DAQ-2024-004487

Yr*sHF"g."n.r
Huntington Power Plant
8 miles west of Huntington, Utah on Hwy. jl
P.O. Box 680
Huntington, utqh 84528
January 22,2024
Mr. Bryce Bird, Director
Utah Department of Environmental Quality
Division of Air Quality
195 North 1950 West
P.O. Box'144820
Salt Lake City, UT 84114-4820
And
Director, USEPA Region Vlll
8 ENF-AT
1595 \Afinkoop St.
Denver, CO 80202-1129
UTAH DEPAETMENT OF
ETWTRONMEMTAL OUruTY
JAN 2:l 2,,;;,,
DIVISION OF AIR QUALTTY
RE: Semiannua! Compliance Report,40 CFR 63 Subpart UUUUU, Huntington Power Ptant (Title
V Permit #1501001005) Boiler Unit 2
Dear Mr. Bird:
Huntington Power Plant's Title V Permit Conditions 11.B.2.9.3 and 11.B.3.f.3 require the Huntington Plant
submit Compliance Reports according to the requirements of 40 CFR 563.10031(b). This submittal
covers the period from July 1,2023, to December 31 , 2023, and is intended to satisff those requirements.
I am authorized to make this submission on behalf of the owners and operators of the affected source or
affected units for which the submission is made. I certify under penalty of law that I have personally
examined, and am familiar with, the statements and information submitted in this document and all its
attachments. Based on my inquiry of those individuals with primary responsibility for obtaining the
information, I certiff that the statements and information are to the best of my knowledge and belief true,
accurate, and complete. I am aware that there are significant penalties for submitting false statements
and information, or omitting statements and information, including the possibility of fine or imprisonment.
Should you any questions regarding this information, please contact Terry Guthrie, Hunter and
H I Manager (435) 6874334 or me at (435) 6874211.
Managing Director Hunter and Huntington Plant
Responsible Official
REVIEWED
Initials JBR Date 2/6/2024
Comp Status Meets
File # 10238 Blue 2
limits below allowed.
Enclosures: Mercury and Air Toxics Semiannual Compliance Report with aftachments A thru C - Unit 2
cc: Youn Joo Kim - USEPA Region VlllWenclosure
Josh Sewell- NTO w/o enclosure
Scarlet Jackson - NTO Wo enelosure
Russ \Mllson - Huntington Plant - Files
L'TAH T'EPARTMEIIT OF
ENVIRONMENTAI- QUAUTY
Mercury and Air Toxics Semi-Annual Compliance Report I 'i
Huntington Power Plant Unit 2
Reporting Period July l, 2023 to December 31,2023 lt\.i iS;iON OF AIR qUALIT\"
$63.100031(c)
The compliance report must contain the information required in paragraphs (c)(1) through (5) of this
section.
563.1003 l(c)(l)
The information required by the summary report located in 63.10(e)(3)(vi).
I. See Attachment A Summary Report-Gaseous Excess Emission and Continuous Monitoring
System Performance
$63.1 003 1(c)(2)
The total fuel use by each affected source subject to an emission limit, for each calendar month within
the semiannual reporting period, including, but not limited to, a description of the fuel, whether the
fuel has received a non-waste determination by EPA or your basis for concluding that the fuel is not a
waste, and the total fuel usage amount with units of measure.
Month #2 Fuel OiI Burned (gallons)Bituminous Coal Burned (tons)
Julv 2023 50.075 72.t16
August 2.581 118.012
September I 1.785 54.051
October 35.557 21.371
November 20.439 46.st3
December 5.247 3s.167
Total 12s.684 347,230
Note: Fuel Oil burned is a product of refineries and the coal burned is a product of coal
mines therefore all fuel bumed was not a waste product.
$63.1003 l(c)(3)
Indicate whether you burned new types of fuel during the reporting period. If you did burn new
types of fuel you must include the date of the perforrnance test where that fuel was in use.
