 60.4211(c))

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

53
If the permittee does not install, configure, operate, and maintain affected emission units
and control devices according to the manufacturer's emission-related written instructions,
or changes emission-related settings in a way that is not permitted by the manufacturer,
the permittee shall demonstrate compliance as follows:

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

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

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

II.B.5.b.2 Recordkeeping:

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

II.B.5.b.3 Reporting:

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

Status: In compliance. A certified engine has been permitted, purchased, and installed.

II.B.5.c 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.
[40 CFR 60.4207(b)]. [40 CFR 60 Subpart IIII]

II.B.5.c.1 Monitoring:

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

II.B.5.c.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.

54
II.B.5.c.3 Reporting:

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

Status: In compliance. Fuel records were provided and included sulfur content and cetane
index values.

II.B.6 Conditions on #2 Emergency Fire Pump (Emission unit #19)

II.B.6.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 have 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.

[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]

55
II.B.6.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.6.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]
56
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.6.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. The permittee shall also report each
instance in which it did not meet the applicable requirements in Table 8.
[40 CFR 63.6640(e)]

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

Status: In compliance. Maintenance requirements have been entered into the permittee’s
preventative maintenance work order system. A non-resettable hour meter has been
installed. Operating hours are recorded.
57
II.B.6.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.
[40 CFR 63.6595(a)(1), 40 CFR 63.6605(b)]. [40 CFR 63 Subpart ZZZZ]

II.B.6.b.1 Monitoring:

Records required for this permit condition will serve as monitoring.

II.B.6.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.6.b.3 Reporting:

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

Status: In compliance. The facility appeared to be well maintained.

II.B.7 Conditions on Gypsum Off-loading Conveyor (Emission unit# 49)

II.B.7.a Condition:

All conveyors and drop points shall be enclosed in a structure. Fugitive dust and emissions shall
be minimized. [DAQE-AN102370028-18]. [R307-401-8]

II.B.7.a.1 Monitoring:

The permittee shall ensure the required covers are installed.

II.B.7.a.2 Recordkeeping:

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

58
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. All conveyors and drop points are enclosed.

II.B.8 Conditions on Refined Coal System (Emission unit # 50)

II.B.8.a Condition:

All conveyors, drop points, live coal handling and storage shall be enclosed in a structure.
Fugitive dust and emissions shall be minimized. [DAQE-AN102370028-18]. [R307-401-8]

II.B.8.a.1 Monitoring:

The permittee shall ensure the required covers are installed.

II.B.8.a.2 Recordkeeping:

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

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. All conveyors and drop points are enclosed.

II.B.8.b Condition:

The amount of M45-PC-A used at the Refined Coal System shall be limited to 12, 533 tons per
rolling 12-month period. [DAQE-AN102370028-18]. [R307-401-8]

II.B.8.b.1 Monitoring:

The permittee shall calculate a new 12-month total by the 20th day of each month using
throughput data from the previous 12 months. Throughput shall be determined by
purchase records or any other methods approved by the Director.

II.B.8.b.2 Recordkeeping:

The records of material throughput shall be kept on a daily basis and for all periods when
the plant is in operation.

59
II.B.8.b.3 Reporting:

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

Status: In compliance. The permittee discontinued using M45-PC-A in December, 2021.
During the 12-month period ending March 30, 2024, the amount was 0 tons of
M45-PC-A.

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.

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.
II.E.1 Startup. Startup is defined as the period beginning with the introduction of fuel into the boiler and
ending no later than when two coal feeders have been proven in service and the flue gas temperature
at the outlet ducts to both sides of the baghouse outlet (Units #1, #2 or #3 boilers) have reached a
temperature of 220oF and less than 20 percent of the boiler heat input is being furnished by fuel oil.
II.E.2 Shutdown. Shutdown is defined as the period beginning 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 and ending when fuel flow to the boiler ceases.
II.E.3 Downtime. Downtime is that time between the end of shutdown and the beginning of startup in which
the affected source has temporarily ceased operation.
II.E.4 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.
II.E.5 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.

60
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 (NSPS for 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 Y (NSPS for Coal Preparation Plants)

This regulation is not applicable to the Permitted Source for the following reason(s): the source does
not include equipment to crush, break, screen, wet or dry clean, or thermal dry coal that is required
for applicability as described in EPA applicability determination #NS48 dated 5/17/85
III.D. 40 CFR, Part 63, Subpart Q (NESHAP for Industrial Process Cooling Towers)

This regulation is not applicable to the Permitted Source for the following reason(s): the cooling
towers are not operated with chromium-based water treatment chemicals
III.E. 40 CFR, Part 60, Subparts K, Ka, Kb (NSPS for Volatile Organic Liquid Storage Vessels)

