DAQE­AN0238012­05 

April 6, 2005 

Eugene Marshall

PacifiCorp 

1407 West North Temple  Salt Lake City, Utah  84140 

Dear Mr. Marshall:

Re: Approval Order: Installation of a Wet­Lime FGD, Baghouse and Low­NOx Combustion  Controls at Huntington Unit 2, Emery County, CDS­A, ATT, Title V, Baghouse & LNBs  Project Code: N0238­012 

The attached document is the Approval Order (AO) for the above­referenced project.

Future correspondence on this AO should include the engineer's name as well as the DAQE number as

shown on the upper right­hand corner of this letter. Please direct any technical questions you may have  on this project to Mr. John D. Jenks. He may be reached at (801) 536­4459.

Sincerely,

Richard W. Sprott, Executive Secretary 

Utah Air Quality Board 

RWS:JJ:re 

cc: Southeastern Utah District Health Department

Mike Owens, EPA Region VIII

150 North 1950 West • PO Box 144820 • Salt Lake City, UT 84114­4820 • phone (801) 536­4000 • fax (801) 536­4099 T.D.D. (801) 536­4414 • www.deq.utah.gov

State of Utah 

Department of 

Environmental Quality

Dianne R. Nielson, Ph.D. Executive Director

DIVISION OF AIR QUALITY

Richard W. Sprott Director

JON M. HUNTSMAN, JR. Governor

GARY HERBERT

Lieutenant Governor
STATE OF UTAH

Department of Environmental Quality

Division of Air Quality

APPROVAL ORDER:  INSTALLATION OF A WET­LIME 

FGD, BAGHOUSE AND LOW­NOX COMBUSTION 

CONTROLS AT HUNTINGTON UNIT 2

Prepared By: John D. Jenks, Engineer 

(801) 536­4459 

Email: jjenks@utah.gov 

APPROVAL ORDER NUMBER

DAQE­AN0238012­05 

Date: April 6, 2005

PacifiCorp

Source Contact

Dave Sharp 

(435) 687­4306 

Richard W. Sprott

Executive Secretary 

Utah Air Quality Board
Abstract

PacifiCorp is installing new emissions  control equipment at Unit number 2 of the Huntington Power  Plant in order to substantially reduce SO2, particulate matter (PM) and NOx emissions. The plant will

install a NOx reduction system consisting of two general components: (1) two levels of separated overfire air; and (2) new low­NOx  burners.  The  plant will also replace  the existing electrostatic  precipitator 

(ESP) with a new fabric filter (baghouse) system, which will use the old ESP box housing. This will result in a reduction of PM emissions. Finally, the  plant will install a new wet­lime, flue  gas 

desulfurization system (FGD), which will significantly reduce the amount of SO2  emissions. As a result

of adding this  new emissions reduction equipment, Huntington  Unit 2 will become  a Prevention  of

Significant Deterioration (PSD) major source, but the source is not subject to PSD review at this time as  all emission changes are reductions. The source is subject to New Source Performance Standards, but no additional conditions or limitations are expected as a result of the modification. In addition, these  changes are not considered a reconstruction under the NSPS rules, so Huntington Unit 2 will remain a  non­NSPS unit. The Title  V Operating Permit will be  updated prior  to operating the  modified 

equipment. The source is  located in Emery  County, which  is an  attainment area of the  National

Ambient Air Quality Standards (NAAQS) for all pollutants. The emissions, in tons per year, will change  as follows: PM10 –1,432.0, NOx –2,781.0, SO2 –17,479.0.