I. No new types of fuel were burned during the reporting period.
$63.1003 l(cXa)
Include the date of the most recent tune-up for each EGU. The date of the tune-up is the date the
tune-up provisions specified in $ 63.10021(e)(6) and (7) were completed.
I. The most recent boiler tune up was completed on December 4,2023 with the burner
inspection occurring as part ofthe tune-up.
$63.10031(c)(s)
Should you choose to rely on paragragh (2) ofthe definition of"startup" in 963.I0042 for your
EGU, for each instance of startup or shutdown you shall:
I. The Unit relies on paragraph (1) of the definition of "startup." Therefore, no startups or
shutdowns in the current semi-annual reporting period are subject to this requirement.
$63.1 003 1(c)(6)
You must report emergency bypass information annually from EGUs with LEE status.
I. No emergency bypass occurred during the reporting period.
$63.10031(cX7)
A summary of the results of the annual performance tests and documentation of any operating
limits that were reestablished during the test, if applicable. If you are conducting stack tests once
every 3 years to maintain LEE status, consistent with $ 63.10006(b), the date of each stack test
conducted during the previous 3 years, a comparison of emission level you achieved in each stack
test conducted during the previous 3 years to the 50 percent emission limit threshold required in $
63. 10005(h)( l Xi), and a statement as to whether there have been any operational changes since
the last stack test that could increase emissions.
I. Unit 2 Annual Mercury LEE tests - summary results (lbs Hg/Tbtu)
Test Completion
Date
Mercury LEE
Threshold
Actual Test
Result
71612021 0.t2 0.01
61712022 0.t2 0.01
412412023 0.t2 0.003
The Huntington Plant completed a three (3) consecutive year, quarterly PM testing period
to quality Unit2 as a PM Low Emitting EGU. Reference Method 5 was performed in
accordance with $63.10005(hX1Xi) to demonstrate PM emissions were less than fifty
(50) percent of the applicable emission limit, 0.030 lb/N4MBtu. The corresponding
threshold for a LEE unit (50% of the applicable emission limit) is 0.015 lb/MMBtu.The
test results show an average PM emission rate over the 3-year period of 0.005 lb/MMBtu,
which qualifies Unit 2 as a LEE. The performance test was repeated every three years as
required demonstrating continued LEE status as indicated by test results below.
A summary report of the test results for the tree (3) year period is listed below:
Huntineton 2 PM LEE Test Summarry
Test ID Test Date Average PM
0b/mmBtu)
LEE Threshold
Q220ts 5lt3-
14120t5
0.007
0.015lb/mmBtu
03 2015 8lt2l20ts 0.007
04 2015 t21161201s 0.008
o-12016 2lt0/2016 0.00s
022016 5lt0/2016 0.007
03 2016 8t24t2016 0.002
04 20t6 tt/0912016 0.003
II.
o-12017 2/08t20r7 0.006
o22017 s/09t2017 0.003
03 2017 9/19/2017 0.008
04 2017 t2t06/20t7 0.00s
ol 20r8 2t7t20t8 0.00s
36 Month Averase 0.006
PacifiCorp
Huntington Unit2
PM Low Emittine EGU GEE) Subsequent Test Results
Test II)Test Date Average PM
flb/mmBtu)
MATS PM
Limit
MATS PM
LEE Limit
o12021 3n0t2021 0.008 0.030 0.015
$63.10031(cX8)
A certification.
I. A signed certification by a Responsible Official is included in the cover letter of this
submittal.
$63.1 003 1(c)(e)
If you have a deviation from any emission limit, work practice standard, or operating limit, you
must also submit a brief description of the deviation, the duration of the deviation, emissions
point identification, and the cause of the deviation.