This regulation is not applicable to the Distillate Fuel Oil Tanks (Emission unit #28) for the
following reason(s): the tanks were constructed prior to 1984. 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
III.F. 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 Steam Generating Unit #1 (Emission unit #1) for the
following reason(s): this unit was constructed prior to September 18, 1978
III.G. 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 Steam Generating Unit #2 (Emission unit #2 for the
following reason(s): this unit was constructed prior to September 18, 1978
61
III.H. 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 Steam Generating Unit #3 (Emission unit #3) for the
following reason(s): 40 CFR 40(e) excludes facilities regulated by Subpart Da from regulation by
Subpart D

SECTION IV: ACID RAIN PROVISIONS

IV.A Utah Acid Rain Program Authority.
Authority to implement the Acid Rain Program is contained in R307-417, Permits:
Acid Rain Sources, and R307-415-6a(4), Standard permit requirements [for operating
permits].
Status: For informational purposes only.
IV.B Permit Requirements.
IV.B.1 The designated representative of the source and each affected unit at the source shall:
IV.B.1.a Submit a complete Acid Rain permit application (including a compliance plan)
under R307-417 and 40 CFR Part 72 in accordance with the deadlines specified
in 40 CFR 72.30; and
IV.B.1.b Submit in a timely manner any supplemental information that the Director
determines is necessary in order to review an Acid Rain permit application and
issue or deny an Acid Rain permit;
IV.B.2 The owners and operators shall:
IV.B.2.a Operate each affected unit at the source in compliance with a complete Acid
Rain permit application or a superseding Acid Rain permit issued by the
Director; and
IV.B.2.b Have an Acid Rain Permit.
Status: In compliance – The source is part of the Acid Rain program.
IV.C Sulfur Dioxide Requirements.
IV.C.1 The owners and operators of each affected unit at the source shall:
IV.C.1.a Hold allowances, as of the allowance transfer deadline, in the unit's compliance
subaccount (after deductions under 40 CFR 73.34(c)) not less than the total
annual emissions of sulfur dioxide for the previous calendar year from the unit;
and
IV.C.1.b Comply with the applicable Acid Rain emissions limitations for sulfur dioxide.
62
IV.C.2 Each ton of sulfur dioxide emitted in excess of the Acid Rain emissions limitations for
sulfur dioxide shall constitute a separate violation of the Act.
IV.C.3 An affected unit shall be subject to the requirements under Provision IV.C.1. of the
sulfur dioxide requirements as follows:
IV.C.3.a Starting January 1, 2000, an affected unit under 40 CFR 72.6(a)(2); or
IV.C.3.b Starting on the later of January 1, 2000 or the deadline for monitor certification
under 40 CFR Part 75, an affected unit under 40 CFR 72.6(a)(3).

IV.C.4 Allowances shall be held in, deducted from, or transferred among Allowance Tracking
System accounts in accordance with the Acid Rain Program.
IV.C.5 An allowance shall not be deducted in order to comply with the requirements under
Provision IV.C.1.a. of the sulfur dioxide requirements prior to the calendar year for
which the allowance was allocated.
IV.C.6 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program is
a limited authorization to emit sulfur dioxide in accordance with the Acid Rain
Program. No provision of the Acid Rain Program, the Acid Rain permit application,
the Acid Rain permit, or the written exemption under 40 CFR 72.7 and 72.8 and no
provision of law shall be construed to limit the authority of the United States to
terminate or limit such authorization.
IV.C.7 An allowance allocated by the Administrator, USEPA, under the Acid Rain Program
does not constitute a property right.
Status: In compliance – The source is part of the Acid Rain program.
IV.D Nitrogen Oxides Requirements.
The owners and operators for each affected unit at the source shall be compliance with
the applicable Acid Rain emissions limitations for nitrogen dioxide.
Status: In compliance – The source is part of the Acid Rain program.
IV.E Monitoring Requirements.
IV.E.1 The owners and operators and, to the extent applicable, designated representative of
each affected unit at the source shall comply with the monitoring requirements as
provided in 40 CFR Parts 74, 75, and 76.
IV.E.2 The emissions measurements recorded and reported in accordance with 40 CFR Part 75
shall be used to determine compliance by the unit with the Acid Rain emissions
limitations and emissions reduction requirements for sulfur dioxide and nitrogen oxides
under the Acid Rain Program.
63
IV.E.3 The requirements of 40 CFR Parts 74 and 75 shall not affect the responsibility of the
owners and operators to monitor emissions of other pollutants or other emissions
characteristics at the unit under other applicable requirements of the Act and other
provisions of the operating permit for the source.
Status:

In compliance – Acid Rain monitoring and reporting is performed.
IV.F Recordkeeping and Reporting Requirements.
IV.F.1 Unless otherwise provided, the owners and operators for each affected unit at the source
shall keep on site at the source each of the following documents for a period of 5 years
from the date the document is created. This period may be extended for cause, at any
time prior to the end of 5 years, in writing by the Administrator, USEPA, or Director:
IV.F.1.a The certificate of representation for the designated representative for the source
and each affected unit at the source and all documents that demonstrate the truth
of the statements in the certificate of representation, in accordance with 40 CFR
72.24; provided that the certificate and documents shall be retained on site at the
source beyond such 5-year period until such documents are superseded because
of the submission of a new certificate of representation changing the designated
representative;
IV.F.1.b All emissions monitoring information, in accordance with 40 CFR Part 75;