The project has been evaluated and found to be consistent with the requirements  of the  Utah 

Administrative Code Rule 307 (UAC R307). A public comment period was held in accordance with UAC

R307­401­4 and comments were received. The comments were evaluated and no comment was found to  be  adverse to  the  proposed AO. This  air quality Approval Order (AO) authorizes the  project with the 

following conditions, and failure to comply with any of the  conditions may constitute a violation of this  order. General Conditions:

1. This Approval Order (AO) applies to the following company:

Site Office  Corporate Office Location  Huntington Power Plant PacifiCorp 

P. O. Box 680  1407 W. North Temple  Huntington, UT 84528  Salt Lake City, UT  84140 

Phone Number (435) 687­4211  (801) 220­2235 

Fax Number (435) 687­4201  (801) 220­4307 

The equipment listed in this AO shall be operated at the following location:

The Huntington plant is located on State Highway 31, 10 miles west of Huntington, Emery 

County, Utah 

Universal Transverse Mercator (UTM) Coordinate System: UTM Datum NAD27 

4,358.8 kilometers Northing, 493.1 kilometers Easting, Zone 12
DAQE­AN0238012­05 

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2. All definitions, terms, abbreviations, and references used in this AO conform to those used 

in  the  Utah  Administrative Code (UAC) Rule 307 (R307) and  Title  40 of the Code  of

Federal Regulations  (40 CFR). Unless noted otherwise, references cited in these  AO

conditions refer to those rules.

3. The limits set forth in this AO shall not be exceeded without prior approval in accordance  with R307­401.

4. Modifications  to  the  equipment or processes  approved by this  AO that could affect the  emissions  covered  by  this  AO must be  reviewed and approved in accordance  with 

R307­401­1.

5. All records referenced in this AO or in applicable NSPS, which are required to be kept by 

the  owner/operator, shall be made  available  to the Executive  Secretary or Executive  Secretary’s representative upon request, and the records shall include the two­year period 

prior to the date of the request. All records shall be kept for the minimum period of five  years.

6. PacifiCorp shall install and operate the new low­NOx burners, overfire  air system, wetlime  FGD and fabric filter baghouse and shall conduct its  operations  of the Huntington  power plant in accordance with the terms  and conditions of this AO, which was written  pursuant to PacifiCorp’s Notice of Intent submitted to the Division of Air Quality (DAQ) on October 28, 2004, and additional information submitted on February 2, 2005, February 

15, 2005 and February 17, 2005.

7. This AO shall replace the AO (DAQE­AN0238009­04) dated May 26, 2004.

8. The approved installations shall consist of the following equipment or equivalent*:

A. Boiler Unit #1 

Unit Description: Nominal 480 MW gross capacity dry bottom, tangentially fired  utility  boiler fired on sub  bituminous and bituminous coal using fuel oil during  startup & flame stabilization. System is  equipped  with  electrostatic  precipitator and SO2 FGD scrubber system.

B. Boiler Unit #2 

Unit Description: Nominal 480 MW gross capacity dry bottom tangentially fired  utility  boiler fired on sub  bituminous and bituminous coal using fuel oil during  startup  & flame  stabilization. System is  equipped with new low­NOx  burners, separated overfire  air system, new SO2  FGD scrubber system and new pulse jet

fabric filter (baghouse).

C. Coal Storage 

Unit Description: Existing covered coal storage facility and open coal pile. No  unit specific applicable requirements.

D. Ash Landfill

Unit Description: Ash  and sludge  disposal. No  unit specific applicable 

requirements.
DAQE­AN0238012­05 

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E.  Unit #1 Cooling Towers  Unit Description: Unit #1 cooling towers for the  circulating water system. No  unit specific applicable requirements.

F. Unit #2 Cooling Towers  Unit Description: Unit #2 cooling towers for the  circulating water system. No  unit specific applicable requirements.

G. Coal Conveyors  Unit Description: Coal transfer on plant site 

H. Ash Haul Road (dirt)

Unit Description: Unpaved ash haul road. No  unit specific  applicable 

requirements.

I. Ash Haul Road (paved)

Unit Description: Paved ash haul road. No unit specific applicable requirements.

J. Unit #1 Emergency Generator (diesel engine)

Unit Description: Emergency  generator (diesel engine) for Unit #1. No unit specific applicable requirements.

K. Unit #2 Emergency Generator (diesel engine)

Unit Description: Emergency  generator (diesel engine) for Unit #2. No unit specific applicable requirements.

