UNITED STATES ENVIRONMENTAL PROTECTION AGENCY REGION 10 1200 Sixth Avenue, Suite 900 Seattle, WA 98101-3140

OFFICE OF AIR, WASTE AND TOXICS
October 1,2010

Mr. BrianFinneran Department ofEnvironmental Quality 811 SW 6th Avenue Portland, Oregon 97204

DearMr. Finneran:

We have reviewed the proposed revisions to OregonDepartment ofEnvironmental Quality's (ODEQ) 2009 Oregon Regional Haze State Implementation Plan (OR RH SIP), the proposed revisions to the ODEQ Regional Haze BestAvailable Retrofit Technology (BART) rules for the Portland General Electric (PGE) Boardman PowerPlant, and PGE's Alternative BARTproposal that
were released for public comment on September 1, 2010. TheEnvironmental Protection Agency (EPA) respectfully submits the following comments for your consideration to improve the ORRH SIP so it meets all requirements ofthe Regional Haze Rule and all applicable EPA guidance:
1. The proposed revisions to BARTrules for the PGEBoardmanfacility improperly exclude the emissions during unlimitedperiods ofstartup or shutdown from the NOx, S02 and PM emission limits (see OAR 340-223-0030(1)(d) as proposed). ODEQ's analysis has not evaluated the potential impact on visibility when the emissions during these periods are not limited, or why no limits during these periods represents BART. Forexample, the analysis accompanying the BARTrule fails to analyze the frequency or duration ofthe startup/shutdownperiods for this facility, the quantity ofemissions during these periods, or the impact that the emissions during the unlimited startup/shutdownperiods have on visibility in the Class I Areas.
2. EPA notes that PGE indicates that the Dry Sorbent Injection (DSI) S02 control is technically infeasible (PGE BARTreasonable Progress Analysis Revision 3 Boardman 2020 Alternative, p. 4-2-4-3Alternative BART Analysis). EPA agrees with ODEQ's determination (see ODEQ BART Report for the BoardmanPower Plant September 2010, p. 6) that DSI is technically feasible for the PGE Boardman facility for the control ofS02emissions. This technology has been demonstrated to be effective for controlling S02 emissions on smallerutility boilers. The onlyuncertainty, in the DSI application to the PGE Boardman facility, is the degree ofS02reduction achievable.

3. Theproposed BART rules for Boardman include three early shutdown options under which the Foster-Wheeler Boiler at the facility would permanently cease operationprior to the end ofits useful life (OAR 340-223-0050as proposed). The proposed rules provide that the
owner or operator ofthe boiler may comply with less stringent emission limits ifthey notify ODEQ, not laterthan July 1,2014, that it is electing to cease operation early, specifies which option it is selecting, and permanently ceases operation by the relevant early closure date. This approach appears reasonable as long as the early closure is permanent and enforceable. Additionally, EPA agrees with ODEQ's statement in the Announcement for the Proposed Rulemaking that choosing one ofthe early shutdown options would not preclude the owners


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4. Please evaluate the cost analysis conducted by PGE for the 2020 Boardman shutdown option (PGE'sBARTIII proposal for Boardman) and determine ifcosts specified in this proposal
are allowable according to the OAQPS Cost Control Manual, which is the preferred method for determining which costs are allowed for BART. Cost of 'replacement' power (the costto replace powergenerated by the Boardman coal-fired boiler with otherpower sources) should not be included in these costs.
5. IfODEQ intends to include an early shutdown optionfor Boardman that relies on DSI, ODEQ could considerestablishing an enforceable process for reducing the BART S02 limits, currently set at a level of0.4 Ibs/mrnBtu, based on the control level that DSI achieves during a full-scale pilottest.
6. The Announcement that accompanied the Proposed Rulemaking specifically requested comment on ODEQ'suse of$7300/ton for reducing emissions as a costeffectiveness threshold. EPA agrees that this cost effectiveness level is on the high end ofthe range used by other states. However, based on the reasons articulated by ODEQ, especially the magnitude ofvisibilityimpacts caused byemissions from the Boardman facility (the facility's significant visibility impact on visibility in 14 ClassI areas above 0.5 deciviews (dv), and 5.0 dv visibility impact at the Mt. HoodWilderness Class I area), EPA believes that $7300/ton falls within the range ofvalues that is acceptable to EPA.

7. EPAnotes that the regional haze regulations require the state to considerthe emission reductions that would be required to achieve the uniformrate ofprogress for the period covered by the implementation plan (see 40 C.P.R. 51.308(d)(1)(B). Additionally, 40 C.P.R. 51.308 (d)(l)(ii) explains that, ifa state establishes a reasonable progress goal thatprovides for a slowerrate ofimprovement in visibility than the rate that would be needed to attain natural conditions by 2064, then the State must demonstrate, based on the four factors specified in 40C.P.R. 51. 308(d)( 1 )(i)(A), that the rate ofprogress needed to attain natural conditionsby 2064 is not reasonable. Please further describe how the state has satisfied these requirements.
Ifyou have any questions on these comments, please contact Keith Rose at 206-553-1949 or Rose.Keith@epa.gov

. Sincerely,

# ~~py, Richard Albright, Director Office ofAir, Waste and Toxics

cc: David Collier, ODEQ Paul Kaprowski, 000



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