IV.F.1.c Copies of all reports, compliance certifications, and other submissions and all
records made or required under the Acid Rain Program; and,
IV.F.1.d Copies of all documents used to complete an Acid Rain permit application and
any other submission under the Acid Rain Program or to demonstrate
compliance with the requirements of the Acid Rain Program.
IV.F.2 The designated representative of each affected unit at the source shall submit the reports
and compliance certifications required under the Acid Rain Program, including those
under 40 CFR Part 72 Subpart I and 40 CFR Part 75.
Status: In compliance – Acid Rain reporting is performed.
IV.G Excess Emissions Requirements.
IV.G.1 The designated representative of an affected unit that has excess emissions in any
calendar year shall submit a proposed offset plan to the Administrator, USEPA, as
required under 40 CFR Part 77.
IV.G.2 The owners and operators of an affected unit that has excess emissions in any calendar
year shall:
IV.G.2.a Pay without demand the penalty required, and pay upon demand the interest on
that penalty, to the Administrator, USEPA, as required by 40 CFR Part 77; and
64
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.
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.

65
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,
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: Taken from DAQ’s 2022 emissions inventory database:

Pollutant Code/CAS # Pollutant Name
Emissions
(tons, excluding
tailpipe)

Tailpipe
Emissions
(tons)

Total Emissions
(tons)*
PM10-PRI PM10 Primary(Filt + Cond) 580.10483 0.14849 580.25332
PM10-FIL PM10 Filterable 474.26867 <.00001 474.26867
PM25-PRI PM2.5 Primary(Filt + Cond) 306.2462 0.14404 306.39024
PM25-FIL PM2.5 Filterable 200.32631 <.00001 200.32631
PM-CON PMCondensible 106.07399 <.00001 106.07399
SO2 Sulfur Dioxide 3,274.50013 0.00444 3,274.50456
NOX Nitrogen Oxides 9,517.27549 2.94465 9,520.22014
VOC Volatile Organic Compounds 116.0535 0.23418 116.28768
CO Carbon Monoxide 4,396.24281 1.18588 4,397.42869
7439921 Lead 0.07425 <.00001 0.07425
NH3 Ammonia 1.31103 <.00001 1.31103

CRITERIA AIR POLLUTANT (CAP) EMISSIONS TOTALS
66
Pollutant Code/CAS # Pollutant Name Is VOC/PM?
Total Emissions (tons)*

107028 Acrolein (HAP) VOC 0.15996
7440360 Antimony (HAP) PM 0.01329
7440382 Arsenic (HAP) PM 0.01787
71432 Benzene (HAP) VOC 0.09156
100447 Benzyl Chloride (HAP) VOC 0.08683
7440417 Beryllium (HAP) PM 0.00143
117817 Bis(2-Ethylhexyl)Phthalate (HAP) VOC 0.10968
75252 Bromoform (HAP) VOC 0.07479
7440439 Cadmium (HAP) PM 0.02415
532274 2-Chloroacetophenone (HAP) VOC 0.01342
7440473 Chromium (HAP) PM 0.15339
7440484 Cobalt (HAP) PM 0.01519
57125 Cyanide (HAP) PM 4.79577
132649 Dibenzofuran (HAP) VOC 0.12797
77781 Dimethyl Sulfate (HAP) VOC 0.09204
121142 2,4-Dinitrotoluene (HAP) VOC 0.01234
106934 Ethylene Dibromide (HAP) VOC 0.00226
50000 Formaldehyde (HAP) VOC 0.01836
7647010 Hydrochloric Acid (HAP) - 6.52354
7664393 Hydrogen Fluoride (HAP) - 7.52429
7439965 Manganese (HAP) PM 0.23973
7439976 Mercury (HAP) - 0.00197
74839 Methyl Bromide (HAP) VOC 0.30698
74873 Methyl Chloride (HAP) VOC 1.0167
60344 Methylhydrazine (HAP) VOC 0.32532
108101 Methyl Isobutyl Ketone (HAP) VOC 0.13226
75092 Methylene Chloride (HAP) - 0.5563
7440020 Nickel (HAP) PM 0.15548
123386 Propionaldehyde (HAP) VOC 0.22851
7782492 Selenium (HAP) PM 0.39885

PREVIOUS ENFORCEMENT
ACTIONS: None in the past 5 years.

CURRENT STATUS &
RECOMMENDATIONS: PacifiCorp’s Hunter Plant should be considered in compliance with the
Title V permit conditions evaluated during this inspection.

HPV STATUS: Not applicable

HAZARDOUS AIR POLLUTANT (HAP) and/or OTHER POLLUTANT EMISSIONS TOTALS
67
RECOMMENDATIONS FOR
NEXT INSPECTION: Inspect as usual

ATTACHMENTS: VEO form