DAQ-2024-004486

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Huntington Power Plant
8 miles west of Huntington, Utqh on Hwy. j I
P.O. Box 680
Huntington, Utah 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 Vlfinkoop St.
Denver, CO 80202 - 1129
I,TAH DEPABTMENT OF
ENVIRONMENTAL OUALITY
JAN ? t-, 20?_4
DIVISION OF AIR QUALITV
RE: Semiannual Compliance Report,40 CFR 63 Sub-Part UUUUU, Huntington Power Plant
(Title V Permit #1501001005) Boiler Unit 1
Dear Mr. Bird:
Huntington Power Plant's Title V Permit Conditions 11.B.2.9.3 and 11.8.3.f.3 require the Huntington Plant to
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 certify 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 informption, or omitting statements and information, including the possibility of fine or imprisonment.
regarding this information, please contact Terry Guthrie, Hunter and
mental Manager at [phone] or me at (435) 6874211.
/
/f?ren Huntstnbfi'
( / 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 attachments A thru C - Unit 1
cc: Youn Joo Kim - USEPA Region Vlll w/enclosure
Steve Jensen - NTO w/o enclosure
Russ Willson - Plant Files Wenclosure
. Hl,ti",?fi H,?XJ ?,I^fi i"
Mercury and Air Toxics Semi-Annual Compliance Report
Huntington Power Plant Unit 1
Reporting Period July l, 2023 to December 31,2023 DIVIS,ION OF /rlR eUALlT.
$63.100031(c)
The compliance report must contain the information required in paragraphs (c)(1) through (5) of this
section.
563.10031(c)(l)
The information required by the summary report located in 63.10(e)(3)(vi).I. See Attachment A Summary Report-Caseous Excess Emission and Continuous Monitoring
System Performance
$63.10031(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 FuelOil Burned (gallons)Bituminous Coal Burned (tons)
luly 2023 42"313 76.840
August 1,719 I10.307
September 2,262 85.472
October 4,280 63.649
November 0 48.867
December 0 35,459
Total 50.574 420,594
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.
$63.10031(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 perfornance test where that fuel was in use.
L No new types of fuel were burned during the reporting period.
$63.10031(c)(a)
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.
L The most recent boiler tune up was completed on December 14,2022 with the burner
inspection occurring as part ofthe tune-up.
$63.10031(cXs)
Should you choose to rely on paragraph (2) of the definition of "startup" in 963.10042 for your
EGU, for each instance of startup or shutdown you shall:
I. The Unit relies on paragraph (l) of the definition of "startup." Therefore, no startups or
shutdowns in the current semi-annual reporting period are subject to this requirement.
$63.10031(c)(6)
You must report emergency bypass information annually from EGUs with LEE status.
I. No emergency bypass occurred during the reporting period.
$63. 1003 1(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.
L Unit 1 Annual Mercury LEE tests - summary results (lbs Hg/Tbtu)
Test Completion
Date
Mercury LEE
Threshold
Actual Test
Result
tU28t202r 0.12 0.004
911512022 0.12 0.006
4t25t2023 0.12 0.01
The Huntington Plant completed a three (3) consecutive year, quarterly PM testing period
to quality Unit I as a PM Low Emitting EGU. Reference Method 5 was performed in
accordance with $63.10005(hXlXi) to demonstrate PM emissions were less than fifty
(50) percent of the applicable emission limit, 0.030 lbA4MBtu. 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 Ib/\rIMBtu,
which qualifies Unit 1 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:
Huntinston 1 PM LEE Test Summarv
Test ID Test Date Average PM
0blmmBtu)
LEE Threshold
Q22015 5lt2l20ts 0.010
0.015Ib/mmBtu
03 20ts 8/rU20r5 0.007
04 20ts 12115120t5 0.004
01 2016 2109/2016 0.00s
022016 6/2812016 0.006
03 2016 812312016 0.004
04 20t6 tt/0812016 0.005
II.
ot 20t7 2t07/2017 0.006
c220t7 5110/2017 0.003
03 2017 810812017 0.004
04 2017 t2/0st2017 0.011
01 2018 216/2018 0.004
36 month Averase 0.006
PacifiCorp
Huntington Unit I
PM Low Emittins EGU OEE) Subsequent Test Results
Test II)Test Date Average PM
0b/mmBtu)
MATS PM
Limit
MATS PM
LEE Limit
o12021 3t9t2021 0.007 0.030 0.01s
III. No operational changes have occurred since the last stack test that could increase
emissions
$63.10031(c)(8)
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
III. 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 all phases of operation including startup according
to the required Work Practice Standard except for periods identified in
Attachment B CEMS Monitor Outage Report.
VI. Clean fuel was burned during each startup as required by the Work Practice
Standard.
$63.10031(cX10)
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.
L Malfunctions during the reporting period are identified in Attachment C Excess
Emissions Report
$63.1003 1(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 63.10(e)(3)(vi) (and under paragraph (e)(3)(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 13 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.
$63.1 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 certifring 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 0(c)(s)
The date and time identif,ing 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. I 0(c)(6)
The date and time identiffing each period during which the CMS was out of
control, as defined in 963.8(c)(7);
L CEMS out of control periods can be found in Attachment B CEMS
Monitor Outage Report.
