DAQ-2024-005026

1

DAQC-087-24
Site ID # 10238-B4
MEMORANDUM

TO: STACK TEST FILE – PAFICIFICORP ENERGY – Huntington Power Plant

THROUGH: Harold Burge, Major Source Compliance Section Manager

FROM: Paul Morris, Environmental Scientist

DATE: January 31, 2024

SUBJECT: Location: Huntington Power Plant, Huntington, Carbon County, Utah
Contact: Russ Wilson: 435-687-4331
Tester: Montrose Air Quality Services, LLC: 303-495-3936
Sources: Units 1 and 2
FRS ID #: UT0000004901500101
Permit # Title V operating permit 1501001005 dated January 22, 2020, revised
August 26, 2021
Subject: Review of Pretest Protocols dated January 16, 2024

On January 24, 2024, the DAQ received protocols for testing of the Pacificorp Energy Huntington Power
Plant Units 1 and 2 located in Huntington, Utah. Testing will begin March 19, 2024. Testing will be
conducted to determine emission rates in accordance with 40 CFR 63 Subpart UUUUU and Title V
permit conditions II.B.2.c, II.B.2.g, II.B.2.h, II.B.3.d, II.B.3.f, and II.B.3.g.

PROTOCOL CONDITIONS:

1. RM 30B used to determine total vapor phase mercury emissions; OK
2. RM 5 used to determine filterable particulate matter emissions; OK
3. RM 202 used to determine condensable particulate matter emissions; OK
DEVIATIONS: None noted.

CONCLUSION: The protocols appears to be acceptable.

RECOMMENDATION: Send protocol review and test date confirmation notice. Test as specified in
protocols.

ATTACHMENT: Test protocols received January 24, 2024

6 , 3
-Tfr^H DFTAFiTMENT oF
r r(vi i q-lUg N ref. o u AUry
Yr,*slflF"g"Rr
Huntington Power Plant
6 miles west of Huntington, Utah on Hwy. 3l
P.O. Box 680
Huntington, Utah 84528
January 16,2024
Mr. Bryce Bird, Director
State of Utah
Division of Air Quality
Department of Environmental Quality
P. O. Box 144820
Salt Lake City, Utah 841144820
Attn: Rob Leishman
Re: Notification of PacifiCorp Huntington Plant's Units I and 2 Low Emitting Electrical (LEE)
Generating Unit Qualification Demonstration
Dear Mr. Bird:
The Huntington plant is providing notification to the Utah Department of Environmental Quality -
Department of Air Quality, of a planned 30-day Mercury (Hg) LEE demonstration test to determine if Units
1 and2 continue to qualify as low emitting electrical(LEE) generating units. The testing will be conducted
in accordance with 40 CFR Part 63, Subpart UUUUU. The testing is scheduled to begin March 19,2024.
Should you any questions or concerns, please contact Mr. Terry Guthrie at (435) 6874334 or me at
(435) 687
Laren
Managing Director,
Responsible Offlcial
Enclosures:Source Test Plan for Annual2024 Compliance Testing Unit 1 & Unit 2 PacifiCorp
Huntington Power Plant, Huntington, Utah
Youn Joo Kim - EPA Region Vlll Wenclosures
Russ Wilson - Huntington Plant Files w/enclosures
Tom Wiscomb - PacifiCorp Environmental NTO 210 w/enclosures
Scarlet Jackson - PacifiCorp Environmental NTO 210 denclosures
Terry Guthrie - Hunter and Huntington Plant Environmental Manager
Hunter and Huntington
CC:
Source Test Plan for
Annuaa 2024 Compliance Testing
Unitl&Unit2
PacifiCorp
Huntington Power Plant
Huntington, Utah
Prepared For:
PacifiCorp
t4O7 W North Temple, Suite 210
Salt Lake City, Utah 84116
Jrll 24 2A?4
Prepared By:
Montrose Air Quality Services,
990 West 43rd Avenue
Denver, CO 80211
LLC
For Submission To:
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Document Number: GPO43AS-O22722'PP'776
Proposed Test Start Date: March lgt 2fJ24
Submittal Date: February L9, 2(J24
TTAH DE-PARTMENT OF
e uii RaNUe N:IAL- ou4L[Y
DIVISiON OF AIR OIIALITY
bAI'iD'8ffi
Ctfr.)tlllor6rl l'l?,NT+9lI 5TA6
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Signature:
Name: Matthew Parks
Date:
Title:
Date:
Title:
L2/t/2O23
QA/QC Analyst
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby certify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
--'7_,Signature: -. '- ././///* " (L2/L/2O23
Name:Tim Wojtach Account Manager
GP043AS-0227 22-PP -7 7 6 Page 2 of 42
Table of Contents
Section paoe
1.0 Introduction ........ ................ 5
1.1 Summary of Test Program .....'....'..5
t.2 Applicable Regulations and Emission Limits... '.'................6
1.3 Key Personnel........... .......'.'.........7
2.0 Plant and Sampling Location Descriptions.............. '.................8
2.L Process Description, Operation, and Control Equipment..........'.. .....'..8
2.2 Flue Gas Sampling Locations.. ........8
2.3 Operating Conditions and Process Data ........'..8
2.4 Plant Safety '..'.....'.'.....9
2.4.1 Safety Responsibilities.,.... ............'.......9
2.4.2 SafeLy Program and Requirements..... ............."... 10
3.0 Sampling and Analytical Procedures ..... 11
3.1 Test Methods............ ............'.'.' 11
3.1.1 EPA Method 30B ......... '.'....11
3.2 Process Test Methods............ ........,..12
4.0 Quality Assurance and Reporting.........,. ...'..."........13
4.L QA Audits '.'.'. 13
4.2 Quality Control Procedures ..........13
4.2.1 Equipment Inspection and Maintenance.......,...... ..".....'..."....13
4.2.2 Audit Samples ......".'..'...... 13
4.3 Data Analysis and Validation ........13
4.4 Sample Identification and Custody.... ...'........14
4.5 Quality Statement ......14
4.6 Reporting '.'..',...'..14
4.6.1 Example Report Format '..'.' 15
4.6.2 Example Presentation of Test Resu|ts,............. ..... 16
List of Appendices
Appendix A Supporting Information.. .......... L7
Appendix A.1 Units and Abbreviations,..... ....'.......18
AppendixA.2 Accreditationlnformation/Certifications.......,.... ................26
Appendix "S" Field Work Safety Plan,........ ................. 28
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule ..'.....'.5
Proposed Test Date ..,..............5
GP043AS-0227 22-PP -7 7 6 Page 3 of 42