L.  Emergency Fire Pump (diesel engine)

Unit Description: Emergency  fire  pump (diesel engine). No  unit specific  applicable requirements. M. Coal Silo System Exhauster for Unit #1 

Unit Description: Coal silos  for Unit #1 equipped  with exhausters  and dust

collectors.  No unit specific applicable requirements.

N. Coal Silo System Exhauster for Unit #2 

Unit Description: Coal silos  for Unit #2 equipped  with exhausters  and dust

collectors.  No unit specific applicable requirements.

O. Lime Silo Bin Vent

Unit Description: Fabric filter baghouse on lime storage silo. No unit specific  applicable requirements.

P. Distillate Fuel Oil Tanks 

Unit Description: Three 70,000­gallon tanks  (1973) and day tanks  for the  emergency  diesel generators  and fire  pumps. No  unit specific applicable 

requirements.

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DAQE­AN0238012­05 

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Q. Lube Oil Storage Tanks  Unit Description: Four 10,000­gallon tanks that store  lubricating  oil including  vents and associated equipment; two each constructed in 1973 and 1975. No unit specific applicable requirements.

R. Oil Storage Area  Unit Description: Storage area for oil contained in closed 55­gallon drums. No  unit specific applicable requirements.

S. Paved Access Road and Parking Area  Unit Description: Paved access road from the plant entrance to the administration  building and parking area.  No unit specific applicable requirements.

T.  Cold Solvent Degreasing Operations  Unit Description: Bench top cold degreasing  units using  Safety  Kleen, Simple  Green, or other comparable  degreasing agents. No  unit specific  applicable 

requirements.

U. Miscellaneous Electrical Equipment

Unit Description: Fugitive emission units including transformer insulating oil. No  unit specific applicable requirements.

V. Diesel Refueling Stations and Storage Tanks (designated as Emission unit #26)

Unit Description: One 5,000 and one 1,500­gallon aboveground diesel fuel tank 

and dispensing  pumps  to  refuel fleet vehicles and mobile  equipment. No  unit specific applicable requirements. W. Gasoline Vehicle Refueling Station and Tanks 

Unit Description: Gasoline  refueling for fleet vehicles from two  1,500­gallon  aboveground tanks  constructed in December 1991. No unit specific  applicable 

requirements.

X. Unit #1 Generator Seal Oil Air Detraining Tanks  Unit Description: Atmospheric  vents  from the seal oil air detraining  tanks  for Boiler Unit #1. No unit specific applicable requirements.

Y. Unit #2 Generator Seal Oil Air Detraining Tanks  Unit Description: Atmospheric  vents  from the seal oil air detraining  tanks  for Boiler Unit #2. No unit specific applicable requirements.

Z.  Unit #1 Lube Oil Reservoirs  Unit Description: Lube oil reservoirs with vapor extractors for Boiler Unit #1. No  unit specific applicable requirements.

AA. Unit #2 Lube Oil Reservoirs  Unit Description: Lube oil reservoirs with vapor extractors for Boiler Unit #2. No  unit specific applicable requirements.

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DAQE­AN0238012­05 

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BB. Truck Mounted Vacuum System

Unit Description: Mobile truck mounted vacuum to clean up spilled material such  as ash. No unit specific applicable requirements.

CC. Ash Unloader for Unit #1 

Unit Description: Equipment for unloading  ash from silos  and into  trucks for

transport to the ash landfill. No unit specific applicable requirements.

DD. Ash Unloader for Unit #2 

Unit Description: Equipment for unloading  ash from silos  and into  trucks for

transport to the ash landfill. No unit specific applicable requirements.

EE. Emission Units Subject to 40% Opacity Limit

Unit Description: Units constructed prior to April 25, 1971 consisting of Boiler Unit #2 coal silo system exhauster, Unit #2 ash unloader, Unit #2 Generator Seal

Oil Air Detraining Tanks, Unit #2 Lube Oil Reservoirs.

FF. Coal Reject Handling System

Unit Description: Material handling system that separates reject materials from

the coal prior to pulverizing. No unit specific applicable requirements.