$63.10(cX7)
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.
963. I 0(c)(8)
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)( 1 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.
$63.1o(cXl1)
The corrective action taken or preventive measures adopted;
I. The corrective actions taken or preventive measures adopted as a result
of malfunctions can be found in Attachment C Excess Emission Report.
963. I 0(c)( l2)
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)( 1 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.
$63.10031(e)
Each affected source that has obtained a Title V operating permit pursuant to part 70 or part 7 | 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(a)(3)(iii)(A) or 40 CFR 71.6(a)(3)(iii)(A),
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
U. 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.
ry. 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.
VL 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) (3) (vD Summary Report
(A) The company name and address of the affected source;
I. Huntington Power Plant, 6 miles west of Huntington Utah on Hwy 3l
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 demonstrate compliance. On April 3, 2018, the Utah
Division of Air Quality agreed that Huntington Unit 1 met the requirements to
qualifr 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/lvlMBtu limit or 0.015 lb/NIMBtu 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. Mercury (Hg), compliance demonstrated by an annual EPA Method 30 B,
sorbent trap test to re-confirm 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 1,2023 to December 31,2023.
(D) A brief description of the process units;
L Unit 1 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. Low NOx burner technology, dSeparated overfire air
[V. 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);
I. Taken from Table 2 to Subpart UUUUU of Part 63 - Emission Limits
Unit I 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 lb/l\4MBtu (0.030 lbAvIMBtu) emission limit.
On April 3, 2018, the Utah Division of Air Quality agreed that
Huntington Unit I 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 0.030lbA{MBtu limit or
0.015 lbA,IMBtu 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./l\4MBtu (0.20 lb./mmBtu).
Mercury (Hg) - Annual EPA Method 30B sorbent trap test 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.
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)
(H)
Pollutant Manulircture ModelNumber
Sulfur Dioxide (SOz)Thermo 43iQ-ACN
Carbon Dioxide
(co.,)Thermo 410iQ-ACN
CEMS Analvzer Latest RATA Date Latest Linearitv Date
Sulfur Dioxide (SOz)4n3t2023 101412023
Carbon Dioxide
(CO,)411312023 101412023
Oneratins Period Hours of Unit Ooeration
71112023 to 913012023 3rd Ouarter 2.208
l0ll12023 to 1213112023 4th Quarter 2.208
Total Ooeratins time fromT/112023 to 1213112023 4,416
(D
(J)
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;
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 ofthe 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 Performance Summarv SOz
Downtime percent of total operatins hours 0.25%
Total hour of CMS downtime l1
Hours due to monitorins eouioment malfunctions l0
Hours due to non-monitoring equipment malfunctions I
Hours due to quality assurance/qualitv control calibrations 0
Hours due to other known causes 0
Hours due to other unknown causes 0
A description of any changes in CMS, processes, or controls since the last reporting
period;
No changes have occurred.
Excess Emissions
Summarv PM SOz Hg
Total Hours of Exceedance 0 0 0
Exceedance percent of total
ooeratins hours 0 0.0 0.0
Hours during startup and
shutdown 0 0 0
Hours during control
equipment problems 0 0 0
Hours during process hours 0 0 0
Hours during other know
oroblems 0 0 0
Hours during unknown
causes 0 0 0
Emission Limit 0.030 0.20 1.2
Emission Limitation Unit lbiIvIMBtu lb/MMBtu LblTBtu
Emission limitation
averasins neriod
Annual Stack
Testins
30 boiler
ooeratins dav
30 boiler
ooeratins dav
(K)
No qgndc *ur nrdc &rfu fu p6iod.
Eddtrdr! offu rrryodbL sfficialx,to b ordglngtc mncyof
Mrorghg Dhfir- Itu 0d IIffigtur Foru Phr
no+omf Ofrdd
(L) rb
Attaehment B
CEMS Monitor Outage Report
Sulfur Dioxide (SOz) System Monitor Outage (lb/MMBtu)
I 81t512023 9:00 9:59 I N N 722 d
2 1012312023 6:00 7:59 2 N N 721 afl
3 Lvt312023 00:00 7:59 8 Y Y 721 a
Total duration of monitor downtime I I hours
of Causes/Conective Actions.
*Caluse;722 Hours due to non-monitor malfunctions.
'Corrective Action: d A losVintemrption 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.
*Cause:721 Hours due to monitor malfunction
*Corrective Action: aa The analyzer stopped collecting valid data (went
to data error), Could not see arqr problems;
powered down the analyzer and then powered
back up; analyzer started collecting valid data
again and emissions were within range.
*Cause:721 Hours due to monitor malfirnction
*Corrective Action: a The monitor failed its daily calibration drift test
by more than 4 times the performance
specification. The monitor was
cleaned/inspected/ recalibrated and returned to
service.
Attachment C
Excess Emissions Report
PM Excess Emissions
0.030 lbA{MBtu (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/tMBtu (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 Malfrrnction 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
0.0 hours
Malfunction reason and corrective /preventive action taken)
No Hg Excess Emissions occurred during the reporting period
No Hg Malfunction occurred during the reporting period
_t,IAH DEPARTMENT OFET.JVIRONMENTAL QUALITY
JAN 2 6 2024
DIUSION OF AIH QUALITY