Table 1-2 Reporting Units and Emission Limits .........'....6
Table 1-3 Test Personnel and Responsibilities ...............8
Table 2-1 Sampling Location(s).......... ......."8
Table 4-1 Example <Parameter> Emissions Results - Unit Name....... ............ 16
List of Figures
Figure 3-1 EPA Method 30B Sampling Train ...'.'...........L2
Figure 4-1 Typical Report Format '.......'.'... 15
GP043AS-0227 22-PP -77 6 Page 4 of 42
1.O Introduction
1.1 Summary of Test Program
PaciflCorp contracted Montrose Air Quality Seruices, LLC (Montrose) to perform an
emissions test program at the Huntington Power Plant located in Huntington, Utah. The
tests are conducted to determine compliance with the applicable UDEQ permit.
The specific objectives are to:
. Perform annual mercury emissions testing on the exhaust stacks of Unit 1
and Unit 2 over 30-day operating periods.
. Conduct the test program with a focus on safety
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-1
Summary of Test Program and Proposed Schedule
GP043AS-0227 22-PP -7 7 6 Page 5 of 42
To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
L,2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Repofting Units and Emission Limits
40 CFR Part 63, Subpart UUUUU
(Low Emitting EGU Limit)
Units 1 & 2
40 CFR Part 63, Subpart UUUUU
(Low Emitting EGU Limit)
40 CFR Part 63, Subpart UUUUU
(Low Emitting EGU Limit)
G P043AS-0227 22-PP -7 7 6 Page 6 of 42
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location: PacifiCorp
Huntington Plant
8 Miles West of Huntington on Hwy 31
Huntington, Utah 84528
Tom Wiscomb
Sr, Environmental Advisor
PacifiCorp
[phone]
Tom. Wiscom b@pacifl corp.com
Agency Information
Regulatory Agency: Utah Depaftment of Air Quality
Agency Contact: Rob Leishman
Telephone: [phone]
Email: [e-mail]
Testing Company Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Craig Kormylo
Title: District Manager
Telephone: [phone]
Email: [e-mail]
Russell Willson
Senior Environmental Analyst
PacifiCorp
(43s) 687-433t
Russel l.Willson@Pacifl Corp.com
Project Contact:
Role:
Company:
Telephone:
Email:
GP043AS-0227 22-PP -7 7 6 Page 7 of 42
Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personne! and Responsibilities
2.O Plant and Sampling Location Descriptions
Facility interface, test crew coordination
Preparation, support PM
2.1 Process Description, Operation, and Contro!
Equipment
The Huntington Power Plant comprises two pulverized coal-fired boilers.
2.2 Flue Gas Sampling Locations
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Location(s)
Sample location(s) are verified in the field to conform to EPA Method 1. Acceptable cyclonic
flow conditions are confirmed priorto testing using EPA Method 1, Section 11.4.
2.3 Operating Conditions and Process Data
Emission tests are performed while the source/units and air pollution control devices are
operating at the conditions required by the applicable regulation. The units are tested when
operating normally.
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
. Relevant CEMS data
GP043AS-0227 22-PP -7 7 6 Page 8 of 42
2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.1 Safety Responsibilities
Ptanning
. Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work
. W€ must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed
. The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
. Montrose will provide a list of equipment being brought to the site, if required
by the client
Project Day
. Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate
. Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits, The Client Sponsor and Operations Team are invited to
participate.
o Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection
. We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area
. As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms
GP043AS-0227 22-PP -7 7 6 Page 9 of 42
o Safe access to the platforms and test pofts, including any scaffolding or
man lifts
o Sufficient utilities to perform all necessary testing
. Montrose will use the client communication system, as directed, in case of
plant or project emergency
. Any adverse conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
. Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site
. Montrose will clean up our work area to the same condition as it was prior to
our arrival
. We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
. All regulatory required policies/procedures and training for OSHA, EPA,
FMCSA, and MSHA
. Medical monitoring, as necessary
. Use of Personal Protective Equipment (PPE) and chemical detection equipment
. Hazard communication
. Pre-test and daily toolbox meetings
. Continued evaluation of work and potential hazards
. Near-miss and incident repofting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees. The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix "S".
GP043AS-0227 22-PP -7 7 6 Page 10 of 42
3.0 Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Method 3OB
Determination of Total Vapor Phase Mercury Emissions from Coal-Fired
Combustion Sources Using Carbon Sorbent Traps
EPA Method 30B is a manual test method for measuring total vapor phase mercury (Hg)
emissions from coal-fired combustion sources using sorbent trap sampling and an extractive
or thermal analytical technique. The method includes sampling into duplicate sorbent traps,
which are analyzed using a sorbent trap mercury analyzer. This type of analyzer uses
thermal desorption with ultraviolet atomic absorption (UV AA) or ultraviolet atomic
fluorescent (UV AF) cold vapor analysis. Each trap consists of two equal-mass sections of
iodinated activated charcoal (Section 1 and 2). The results for Section 1 and Section 2 of
each tube are reported in nanograms (ng) of Hg per section, and then they are summed.