GG. Hazardous Waste Storage Area  Unit Description: Area  where hazardous  waste  is  stored temporarily  awaiting 

disposal. No unit specific applicable requirements.

HH. Electro hydraulic Control Reservoirs  Unit Description: Three  400­gallon tanks that store  lubricating  oil. No  unit specific applicable requirements.

II. Water Treatment Chemical Tanks  Unit Description: Tank storage including: lime, sodium sulfite, hydrochloric acid, sodium hydroxide, sulfuric  acid, anti scale, aqueous  ammonia. No unit specific  applicable requirements.

JJ. Paint Storage Areas Unit Description: Various  storage  areas for sealed paint containers. No  unit specific applicable requirements.

KK. Coal Handling and Blending Equipment. Unit Description: Truck unloading hopper enclosed on the sides with water sprays, covered conveyor belts  with enclosed transfer stations, radial stacker, Stamler

feeder with water sprays, and screens.

LL. Real Time Coal Analyzer Unit Description: Thermo Electron CQM coal analyzer with hopper and associated  covered conveyor belts with enclosed transfer stations equipped with dust closure  seals and curtains at all loading points.

* Equivalency shall be determined by the Executive Secretary.

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DAQE­AN0238012­05 

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Limitations and Tests Procedures

9. Boiler Unit #1 

A. Emissions of SO2 from Boiler Unit #1 shall be no greater than 1.2 lb SO2/MMBtu  heat input for any 3 hour period as determined by the arithmetic average of three  contiguous  one hour periods  except during periods  of startup, shutdown, maintenance/planned outage, or malfunction.

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

B. Emissions of SO2  from Boiler Unit #1 shall be no greater than 20 percent of the  potential combustion concentration based on the average inlet and average outlet

SO2  emissions determined as the  arithmetic  average  of all hourly emission rates 

for the 30 successive boiler operating days.

PacifiCorp shall install, calibrate, maintain, and operate a  continuous monitoring  system, and record the  output of the  system, for measuring  sulfur dioxide  emissions. PacifiCorp shall determine compliance with the SO2 reduction limit by 

periodic  monitoring using procedures in 40 CFR Part 60.46a, Compliance  provision (subparagraph (c), (d), (e), (g) and (h)), 60.47a, Emission monitoring 

(subparagraph (b), (d), (e), (f), (g), (h), (i) and (j)), and 60.48a, Compliance  determination procedures and methods (subparagraph (c)).

C. Emissions of particulate matter (PM) from Boiler Unit #1 shall not be greater than  0.10 lb/MMBtu heat input except during periods of startup, shutdown, maintenance/planned outage or malfunction.

D. Emissions of NOx  from Boiler Unit #1 shall be no greater than 0.70 lb/MMBtu  heat input for any 3 hour period as determined by the arithmetic average of three  contiguous  one hour periods  except during periods  of startup, shutdown, maintenance/planned outage or malfunction.

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

E.  Visible emissions shall be no greater than 20 percent opacity (six minute average) except for one six minute period per hour of not more than 27 percent opacity and  except during  periods  of start up, shutdown, maintenance/planned outage, or malfunction.

PacifiCorp shall determine compliance with the visible emission limit by periodic  monitoring using  a  continuous  opacity monitoring  (COM) system installed and
DAQE­AN0238012­05 

Page 8 

operated in accordance  with 40 CFR 60.45, Emission and fuel monitoring 

(subparagraphs (a) and (g)) and 60.13(e).

10. Boiler Unit #2 

A. Sulfur content of any mixture of coal burned in Boiler Unit #2 shall be no greater

than 1 lb/MMBtu gross heat input. Once installation and operation of the wet­lime 

flue gas desulfurization system as shown in Condition #8.B has been  completed,

this condition shall no longer apply, as Condition #10.C will cover emissions of

SO2 as allowed under R307­203­1 (2).

B. Visible emissions from Boiler Unit #2 shall be no greater than 40 percent opacity 

(six minute average) except for one  three minute  period per hour as a result of unavoidable  combustion irregularities and except during  periods  of start up, shutdown, maintenance/planned outage, or malfunction.