I. Any Deviations to emissions limits are identified in Attachment C Excess
Emission Report
II. Any Deviations to monitoring system malfunctions, monitoring system out-of
control periods, or repairs associated with monitoring system malfunctions or
monitoring system out-of-control periods are identified in Attachment B CEMS
Monitor Outage Report
IIL There are no operating limits associated with compliance to the Mercury and Air
Toxics Standards for this Unit.
IV. There were no deviations related to the Work Practice Standard related to Boiler
Tune Up requirements.
V. CMS were in service during allphases of operation including startup according
to the required Work Practice Standard except for periods identified in
Attachment B CEMS Monitor Outage Report.
VL Clean fuel was burned during each startup as required by the Work Practice
Standard.
$63.10031(c)(10)
If you had any process or control equipment malfunction(s) during the reporting period, you must
include the number, duration, and a brief description for each type of malfunction which occurred
during the semiannual reporting period which caused or may have caused any applicable
emission limitation to be exceeded.
I. Malfunctions during the reporting period are identified in Attachment C Excess
Emissions Report
s63.1003 l(d)
Excess emissions and deviation reporting. For EGUs whose owners or operators rely on a CMS to
comply with an emissions or operating limit, the semiannual compliance reports described in
paragraph (c) of this section must include the excess emissions and monitor downtime summary
report described in 40 CFR 63.10(e)(3)(vi). However, starting with the first calendar quarter of
2024,reporting of the information under 40 CFR 63.1O(eX3Xvi) (and under paragraph (eX3)(v),
if the applicable excess emissions and/or monitor downtime threshold is exceeded) is
discontinued for all CMS, and you must, instead, include in the quarterly compliance reports
described in paragraph (g) of this section the applicable data elements in section l3 of appendix E
to this subpart for any "deviation" (as defined in 40 CFR 63.10042 and elsewhere in this subpart)
that occurred during the calendar quarter. If there were no deviations, you must include a
statement to that effect in the quarterly compliance report.
$63. I 0(e)(3)(v)
All excess emissions and monitoring system performance reports and all summary
reports, if required, shall be delivered or postmarked by the 30th day following the end of
each calendar half or quarter, as appropriate. Written reports of excess emissions or
exceedances of process or control system parameters shall include all the information
required in paragraphs (c)(5) through (c)(13) ofthis section, in 963.8(c)(7) and
$63.8(c)(8), and in the relevant standard, and they shall contain the name, title, and
signature of the responsible official who is certifuing the accuracy of the report. When no
excess emissions or exceedances of a parameter have occurred, or a CMS has not been
inoperative, out of control, repaired, or adjusted, such information shall be stated in the
report.
$63. I o(c)(s)
The date and time identif,zing each period during which the CMS was inoperative
except for zero (low-level) and high-level checks;
I. CEMS monitor unavailability can be found in Attachment B CEMS
Monitor Outage Report.
$63.10(cX6)
The date and time identifuing each period during which the CMS was out of
control, as defined in 963.8(c)(7);
I. CEMS out of control periods can be found in Attachment B CEMS
Monitor Outage Report.
$63. I 0(c)(7)
The specific identification (i.e., the date and time of commencement and
completion) of each period of excess emissions and parameter monitoring
exceedances, as defined in the relevant standard(s), that occurs during startups,
shutdowns, and malfunctions of the affected source;
I. Excess emissions and monitor exceedances that occurred during startups,
shutdowns, and malfunctions can be found in Attachment C Excess
Emissions Report.
$63.1o(cX8)
The specific identification (i.e., the date and time of commencement and
completion) of each time period of excess emissions and parameter monitoring
exceedances, as defined in the relevant standard(s), that occurs during periods
other than startups, shutdowns, and malfunctions of the affected source;
I. Excess emissions and monitor exceedances that occurred during period
other than startups, shutdowns, and malfunctions can be found in
Attachment C Excess Emissions Report.
$63.1 0(c)(l 0)
The nature and cause of any malfunction (if known);
I. Malfunctions nature and causes can be found in the Attachment C Excess
Emission Report.