The charcoal sorbent is pre-checked to certify that mercury background levels are below the
detection limit of the laboratory instrument. Each trap is uniquely numbered, and the
sorbent batch number is printed on the outside of the glass tubes. One trap per run is pre-
spiked in the first sorbent section with a known quantity of elemental mercury, using a
proprietary gas-phase bulk spiking procedure. Each run includes two samples (A and B)
collected concurrently from a single representative sampling point in the exhaust stack
using a dual probe. Samples are drawn through the sorbent traps into a moisture knockout
loaded with desiccant, and then through a sampling orifice.
The typical sampling system is detailed in Figure 3-1.
GP043AS-0227 22-PP -7 7 6 Page 11 of 42
ibd I-Od
Figure 3-1
EPA Method 3OB Sampling Train
3.2 Process Test Methods
The applicable regulations do not require process samples to be collected during this test
program.
G P043AS-02 27 22-PP -7 7 6 Page L2 of 42
4.O Quality Assurance and Reporting
4.t QA Audits
Montrose has instituted a rigorous QA/QC program for its air quality testing. Quality
assurance audits are performed as part of the test program to ensure that the results are
calculated using the highest quality data available. This program ensures that the emissions
data we report are as accurate as possible. The procedures included in the cited reference
methods are followed during preparation, sampling, calibration, and analysis. Montrose is
responsible for preparation, calibration, and cleaning of the sampling apparatus. Montrose
will also peform the sampling, sample recovery, storage, and shipping. Approved contract
laboratories may peform some of the preparation and sample analyses, as needed.
4.2 Quality Control Procedures
Montrose calibrates and maintains equipment as required by the methods performed and
applicable regulatory guidance. Montrose follows internal procedures to prevent the use of
malfunctioning or inoperable equipment in test programs. All equipment is operated by
trained personnel. Any incidence of nonconforming work encountered during testing is
reported and addressed through the corrective action system.
4.2.t Equipment Inspection and Maintenance
Each piece of field equipment that requires calibration is assigned a unique identification
number to allow tracking of its calibration history. All field equipment is visually inspected
prior to testing and includes pre-test calibration checks as required by the test method or
regulatory agency.
4.2.2 Audit Samples
When required by the test method and available, Montrose obtains EPA TNI SSAS audit
samples from an accredited provider for analysis along with the samples. Currently, the
SSAS program has been suspended pending the availability of a second accredited audit
sample provider. If the program is reinstated, the audit samples will be ordered. If required
as part of the test program, the audit samples are stored, shipped, and analyzed along with
the emissions samples collected during the test program. The audit sample results are
reported along with the emissions sample results.
4.3 Data Analysis and Validation
Montrose converts the raw field, laboratory, and process data to repofting units consistent
with the permit or subpart. Calculations are made using proprietary computer spreadsheets
or data acquisition systems. One run of each test method is also verified using a separate
example calculation. The example calculations are checked against the spreadsheet results
and are included in the final report, The "Standard Conditions" for this project are 29.92
inches of mercury and 68 oF,
GP043AS-0227 22-PP -7 7 6 Page 13 of 42
4.4 Sample Identification and Custody
The on-site Field Project Manager will assume or assign the role of sample and data
custodian until relinquishing custody. The sample custodian will follow proper custody
procedures before depafting from the test site including:
. Assign the unique sample identification number to each sample
. Attach sample labels and integrity seals to all samples
. Complete COC form(s), ensuring that the sample identification numbers on
the samples match the sample identification numbers on the COC
. Pack and store samples in accordance with the test method requirements in
appropriate transport containers for protection from breakage, contamination,
or loss
. Keep samples in a secure locked area if not in the direct presence of Montrose
staff
The sample custodian will follow proper custody procedures upon arriving at the Montrose
office including:
. Remove samples and COC documents from vehicles and check into
designated secure sample holding areas
. Store samples requiring additional measures such as refrigeration or dry ice
appropriately
4.5 Quality Statement
Montrose is qualified to conduct this test program and has established a quality
management system that led to accreditation with ASTM Standard D7036-04 (Standard
Practice for Competence of Air Emission Testing Bodies). Montrose participates in annual
functional assessments for conformance with D7036-04 which are conducted by the
American Association for Laboratory Accreditation (A2LA). All testing performed by Montrose
is superuised on site by at least one Qualified Individual (QI) as defined in D7036-04
Section 8.3.2. Data quality objectives for estimating measurement uncertainty within the
documented limits in the test methods are met by using approved test protocols for each
project as defined in D7036-04 Sections 7.2.1 and l2.LO. Additional quality assurance
information is included in the appendices. The content of this test plan is modeled after the
EPA Emission Measurement Center Guideline Document (GD-042).
4.6 Repofting
Montrose will prepare a final report to present the test data, calculations/equations,
descriptions, and results. Prior to release by Montrose, each report is reviewed and certified
by the project manager and their supervisor, or a peer. Source test reports will be
submitted to the facility or appropriate regulatory agenry (upon customer approval) within
GP043AS-0227 22-PP -7 7 6 Page L4 of 42
25 days of the completion of the field work. The repoft will include a series of appendices to
present copies of the intermediate calculations and example calculations, raw field data,
laboratory analysis data, process data, and equipment calibration data.
