2 

case of Healy, this cost is significant, adding almost $2 million to the SCR project capital 

costs. In general, cost estimates prepared to determine the cost-effectiveness of an air 

pollution control project assume that the project will be well planned and occur during 

a regularly scheduled plant shutdown. 

“Lost opportunity” costs such as the cost to replace lost electricity production due to the 

shutdown can be significant and can introduce an artificial high bias to the cost of the 

air pollution control project. In rare cases, it may be argued that the air pollution 

control project requires an extension to a regularly scheduled plant shutdown because 

the air pollution control equipment cannot be tied into the existing plant exhaust 

ducting in the time allowed. This argument requires highly specific information 

establishing that the extension to the shutdown is unavoidable and is due solely to the 

air pollution control project. The Alaska BART analysis includes no such information or 

detailed argument. I therefore consider these to be inappropriate costs not attributable 

to the SCR project. Other than this cost, my review did not identify any additional costs 

which should be eliminated as inappropriate. 

Removing the lost production cost improves the cost effectiveness for the SCR project 

to the values detailed below, but these costs are still well above the range considered 

cost effective under BART. 

Facility Remaining 

 Useful Life (years) 

SCR Cost 

($ per ton NOX removed)

8 $13,624 

10 $12,122 

15 $10,170 

20 $9,248 

Auxiliary Boiler #1 

The Enviroplan BART document proposes that BART for particulate matter (PM), sulfur 

dioxide (SO2), and nitrogen oxides (NOX) emissions from the Auxiliary Boiler #1 consist 

of the existing emission limits, which reflect no additional controls. However, except for 

noting that the visibility impairment attributable to this boiler is less than 0.5 deciview, 

the Enviroplan BART analysis did not include technical or cost analysis supporting this 

BART determination. 

According to the facility Title V Air Operating Permit for the Healy Power Plant (ADEC, 

2003), annual emissions from this boiler are limited to 2 tons per year (tpy) NOX, 1 tpy 

PM, and 4 tpy SO2. At these emission levels, cost effective controls to reduce NOX and 

PM emissions are clearly not available since technologies to reduce emissions of these 

pollutants involve add-on pollution control equipment whose costs would not be 

justified to reduce these already low emission levels. 
3 

For SO2, the most cost-effective method to reduce emissions from the boiler would be to 

burn lower sulfur diesel fuel in the boiler. According to the Title V permit, the boiler is 

currently allowed to burn diesel fuel with sulfur content up to either 3,000 or 5,000 

parts per million (ppm), depending on the averaging time. Since ultra-low sulfur diesel 

(ULSD) with sulfur content of 15 ppm is widely available, I conducted limited research 

into the local (Healy, AK) market to understand the cost differential between these two 

distillate fuels. 

On February 6, 2012, I contacted Nenana Heating Service in Nenana, AK and obtained 

prices for ULSD and high sulfur heating oil, which typically has sulfur content above 

3,000 ppm. After calling several companies, Nenana was the only one I found that 

delivered to Healy. The price differential between "keep full" prices for the two fuels 

was 55.5 cents per gallon. 

As noted above, Auxiliary Boiler #1 is limited to 2 tons/year NOX emissions. Using the 

AP-42 emission factor 20 pounds of NOX per 1000 gallons of diesel1, the boiler would be 

allowed to burn approximately 200,000 gallons of diesel per year2. 

At 55.5 cents/gallon, it would cost GVEA approximately an additional $111,000 per year 

to purchase ULSD. For SO2, this translates to almost $28,000/ton3 of SO2 removed. This 

is clearly not cost effective. 

If you have any questions about these comments, please call me at 3-1217. 

C: Mark Filippini, Unit Manager, ESU, OEA 

 Debra Suzuki, Unit Manager, STAPU, OAWT 

 Juliane Matthews, ORC 

 

1

 Table 1.3-1 Distillate oil fired boilers less than 100 MMBtu/hr heat input. Auxiliary Boiler #1 is rated at 10.4 

MMBtu/hr. http://www.epa.gov/ttn/chief/ap42/ch01/final/c01s03.pdf

2

				

			





	x	

,			

		

	x	

,		

			

= 200,000	 	





3

				

$.

	

	x	

,		





	x	





		

= $27,750	per	ton	SO2
4 

References 

ADEC, 2003. Title V Air Operating Permit No. 173TVP01 – Healy Power Plant. Alaska 

Department of Environmental Conservation. Issued November 14, 2003. 

EPA, 2002. EPA Air Pollution Control Cost Manual, Sixth Edition. US Environmental 

Protection Agency, Office of Air Quality Planning and Standards. EPA/452/B-02-001. 

http://www.epa.gov/ttn/catc/dir1/c_allchs.pdf

Fuel Tech, 2009. Golden Valley Electric Association, Healy Station Unit 1, Conceptual 

Application of Selective Catalytic Reduction (SCR) Technology. Fuel Tech, Inc. 

Warrenville, Illinois. June, 2009.