$63.1 0(c)(1 1 )
The corrective action taken or preventive measures adopted;
L The corrective actions taken or preventive measures adopted as a result
of malfunctions can be found in Attachment C Excess Emission Report.
$63.1 0(c)( I 2)
The nature of the repairs or adjustments to the CMS that was inoperative or out
of control;
I. The nature of repairs or adjustments to CMS is found in Attachment B
CEMS Monitor Outage Report.
$63.1 0(c)( I 3)
The total process operating time during the reporting period;
L Total process operating time during reporting period can be found in
section (H) of Attachment A Summary Report-Gaseous Excess
Emission and Continuous Monitoring System Performance.
$63.1 003 1(e)
Each affected source that has obtained a Title V operating permit pursuant to part 70 or part 7l of
this chapter must report all deviations as defined in this subpart in the semiannual monitoring
report required by 40 CFR 70.6(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A). If an affected source
submits a compliance report pursuant to Table 8 to this subpart along with, or as part of, the
semiannual monitoring report required by 40 CFR 70.6(aX3)(iii)(A) or 40 CFR 71.6(a)(3)(iiiXA),
and the compliance report includes all required information concerning deviations from any
emission limit, operating limit, or work practice requirement in this subpart, submission of the
compliance report satisfies any obligation to report the same deviations in the semiannual
monitoring report. Submission of a compliance report does not otherwise affect any obligation the
affected source may have to report deviations from permit requirements to the permit authority.
I. Any Deviations to emissions limits are identified in Attachment C Excess
Emission Report
II. Any Deviations to monitoring system malfunctions, monitoring system out-of
control periods, or repairs associated with monitoring system malfunctions or
monitoring system out-of-control periods are identified in Attachment B CEMS
Monitor Outage Report
m. There are no operating limits associated with compliance to the Mercury and Air
Toxics Standards for this Unit.
tV. There were no deviations related to the Work Practice Standard related to Boiler
Tune Up requirements.
V. CMS were in service during all phases of operation including startup according
to the required Work Practice Standard except for periods identified in
Attachment B CEMS Monitor Outage Report.
V[. Clean fuel was burned during each startup as required by the Work Practice
Standard.
Attachment A
Summary Report-Gaseous Excess Emission and Continuous Monitoring
System Performance
$63.10(e)(3Xvi) Summary Report
(A) The company name and address of the affected source;
I. Huntington Power Plant, 6 miles west of Huntington Utah on Hwy 31
P.O. Box 680
Huntington, Utah 84528
(B) An identification of each hazardous air pollutant monitored at the affected source;
I. Non-Mercury TIAPS metal using a quarterly Filterable particulate matter (PM)
stack test as a surrogate to demonshate compliance. On April 3, 2018, the Utah
Division of Air Quality agreed that Huntington Unit 2 met the requirements to
qualifl, as a PM Low Emitting EGU (LEE) unit. The Huntington Plant had
submitted a summary table showing three years' worth of quarterly test data.
Each particulate matter (PM) testing result was below one-half of the 0.030
lb/IVIMBtu limit or 0.015 lbA{MBtu as required by the subpart.
II. Acid Gases using Sulfur dioxide (SOz) as a surrogate to demonstrate compliance
by an SOz continuous emission monitor system (CEMS)
III. An annual EPA Method 308, sorbent trap test is used for compliance purposes to
reconfirm the Mercury Low Emitting Electrical Generating Unit (LEE) status.
(C) The beginning and ending dates of the reporting period;
I. This report covers the reporting period from July l, 2023 to December 31 , 2023 .
(D) A brief description of the process units;
I. Unit2 is an Electric Utility Steam Generating Unit, designed as a bottom
tangentially-fired boiler, designed by Babcock & Wilcox.