4.6.L Example Report Format
The report is divided into various sections describing the different aspects of the source
testing program. Figure 4-1 presents a typical Table of Contents for the final report.
Figure 4-1
Typical Repoft Format
Cover Page
Ceftification of Report
Table of Contents
1.0 Introduction
2.O Plant and Sampling Location Descriptions
3.0 Sampling and Analytical Procedures
.0 Test Discussion and Results
5.0 Internal QA/QC Activities
Appendices
A Field Data and Calculations
B Facility Process Data
C Laboratory Analysis Data
D Quality Assurance/Quality Control
E Regulatory Information
GP043AS-0227 22-PP -7 7 6 Page 15 of 42
4.6.2 Example Presentation of Test Results
Table 4-1 presents the typical tabular format that is used to summarize the results in the
final source test report. Separate tables will outline the results for each target analyte and
compare them to their respective emissions limits.
Table 4-l
Example <Parameter> Emissions Results -
Unit Name
Date XX xx XX XX
Time xx xx xx xx
Process Data
parameter 1, units xx xx XX xx
parameter 2, units xx xx xx xx
Sampling & Flue Gas Parameterc
sample duration, minutes xx xx xx xx
Oz, o/o volume dry xx xx XX xx
COz, o/o volume dry XX XX xx xx
flue gas temperature, oF xx xx xx xx
moisture content, o/o volume xx xx XX XX
volumetric flow rate, dscfm XX xx XX xx
<Parameter>
ppmvd xx XX xx xx
ppmvd @ 15o/o Oz xx xx xx XX
tb/hr XX xx xx XX
tons/yr xx xx xx XX
lb/MMBtu xx xx xx xx
GPO4 3AS-0227 22-PP -7 7 6 Page 16 of 42
Appendix A
Supporting Information
GPO43AS-0227 22-PP -7 7 6 Page t7 ot 42
Appendix A.1
Units and Abbreviations
6(i) ltgN,T+gp.H
UNITS AND ABBREVIATIONS
@XYo 02 corrected to X% oxygen (corrected for dilution air)
lCCl absolute value of the confidence coefficient
ldl absolute value of the mean differencesoC degrees CelsiusoF degrees FahrenheitoR degrees Rankine
" HzO inches of water column
13.6 specific gravity of mercury
AH pressure drop across orifice meter, inches H2O
AP velocity head of stack gas, inches H2O
e total sampling time, minutes
us microgram
pa density of acetone, mg/ml
P* densi$ of water, 0.9982 g/ml or 0.002201 lb/ml
acfm actual cubic feet of gas per minute at stack conditions
An cross-sectional area of nozzle, f(
As cross-sectional area of stack, square feet (#)
Btu British thermal unit
B*. proportion by volume of water vapor in gas stream
C" particulate matter concentration in stack gas, gr/acf
Cnus average unadjusted gas concentration, ppmv
Coi, measured concentration of calibration gas, ppmv
cf or ft3 cubic feet
cfm cubic feet per minute
Cc.. average gas concentration adjusted for bias, ppmv
CM average of initial and final system bias check responses from upscale calibration gas, ppmv
cm or mt cubic meters
Crua actual concentration of the upscale calibration gas, ppmv
Co average of initial and final system bias check responses from low-level calibration gas, ppmv
Cp pitot tube coefficient
C. particulate matter concentration in stack gas, gr/dscf
CS calibration span, % or ppmv
Cs measured concentration of calibration gas, ppmv
Cv manufactured cedified concentration of calibration gas, ppmv
D drift assessment, % of span
dcf dry cubic feet
dcm dry cubic meters
Dn diameter of nozzle, inches
Ds diameter of stack, inches
dscf dry standard cubic feet
dscfm dry standard cubic feet per minute
dscm dry standard cubic meters
Fd F-factor, dscf/MMBtu of heat input
fpm feet per minute
fps feet per second
ft feet
# square feetg gram
gal gallons
gr grains (7000 grains per pound)
gr/dscf grains per dry standard cubic feet
hour
GP0434S-0227 22-PP -7 7 6 Page L9 of 42
6(\ mqN,I+gp.E
UNITS AND ABBREVIATIONS
I percent of isokinetic samPling
in inch
k kilo or thousand (metric units, multiply by 103;
K kelvin (temPerature)
K3 conversion factor 0.0154 gr/mg
1& conversion factor 0.002668 ((in. HgXft"))/((mlX"R))
kg kilogram
& pitot tube constant (85.49 fUsec)
kwscfh thousand wet standard cubic feet per hour
I liters
lb/hr pounds per hour
lb/MMBtu pounds Per million Btu
lpm liters Per minute
m meter or milli
M thousand (English units) or mega (million, metric units)
mt cubic meters
ma mass of residue of acetone after evaporation, mg
M6 molecular weight of stack gas; dry basis, lb/lb-mole
meq milliequivalent
mg milligram
Mg megagram (106 grams)
min minute
ml or mL milliliter
mm millimeter
MM million (English units)
MMBtu/hr million Btu Per hour
mn total amount of particulate matter collected, mg
mol mole
mol. wt. or MW molecular weight
Ms molecular weight of stack gas; wet basis, lb/lb-mole
MW molecular weight or megawatt
n number of data Pointsng nanogram
nm nanometer
Po", barometric Pressure, inches Hg
pS picogram
Pe stack static pressure, inches H2O
Pm barometric pressure of dry gas meter, inches Hg
ppb parts Per billion
ppbv parts Per billion, bY volume