Once installation of the fabric filter system as shown in Condition #8.B has been  completed, emissions of particulate matter (PM) from Boiler Unit #2 shall not be 

greater than 70 lb/hr, except during periods of startup, shutdown, maintenance/planned outage  or malfunction. Additionally, following installation  of the fabric filter system visible emissions from Boiler Unit #2 shall be no greater

than 20 percent opacity (six minute average) except for one six minute period per

hour of not more than 27 percent opacity  and except during periods  of start up, shutdown, maintenance/planned outage, or malfunction.

C. Once  installation of the wet­lime flue  gas desulfurization system as shown in  Condition #8.B has been completed, emissions of SO2 from Boiler Unit #2 shall be  no  greater than  0.12 lb  SO2/MMBtu heat input for any  24 hour block  average  except during periods  of startup, shutdown, maintenance/planned outage, or malfunction.

D. Once  installation  of the  low­NOx  burners  and overfire  air system as shown in  Condition #8.B has been completed, emissions of NOx  from Boiler Unit #2 shall

be no greater than 0.26 lb/MMBtu heat input for any 30 day rolling average except

during periods of startup, shutdown, maintenance/planned outage or malfunction. PacifiCorp shall install, calibrate, maintain, and operate  a continuous monitoring  system for measuring nitrogen oxides emissions.

E.  PacifiCorp shall notify the Executive Secretary in writing when the installation of each new system (fabric filter, flue gas desulfurization, burners and overfire air) as 

listed in Condition #8.B and outlined in Conditions #10.B, 10.C and 10.D has been  completed and is  operational, as an  initial compliance  inspection is required for each system. To insure proper credit when notifying the Executive Secretary, send 

your correspondence to the Executive Secretary, attn: Compliance Section.

If installation has not been completed within eighteen months from the date of this  AO, the  Executive Secretary shall be  notified in  writing  on  the  status  of the 

installation. At that time, the Executive Secretary shall require documentation of
DAQE­AN0238012­05 

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the continuous installation of the operation and may revoke the AO in accordance  with R307­401­11.

11. All coal conveyors and drop points shall be enclosed.

12. Visible emissions from the coal reject handling system shall be no greater than 40 percent

opacity.

13. Visible emissions shall be no greater than 5 percent opacity at all conveyor transfer points  and conveyor drop points for the coal blending equipment.

14. Visible emissions  shall be  no  greater than 10 percent opacity  for the  truck  unloading 

hopper, radial stacker and all screens.

15. There shall be  no  visible emissions  at the Real­Time  coal analyzer and all conveyor

transfer points  and conveyor drop points  associated  for the  Real­Time coal analyzer

equipment. Monitoring  A visual observation of the  site shall be  made  at least once  each  month.

Record Keeping  A log of the visual inspections shall be maintained including the date  and time of each inspection and the name of the person making  the 

inspection.

Reporting  Any visible emissions observed, shall be reported as a deviation.

16. Visible emissions shall be no greater than 20 percent opacity except as listed in this AO or diesel engines as described in R307­201­1.

17. Visible emissions from any stationary point or fugitive emission source associated with the  source or with the control facilities shall not exceed 20% opacity. Opacity observations of emissions from stationary sources shall be conducted in accordance with 40 CFR 60, Appendix A, Method 9.

For sources that are subject to New Source Performance Standards (NSPS), opacity shall

be  determined by  conducting  observations  in accordance with 40 CFR 60.11(b) and 40 

CFR 60, Appendix A, Method 9.

Roads and Fugitive Dust

18. PacifiCorp shall abide by a fugitive dust control plan acceptable to the Executive Secretary 

for control of all dust sources associated with the  Huntington power Plant. PacifiCorp 

shall abide  by the  most current fugitive  dust control plan approved by  the  Executive  Secretary.

19. The facility shall abide by all applicable requirements of R307­205 for Fugitive Emission  and Fugitive Dust sources.