II. Rated Heat Input Capacity (mmBtu/hr) of 4,960 MMBtu/hr.
III. The unit is equipped with the following add-on controls
a. Pulse Jet Fabric Filter (baghouse)
b. Wet Flue Gas Desulfurization (wet scrubber)
c. LowNOx burner technology, w/Separated overfire air
IV. Fuels used are bituminous coal and #2 fuel oil for startup fuel when needed.
(E) The emission and operating parameter limitations specified in the relevant standard(s);
L Taken from Table 2 to Subpart UUUUU of Part 63 - Emission Limits
Unit 2 is an existing unit in the coal-fired not low rank virgin coal subcategory
demonstrating compliance with the following emission limits:
Filterable particulate matter (PM) quarterly stack testing demonstrating
compliance with 3.0E-2 lbA{MBtu (0.030 lb/MMBtu) emission limit.
On April 3,2018, the Utah Division of Air Quality agreed that
Huntington Unit2 met the requirements to qualiff as a PM Low Emitting
EGU (LEE) unit. The Huntington Plant had submitted a summary table
showing three years' worth of quarterly test data. Each particulate matter
(PM) testing result was below one-half of the 0.030 lbA{MBtu limit or
0.015 lb/MMBtu as required by the subpart.
Sulfur dioxide (SOz) continuous emission monitor system (CEMS)
reporting hourly averages in units of lb/mmBtu, as a surrogate for acid
gases demonstrating compliance with a 30 boiler operating day average
of 2.0E-l lb./lVIMBtu (0.20 lb./mmBtu).
Mercury @g) EPA Method 308, sorbent trap reporting hourly averages
in units of lb/Tbtu demonstrating compliance with a 30 boiler operating
day average of 1.2E0 lb./TBtu (1.2 lb./TBtu).
(F) The monitoring equipment manufacturer(s) and model number(s);
Note: CO2 analyzer used as a diluent monitor for calculating Heat Input Based Emission
Limits
The date of the latest CMS certification or audit;
Note: The SO2 and COzanalyzers were certified for reporting under the Acid Rain
Program prior to the initial compliance date of April 16, 2015 .
(H) The total operating time of the affected source during the reporting period;
An emission data summary (or similar summary if the owner or operator monitors control
system parameters), including the total duration of excess emissions during the reporting
period (recorded in minutes for opacity and hours for gases), the total duration of excess
ll.
lll.
(G)
Pollutant Manufacfurer Model Number
Sulfur Dioxide (SOz)Thermo 43iQ-ACN
Carbon Dioxide
(CO,)Thermo 4l0iQ-ACN
CEMS Analvzer Latest RATA Date Latest Linearitv Date
Sulfur Dioxide (SOz)411412023 1110112023
Carbon Dioxide
(COr)4t14t2023 1110U2023
Ooeratinq Period Ilours of Unit Operation
7lll202l to 913012021 3rd ouarter 1,845
l0l | 12021 to 1213 I 12021 4th ouarter r.697
Total Ooeratins time from 71112023 to 1213112023 3,542
(r)
emissions expressed as a percent of the total source operating time during that reporting
period, and a breakdown of the total duration of excess emissions during the reporting
period into those that are due to startup/shutdown, control equipment problems, process
problems, other known causes, and other unknown causes;
(J) A CMS performance summary (or similar summary if the owner or operator monitors
control system parameters), including the total CMS downtime during the reporting period
(recorded in minutes for opacity and hours for gases), the total duration of CMS downtime
expressed as a percent of the total source operating time during that reporting period, and
a breakdown of the total CMS downtime during the reporting period into periods that are
due to monitoring equipment malfunctions, non-monitoring equipment malfunctions,
quality assurance/quality control calibrations, other known causes, and other unknown
causes;
CMS Perforrnance Summary SOz
*Downtime Dercent of total ooeratins hours 0.28%
Total hour of CMS downtime t0
Hours due to monitorinq equipment malfunctions 0
Hours due to non-monitorins eouioment malfunctions 2
Hours due to qualitv assurance/qualitv control calibrations 0
Hours due to other known causes 8
Hours due to other unknown causes 0
(K) A description of any changes in CMS, processes, or controls since the last reporting
period;
PacifiCorp, Huntington Unit 2 received the following CEMS monitoring equipment
upgrades during the reporting period:
Excess Emissions
Summary PM S02 Irg
Total Hours of Exceedance 0 0 0
Exceedance percent of total
ooeratins hours 0.0 0.0 0.0
Hours during startup and
shutdown 0 0 0
Hours during control
eouioment oroblems 0 0 0
Hours durins process hours 0 0 0
Hours during other know
problems 0 0 0
Hours during unknown
causes 0 0 0
Em ssion Limit 0.030 0.20 1.2
Em ssion Limitation Unit lb/MMBtu lb/i\4MBtu Lb/TBtu
Emission limitation
averasins oeriod
Quarterly Stack
Testins
30 boiler operating
dav
30 boiler
ooeratins dav
(L) Ib m0! d[A d trut dtutqmlblc ofrobl qrho L oasdogtu mry oftureoGd
****.-
LgtIfu
tmfhg DLctu - Ih d II@h hrr PLUEAodt&Ofichl
GI)m!edtt.