ppbvd parts per billion by volume, dry basis
ppm parts per million
ppmv parts per million, bY volume
ppmvd parts per million by volume, dry basis
ppmvw parts per million by volume, wet basis
Ps absolute stack gas pressure, inches Hg
psi pounds Per square inch
psia pounds per square inch absolute
psig pounds Per square inch gauge
Psro standard absolute pressure, 29.92 inches Hg
Q" volumetric flow rate, actual conditions, acfin
Q. volumetric flow rate, standard conditions, scfrn
Q.,o volumetric flow rate, dry standard conditions, dscfrn
R ideal gas constant 21.85 ((in. Hg) (ft3)y(('R) (lbmole))
G P043AS-0227 22-PP -7 7 6 Page 2O of 42
66 l,l?N,T+gp.E
UNITS AND ABBREVIATIONS
SBtinar post-run system bias check, % of span
SBi pre-run system bias check, % of span
scf standard cubic feet
scfh standard cubic feet per hour
scfrn standard cubic feet per minute
scm standard cubic meters
scmh standard cubic meters per hour
sec second
sf, sq. ft., or f square feet
std standard
t metric ton (1000 kg)
T o.szs t-value
Ta absolute average ambient temperature, "R (+459.67 for English)
Tm absolute average dry gas meter temperature, oR (+459.67 for English)
ton ort ton = 2000 pounds
tph or tons/hr tons per hour
tpy or tons/yr tons per year
Ts absolute average stack gas meter temperature, oR (+459.67 for English)
Tsto absolute temperature at standard conditions
V volt
Va volume of acetone blank, ml
V"* volume of acetone used in wash, ml
V6 total volume H2O collected in impingers and silica gel, grams
Vm volume of gas sampled through dry gas meter, ft'
Vm(srd) volume of gas measured by the dry gas meter, corrected to standard conditions, dscf
Vma stack gas volume sampled, acf
Vn volume collected at stack conditions through nozzle, acl
Vs average stack gas velocity, feet per second
Vwclstal volume of water vapor condensed, corrected to standard conditions, scf
V*(sto) volume of water vapor in gas sampled from impingers, scf
Vwsg(srd) volume of water vapor in gas sampled from silica gel, scf
W watt
Wa weight of residue in acetone wash, mg
Wrp total weight of imPingers, grams
Wss total weight of silica gel, grams
Y dry gas meter calibration factor, dimensionless
G P043AS-0227 22-PP -7 7 6 Page 2L of 42
6(\ l,l?N,T+gLH
AAS
ACDP
ACE
AD
ADL
AETB
AS
ASTM
BACT
BDL
BHP
BIF
BLS
cc
CD
CE
CEM
CEMS
CERMS
CET
CFR
CGA
CHNOS
CNCG
CO
coc
COMS
CPM
CPMS
CT
CTM
cro
CVAAS
De
DE
Dioxins
DLL
DNCG
ECD
EIT
ELCD
EMPC
EPA
EPRI
ES
ESP
EU
FCCU
FGD
FI
FIA
FID
FPD
FPM
FTIR
FTPB
FTRB
Furans
GC
ACRONYMS
atomic absorption spectroscopy
air contaminant discharge permit
analyzer calibration error, percent of span
absolute difference
above detection limit
Air Emissions Testing Body
applicable standard (emission limit)
American Society For Testing And Materials
best achievable control technology
below detection limit
brake horsepower
boiler and industrial furnace
black liquor solids
confidence coefficient
calibration drift
calibration error
continuous emissions monitor
continuous emissions monitoring system
continuous emissions rate monitoring system
calibration error test
Code of Federal Regulations
cylinder gas audit
elemental analysis for determination of C, H, N, O, and S content in fuels
concentrated non-condensable gas
catalytic oxidizer
chain of custody
continuous opacity monitoring system
condensible particulate matter
continuous parameter monitoring system
combustion turbine
conditional test method
catalytic thermal oxidizer
cold vapor atomic absorption spectroscopy
equivalent diameter
destruction efficiency
polychlorinated dibenzo-p{ioxins (pcdd's)
detection level limited
dilute non-condensable gas
electron capture detector
Engineer ln Training
electoconductivity detector (hall detector)
estimated maximum possible concentration
US Environmental Protection Agency
Electric Power Research lnstitute
emission standard (applicable limit)
electrostatic precipitator
emission unit
fluid catalytic cracking unit
fl ue gas desulfurization
flame ionization
flame ionization analyzer
flame ionization detector
fl ame photometric detector
fi lterable particulate matter
Fourier-transform infrared spectroscopy
field train proof blank
field train recovery blank
polychlorinated dibenzofurans (pcdf s)
gas chromatography
G P04 3AS -02 27 22-PP -7 7 6 Page 22 of 42
66 l,l?N,r+gp.E
ACRONYMS
GC/MS gas chromatography/mass spectroscopy
GFAAS graphite furnace atomic absorption spectroscopy
GFC gas filter correlation
GHG greenhouse gas
HAP hazardous air pollutant
HC hydrocarbons
HHV higher heating value
HPLC high performance liquid chromatography
HRGC/HRMS high-resolution gas chromatography/high-resolution mass spectroscopy
HRSG heat recovery steam generator
lC ion chromatography
ICAP inductively-coupled argon plasmography
ICPCR ion chromatography with a post-column reactor