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20. The facility shall abide by all applicable requirements of R307­206 for Abrasive Blasting 

Emission Standards.

Fuels

21. The sulfur content of any fuel oil shall not exceed 0.85 lbs/MMBtu heat input. The sulfur content shall be  determined by  ASTM Methods  D2015­77 or D3286­85  or approved 

equivalent.

Federal Limitations and Requirements

22. In addition to the requirements of this AO, all applicable provisions of 40 CFR 60, New

Source Performance Standards (NSPS) Subpart A, 40 CFR 60.1 to 60.18 and Subpart D, 40 CFR 60.40 to 60.49 (Standards of Performance for Fossil­Fuel­Fired Steam Generators 

for Which Construction is Commenced After August 17, 1971) applies to the Boiler Unit

#1. NSPS Subpart Y (NSPS for Coal Preparation Plants) applies to the coal preparation  equipment.

23. In addition to the requirements of this AO, all applicable provisions of 40 CFR Part 72, 73, 75, 76, 77, and 78 ­ Federal regulations for the Acid Rain Program under Clean Air Act

Title IV apply to this installation.

Records & Miscellaneous

24. At all times, including  periods of startup, shutdown, and malfunction, owners  and 

operators shall, to  the  extent practicable, maintain and operate  any  equipment approved 

under this  Approval Order including  associated air pollution control equipment in a  manner consistent with good air pollution control practice  for minimizing emissions. Determination of whether acceptable operating and maintenance procedures are being used  will be based on information available to the Executive Secretary which may include, but

is  not limited to, monitoring results, opacity  observations, review of operating  and  maintenance  procedures, and inspection of the  source. All maintenance  performed on  equipment authorized by this AO shall be recorded.

25. The owner/operator shall comply with R307­150  Series. Inventories, Testing  and 

Monitoring.

26. The owner/operator shall comply  with  R307­107. General Requirements: Unavoidable  Breakdowns.

The Executive Secretary shall be notified in writing if the company is sold or changes its name.

This  AO in no  way  releases  the owner or operator from any liability for compliance  with all other applicable federal, state, and local regulations including R307.

A copy of the rules, regulations and/or attachments addressed in this AO may be obtained by contacting the  Division of Air Quality. The Utah Administrative Code R307 rules used  by DAQ, the Notice  of Intent

(NOI) guide, and other air quality documents and  forms  may also be  obtained  on the Internet at the 

following web site:

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http://www.airquality.utah.gov/

The annual emission estimations  below include  point source, fugitive  emissions, fugitive  dust and 

grandfathered emissions, and do not include road dust and tail pipe emissions. These emissions are for the  purpose of determining the applicability of Prevention of Significant Deterioration, non­attainment area, maintenance area, and Title V source requirements of the R307. They are not to be used for determining  compliance.

The Potential To Emit (PTE) emissions for the PacifiCorp Huntington power plant are currently calculated 

at the following values:

Pollutant Tons/yr

A. PM10 ...................................................... 2,138.0 

B. SO2 ...................................................... 26,714.0 

C. NOx ..................................................... 13,274.0 

D. CO............................................................ 796.0 

(The following values are estimates of actual emissions – there are no limitations on these values, which  are simply estimates as submitted in the emission inventory)

E.  VOC........................................................... 90.31 

F. Sulfuric Acid .............................................. 25.08 

G. HAPs  Acetaldehyde....................................0.86 

Benzene............................................1.97 

Benzyl Chloride................................1.06 

Cyanide Compounds.........................3.78 

HCL .............................................317.23 

Hydrogen Fluoride........................183.55 

Isophorone........................................0.88 

Methyl Chloride (Chloromethane) ....0.80 

Methyl Ethyl Ketone (2­Butanone) ...0.59 

Propionaldehyde...............................0.57 

Selenium Compounds.......................1.97 

Misc HAPs <0.5 tpy each .................4.33 

H. Total HAPs............................................... 517.59 

Approved By:

Richard W. Sprott, Executive Secretary 

Utah Air Quality Board