tu-l142
Attachment B
CEMS Monitor Outage Report
Sulfur Dioxide (SOz) System Monitor Outage (lb/MMBtu)
8/2612023 7:00 7:59 I N N 724 b
2 8t26t2023 l0:00 10:59 I N N 724 b
J tult7/2023 18:00 L9:59 2 N N 722 d
4 tolt8/2023 I 1:00 12:59 2 Y Y 724 m
5 1012812023 5:00 7:59 J Y Y 724 k
6 tt/22t2023 23:00 23:59 I Y Y 724 m
Total duration of monitor downtime 10 hours
Description of Causes/Corrective Actions.*Cause: 724 Hours due to other know causes
'Corrective Action: b
Maintenance of another monitor required
normal sampling to be intemrpted. The
system was returned to service following the
maintenance.
'Cause: 724 Hours due to other know causes
'Corrective Action: m
Monitor was not calibrated timely after startup of
unit after outage. Calibration followed and
system restored.
'Cause: 724 Hours due to other know causes
'Corrective Action: k
A daily calibration reference gas bottle was
empff, resulting in a calibration fail out of control
indication. The bottle was changed, and a second
calibration initiated.
'Cause: 722 Hours due to non-monitor malfunctions
*Corrective Action: d
A loss/interruption of power or communication to
the DCS and/or monitor resulted in a loss of data.
Power/communication was restored, and the
monitor was returned to service.
Attachment C
Excess Emissions Report
PM Excess Emissions
0.030 lb/IvIMBtu (Quarterly Stack Testing)
Total time for all excess emissions 0.0 hours
Total time for excess emissions occurring during startup/shutdown or malfunction
0.0 hours
Malfunction reason and corrective /preventive action taken)
No PM Excess Emissions occurred during the reporting period
No PM Malfunction occurred during the reporting period
SOz Excess Emissions
0.20 lbA{MBtu (30 Boiler Operating Day Average)
Total time for all excess emissions 0.0 hours
Total time for excess emissions occurring during startup/shutdown or malfunction
0.0 hours
Malfunction reason and corrective /preventive action taken)
No SOz Excess Emissions occurred during the reporting period
No SOz Malfunction occurred during the reporting period
Hg Excess Emissions
1.2 lb/TBtu (30 Boiler Operating Day Average)
Total time for all excess emissions 0,0 hours
Total time for excess emissions occurring during startup/shutdown or malfunction
-.,1!Q-hours
Malfrrnction reason and corrective /preventive action taken)
No Hg Excess Emissions occured during the reporting period
No Hg Malfunction occurred during the reporting period
UTAH DEPAFruENT OF
ENVIRO.IMENTAL OI'AUTY
JAN 2 6 2024
DIVISION OF AIB OUALTTV