ICP-MS inductively coupled plasma-mass spectroscopy
lR infrared radiation
ISO lnternational Standards Organization
kW kilowatts
LFG landfill gas
LHV lower heating value
LPG liquified petroleum gas
MACT maximum achievable control technology
MDI methylene diphyenyl diisocyanate
MDL method detection limit
MNOC maximum normal operating conditions
MRL method reporting limit
MS mass spectrometry
NA not applicable or not available
NCASI National Council For Air And Steam lmprovement
NCG non-condensable gases
ND not detected
NDIR nondispersive infrared
NESHAP National Emissions Standards For Hazardous Air Pollutants
NG natural gas
NIOSH National lnstitute For Occupational Safety And Health
NIST National lnstitute Of Standards And Technology
NMC non-methane cutter
NMOC non-methane organic compounds
NMVOC non-methane volatile organic compounds
NPD nitrogen phosphorus detector
NSPS New Source Performance Standards
OSHA Occupational Safety And Health Administration
PAH polycyclic aromatic hydrocarbons
PCB polychlorinated biphenyl compounds
PCWP plywood and composite wood products
PE Professional Engineer
PFAS per- and polyfluoroalkyl substances (PFAS)
Pl photoionization
PID photoionization detector
PM particulate matter
PM,o particulate matter less than 10 microns in aerodynamic diameter
PMr.u particulate matter less than 2.5 microns in aerodynamic diameter
POM polycyclic organic matter
PS performance specification
PSD particle size distribution
PSEL plant site emission limits
PST performance specification test
PTE permanent total enclosure
PTM performance test method
G P043AS-0227 22-PP -7 7 6 Page 23 of 42
Yr*sJflF.p"s"r
Huntington Power Plant
6 miles west of Huntington, Utah on Hwy. 3l
P.O. Box 680
Huntington, Utah 84528
January 16,2024
UTAH DEPARTMENT OF
ENVIRONMENTAL QUALITY
,t1li ? I ?A?4
DIVISION OF AIR OUALITY
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
P.O. Box 144820
Salt Lake City, UT 84114-4820
Attn: Rob Leishman
RE: Notification for PacifiCorp Energy's Huntington Plant to Conduct Particulate Matter
Testing on Units l and2
Dear Mr. Bird:
On April 3,2018, the Huntington Power Plant's Units 1 and 2 were granted MATS PM LEE status and
authorized to reduce MATS PM testing to once every 36 months in accordance with 40 CFR 63.10006(b).
This letter is to inform you that the MATS PM LEE demonstration tests are scheduled for Huntington Units
1 and2 on March 19 & 20, 2024.The testing will be conducted according to 40 CFR Part 63, Subpart
UUUUU.
The Huntington plant has also scheduled the annual particulate matter testing on Units 1 and 2. Annual
PM testing will be conducted in accordance with the Title V Operating Permit No. 1 50100't005. The
testing is scheduled to run in conjunction with the MATS PM LEE testing and will be conducted on the
same days.
I have enclosed the testing protocol that will be used by the stack testing team (Montrose) for your review.
Shown below is the testing schedule.
Note: Test times are approximate and subject to change.
Should you have any questions regarding this testing schedule, please do not hesitate to call Mr. Terry
Guthrie at (435) 7486059 or myself at [phone].
Date Unit Test Time Activitv MWo MWn
3t18t2024 1 15:00 Set up N/A N/A
3t19t2024 1 06:00 - 18:00 Particulate
Matter Testino
408-520
(>468)>442
3t20t2024 2 06:00 - 18:00 Particulate
Matter Testinq
401-510
(>459)>430
Laren Huntsman
Managing Dircctor Hunter and Huntington
Responsible Official
Enclosures
cc: Youn Joo Kim - EPA Region Vlll
Tom Wiscomb - NTO 210 Wenclosure
Terry Guthrie - Hunter and Huntington Plant Wenclosure
Scarlet Lewis - NTO 210 Wenclosure
Russ Wllson - Huntington Plantdenclosure
Source Test Plan for
Annual 2O24 Compliance Testing
Unitl&Unit2
PacifiCorp
Huntington Power Plant
Huntington, Utah
Prepared For:
PacifiCorp
t407 W North Temple, Suite 210
Salt Lake City, Utah 84116
Prepared By:
Montrose Air Quality Services, LLC
990 West 43rd Avenue
Denver, CO 80211
For Submission To:
Utah Division of Air Quality
195 North 1950 West
Salt Lake City, UT 84116
Docu ment N umber: G PO43AS-O227 22-PP -77 5
Proposed Test Dates: March 19 & zOt 2024
Submittal Date: February tgt 2024
1=IH DEPARIMENT oF
r r.rvi i o ry H,tgU+,gUUlv
DIVISION OF AIR OUALITY
.J,1il 2 ,1 20)-A
smeffiM $?,NT+R[T sffiorsSYG.mol
I certify that, to the best of my knowledge, the information contained in this document is
complete and accurate and conforms to the requirements of the Montrose Quality
Date:LzlL/2O23
Name: Matthew Parks Title:QA/QC Analyst
I have reviewed, technically and editorially, details and other appropriate written materials
contained herein. I hereby ceftify that to the best of my knowledge the presented material
is authentic and accurate and conforms to the requirements of the Montrose Quality
Management System and ASTM D7036-04.
