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. Brian Finneran 

Department of Environmental Quality 

811 SW 6th Avenue 

Portland, Oregon 97204 

Dear Mr. Finneran: 

We have reviewed the proposed revisions to Oregon Department of Environmental Quality's 

(ODEQ) 2009 Oregon Regional Haze State Implementation Plan (OR RH SIP), the proposed 

revisions to the ODEQ Regional Haze Best Available Retrofit Technology (BART) rules for the 

Portland General Electric (PGE) Boardman Power Plant, and PGE's Alternative BART proposal that 

were released for public comment on September 1, 2010. The Environmental Protection Agency 

(EPA) respectfully submits the following comments for your consideration to improve the OR RH 

SIP so it meets all requirements of the Regional Haze Rule and all applicable EPA guidance: 

1. 	 The proposed revisions to BART rules for the PGE Boardman facility improperly exclude the 

emissions during unlimited periods of startup 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. For example, the analysis 

accompanying the BART rule fails to analyze the frequency or duration of the 

startup/shutdown periods for this facility, the quantity of emissions during these periods, or 

the impact that the emissions during the unlimited startup/shutdown periods 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 BART reasonable 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 Boardman Power Plant September 2010, p. 6) that DSI is technically 

feasible for the PGE Boardman facility for the control of S02 emissions. This technology 

has been demonstrated to be effective for controlling S02 emissions on smaller utility 

boilers. The only uncertainty, in the DSI application to the PGE Boardman facility, is the 

degree of S02 reduction achievable. 

3. 	 The proposed BART rules for Boardman include three early shutdown options under which 

the Foster-Wheeler Boiler at the facility would permanently cease operation prior to the end 

of its useful life (OAR 340-223-0050 as proposed). The proposed rules provide that the 

owner or operator of the boiler may comply with less stringent emission limits if they notify 

ODEQ, not later than 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 of the early shutdown options would not preclude the owners 

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of the facility from constructing a new facility at the Boardman site, so long as all regulations 

and laws are complied with including, but not limited to, new source review permitting 

requirements for a new facility and new source performance standards. 

4. 	 Please evaluate the cost analysis conducted by PGE for the 2020 Boardman shutdown option 

(PGE's BART III proposal for Boardman) and determine if costs 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 cost to 

replace power generated by the Boardman coal-fired boiler with other power sources) should 

not be included in these costs. 

5. 	 If ODEQ intends to include an early shutdown option for Boardman that relies on DSI, 

ODEQ could consider establishing an enforceable process for reducing the BART S02 

limits, currently set at a level of 0.4 Ibs/mrnBtu, based on the control level that DSI achieves 

during a full-scale pilot test. 

6. 	 The Announcement that accompanied the Proposed Rulemaking specifically requested 

comment on ODEQ's use of $7300/ton for reducing emissions as a cost effectiveness 

threshold. EPA agrees that this cost effectiveness level is on the high end of the range used 

by other states. However, based on the reasons articulated by ODEQ, especially the 

magnitude of visibility impacts caused by emissions from the Boardman facility (the 

facility's significant visibility impact on visibility in 14 Class I areas above 0.5 deciviews 

(dv), and 5.0 dv visibility impact at the Mt. Hood Wilderness Class I area), EPA believes 

that $7300/ton falls within the range of values that is acceptable to EPA. 

7. 	 EPA notes that the regional haze regulations require the state to consider the emission 

reductions that would be required to achieve the uniform rate of progress 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, if a state establishes a reasonable progress goal that provides 

for a slower rate of improvement 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 40 C.P.R. 51. 308( d)( 1 )(i)(A), that the rate of progress needed to attain natural 

conditions by 2064 is not reasonable. Please further describe how the state has satisfied these 

requirements. 

If you 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 of Air, Waste and Toxics 

cc: 	 David Collier, ODEQ 

Paul Kaprowski, 000 

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