Signature:
Name:
Date:
Title:
L2/Ll2023
Account Manager
GP043AS-0227 22-PP -7 7 5 Page 2 of 43
Table of Contents
Paqe
1.0 Introduction ........ ................ 5
1.1 Summary of Test Program .............5
t.2 Applicable Regulations and Emission Limits... ...................6
1.3 Key Personnel........... ...................7
2.0 Plant and Sampling Location Descriptions.............. ..................9
2.L Process Description, Operation, and Control Equipment............. ,.......9
2.2 Flue Gas Sampling Locations.. ........9
2.3 Operating Conditions and Process Data ...........9
2.4 Plant Safety ..........,.. ................,, 10
2.4.1 Safety Responsibilities...... ..........,.......10
2.4.2 Safety Program and Requirements....... ................11
3.0 Sampling and Analytical Procedures .....t2
3.1 Test Methods,........... .................t2
3.1,1 EPA Methods 5 and 2O2 ......... ..............12
3.2 Process Test Methods.....,....,. ......13
4.0 Quality Assurance and Reporting........... ...............14
4.1 QA Audits .....L4
4.2 Quality Control Procedures ..........L4
4.2.1 Equipment Inspection and Maintenance.............. ..,............,..14
4.2.2 Audit Samples ............... 14
4.3 Data Analysis and Validation ........,.......14
4.4 Sample Identification and Custody.... ,..,.......,15
4.5 Quali$ Statement ..,..,..,....15
4.6 Reporting ..................15
4.6.1 Example Repoft Format ..........16
4.6.2 Example Presentation of Test Resu|ts.............. ............L7
List of Appendices
Appendix A Suppofting Information.......... ,................ 18
Appendix A.1 Units and Abbreviations....., ............19
Appendix A.2 Accreditation Information/Certifications............ ................27
Appendix "S" Field Work Safety P1an.......... ....29
List of Tables
Table 1-1 Summary of Test Program and Proposed Schedule... .......5
Proposed Test Date .......,..,....,5
GP043AS-0227 22-PP -7 7 5 Page 3 of 43
Table 1-2 Reporting Units and Emission Limits ..............6
Table 1-3 Test Personnel and Responsibilities ..........."..8
Table 2-1 Sampling Location(s).......... .........9
Table 4-1 Example <Parameter> Emissions Results - Unit Name....... .......,....L7
List of Figures
Figure 3-1 EPA Methods 5 and 202 Sampling Train ....... 13
Figure 4-1 Typical Report Format ..............16
GP043AS-0227 22-PP -77 5 Page 4 of 43
1.O Introduction
1.1 Summary of Test Program
PacifiCorp contracted Montrose Air Quality Services, LLC (Montrose) to perform an
emissidns test program at the Huntington Power Plant located in Huntington, Utah. The
tests are conducted to determine compliance with the applicable UDEQ permit.
The specific objectives are to:
. Perform annual Particulate Matter (PM) emissions testing on the exhaust
stacks of Unit 1 and Unit 2.
. Perform diagnostic Condensable Particulate Matter (CPM) emissions testing
on the exhaust stacks of Unit 1 and Unit 2.
. Conduct the test program with a focus on safety
Montrose will provide the test personnel and the necessary equipment to measure emissions
as outlined in this test plan. Facility personnel will provide the process and production data
to be included in the final report. A summary of the test program and proposed schedule is
presented in Table 1-1.
Table 1-l
Summary of Test Program and Proposed Schedule
G P043AS-0227 22-PP -7 7 5 Page 5 of 43
To simplify this test plan, a list of Units and Abbreviations is included in Appendix A.
Throughout this test plan, chemical nomenclature, acronyms, and reporting units are not
defined. Please refer to the list for specific details.
L.2 Applicable Regulations and Emission Limits
The results from this test program are presented in units consistent with those listed in the
applicable regulations or requirements. The reporting units and emission limits are
presented in Table 1-2.
Table 1-2
Repofting Units and Emission Limits
40 CFR Part 63, Subpart UUUUU
UDEQ Operating Permit 1501001004
UDEQ Operating Permit 1501001004
xNote: The Unit 1 emission limit references PM10. However, PM10 sampling cannot be performed on the stack
due to the presence of water droplets. The total PM concentration is used to show compliance with the PM10
limit.
GP043AS-0227 22-PP -7 7 5 Page 6 of 43
1.3 Key Personnel
A list of project participants is included below:
Facility Information
Source Location:PacifiCorp
Huntington Plant
8 Miles West of Huntington on Hwy
Huntington, Utah 84528
Tom Wiscomb
Sr. Environmental Advisor
PacifiCorp
[phone]
Tom. Wiscom b@ pacificorp. com
Utah Department of Air Quality
Rob Leishman
(801) s36-4438
[e-mail]
Project Contact:
Role:
Company:
Telephone:
Email:
Agency Information
Regulatory Agency:
Agenry Contact:
Telephone:
Email:
Testing Gompany Information
Testing Firm: Montrose Air Quality Services, LLC
Contact: Craig Kormylo
Title: District Manager
Telephone: [phone]
Email: [e-mail]
31
Russell Willson
Senior Environmental Analyst
PacifiCorp
(43s) 687-433t
Russel l. Wi I lson@ Pacifi Corp. com
GP043AS-0227 22-PP -7 7 5 Page 7 of 43
Table 1-3 details the roles and responsibilities of the test team.
Table 1-3
Test Personnel and Responsibillties
Facility interface, test crew coordinationField Project Manager
Preparation, support PM
G P043AS-0227 22-PP -7 7 5 Page 8 of 43
2.O Plant and Sampling Location Descriptions
2.L Process Description, Operation, and Control
Equipment
The Huntington Power Plant comprises two pulverized coal-fired boilers.
2.2 Flue Gas Sampling Locations
Actual stack measurements, number of traverse points, and location of traverse points will
be evaluated in the field as part of the test program. Table 2-1 presents the anticipated
stack measurements and traverse points for the sampling locations listed.
Table 2-1
Sampling Location(s)
Sample location(s) are verifled in the field to conform to EPA Method 1. Acceptable ryclonic
flow conditions are confirmed prior to testing using EPA Method 1, Section 11.4.
2.3 Operating Conditions and Process Data
Emission tests are performed while the source/units and air pollution control devices are
operating at the conditions required by the applicable regulation. The units are tested when
operating normally.
Plant personnel are responsible for establishing the test conditions and collecting all
applicable unit-operating data. Data collected includes the following parameters:
. Unit load (MW)
. Relevant CEMS data
GP043AS-0227 22-PP -7 7 5 Page 9 of 43
2.4 Plant Safety
Montrose will comply with all safety requirements at the facility. The facility Client Sponsor,
or designated point of contact, is responsible for ensuring routine compliance with plant
entry, health, and safety requirements. The Client Sponsor has the authority to impose or
waive facility restrictions. The Montrose test team leader has the authority to negotiate any
deviations from the facility restrictions with the Client Sponsor. Any deviations must be
documented.
2.4.L Safety Responsibilities
Planning
. Montrose must complete a field review with the Client Sponsor prior to the
project date. The purpose of the review is to develop a scope of work that
identifies the conditions, equipment, methods, and physical locations that will
be utilized along with any policies or procedures that will affect our work
. We must reach an agreement on the proper use of client emergency services
and ensure that proper response personnel are available, as needed
. The potential for chemical exposure and actions to be taken in case of
exposure must be communicated to Montrose. This information must include
expected concentrations of the chemicals and the equipment used to identify
the substances.
. Montrose will provide a list of equipment being brought to the site, if required
by the client
Project Day
. Montrose personnel will arrive with the appropriate training and credentials
for the activities they will be performing and the equipment that they will
operate
. Our team will meet daily to review the Project Scope, Job Hazard Assessment,
and Work Permits. The Client Sponsor and Operations Team are invited to
participate.
. Montrose will provide equipment that can interface with the client utilities
previously identified in the planning phase and only work with equipment that
our client has made ready and prepared for connection
. We will follow client direction regarding driving safety, safe work permitting,
staging of equipment, and other crafts or work in the area
. As per 40 CFR Part 60 Subpart A, Section 60.8, the facility must provide the
following provisions at each sample location:
o Sampling ports, which meet EPA minimum requirements for testing. The
caps should be removed or be hand-tight.
o Safe sampling platforms
GP043AS-0227 22-PP -7 7 5 Page 10 of 43
o Safe access to the platforms and test ports, including any scaffolding or
man lifts
o Sufficient utilities to perform all necessary testing
. Montrose will use the client communication system, as directed, in case of
plant or project emergency
. Any adverce conditions, unplanned shutdowns or other deviations to the
agreed scope and project plan must be reviewed with the Client Sponsor prior
to continuing work. This will include any safe work permit and hazard
assessment updates.
Completion
. Montrose personnel will report any process concerns, incidents or near misses
to the Client Sponsor prior to leaving the site
. Montrose will clean up our work area to the same condition as it was prior to
our arrival
. We will ensure that all utilities, connection points or equipment have been
returned to the pre-project condition or as stated in the safe work permit. In
addition, we will walk out the job completion with Operations and the Client
Sponsor if required by the facility.
2.4.2 Safety Program and Requirements
Montrose has a comprehensive health and safety program that satisfies State and Federal
OSHA requirements. The program includes an Illness and Injury Prevention Program, site-
specific safety meetings, and training in safety awareness and procedures. The basic
elements include:
. All regulatory required policies/procedures and training for OSHA, EPA,
FMCSA, and MSHA
. Medical monitoring, as necessary
. Use of Personal Protective Equipment (PPE) and chemical detection equipment
. Hazard communication
. Pre-test and daily toolbox meetings
. Continued evaluation of work and potential hazards
. Near-miss and incident repofting procedures as required by Montrose and the
Client
Montrose will provide standard PPE to employees, The PPE will include but is not limited to;
hard hats, safety shoes, glasses with side shields or goggles, hearing protection, hand
protections, and fall protection. In addition, our trailers are equipped with four gas detectors
to ensure that workspace has no unexpected equipment leaks or other ambient hazards.
The detailed Site Safety Plan for this project is attached to this test plan in Appendix "S".
G P043AS-0227 22-PP -7 7 5 Page 11 of 43
3,O Sampling and Analytical Procedures
3.1 Test Methods
The test methods for this test program have been presented in Table 1-1. Additional
information regarding specific applications or modifications to standard procedures is
presented below.
3.1.1 EPA Methods 5 and 2O2
Determination of Particulate Matter from Stationary Sources and Dry
Impinger Method for Determining Condensable Particulate Emissions from
Stationary Sources
EPA Methods 5 and 2O2are manual, isokinetic methods used to measure FPM and CPM
emissions. The methods are performed in conjunction with EPA Methods 1 through 4. The
stack gas is sampled through a nozzle, probe, heated filter, unheated CPM filter, condenser,
and impinger train. FPM is collected from the probe and heater filter, CPM is collected from
the unheated CPM filter and the impinger train. The samples are analyzed gravimetrically.
The sum of FPM and CPM represents TPM. The FPM, CPM, and TPM results are reported in
emission concentration and emission rate units.
Petinent information regarding the performance of the method is presented below:
o Condensed water is measured gravimetrically
o The post-test nitrogen purge is performed by passing nitrogen through the
train under pressure
o To simplify shipping arrangements to remote locations, stainless steel
probe liners and nozzles are used. Aftereach run, the nozzle and probe
liner are brushed and washed a total of six times with reagent-grade
acetone to assure complete recovery of all particulate matter, The brush is
given a final rinse with acetone and the nozzle and probe liner are given a
final rinse with acetone and all rinsate is collected into the appropriate
sample container
The typical sampling system is detailed in Figure 3-1.
GP043AS-0227 22-PP -7 7 5 Page 12 of 43