UNITED STATES ENVIRONMENTAL PROTECTION AGENCY 


REGION 10 


1200 Sixth Avenue, Suite 900 

Seattle, Washington 98101-3140 

JAN 302009 

Reply To: OA WT-107 

Mr. David Collier 

Manager, Air Quality Planning 

Oregon Department of Environmental Quality 

811 SW Sixth Avenue 

Portland, OR 97204-1390 

Re: EPA Comments on Proposed Alternatives for PGE Boardman Power Plant 

Dear Mr. Collier: 

In a letter dated December 17,2008, to Oregon Department of Environmental Quality 

(ODEQ), Portland General Electric Company (PGE) provided comments on ODEQ's 

proposed Regional Haze rulemaking. In their comments, PGE proposed an alternative to 

ODEQ's proposed BART for the PGE Boardman power plant ("Boardman"), and an 

alternative to ODEQ's proposed further reasonable progress for Boardman. Since the 

proposed alternatives may be significant changes to the emission controls for Boardman 

proposed in the rulemaking, EPA is providing the following guidance on the process 

ODEQ must follow, and issues that must be addressed, if one or both of PGE's 

alternatives for Boardman are incorporated into the Oregon Regional Haze State 

Implementation Plan ("RH SIP"). 

1) PGE's proposed a BART alternative of shutting down the Foster-Wheeler boiler at the 

Boardman facility in 2020 instead of installing Semi-Dry Flue Gas Desulfurization 

(SDFGD), which ODEQ proposed as BART for S02 at Boardman. As explained in the 

BART Guidelines, a BART alternative that considers an enforceable permit limit to 

permanently cease operation may be considered. (See 40 C.ER. Part 51, Appendix Y, 

Section IV(D)(4)(k)). However, as with any BART analysis, all five BART factors still 

must be evaluated. For example, the analysis should include identification and evaluation 

of emission control alternatives, not just a cost effectiveness analysis of one control 

option. The remaining useful life of a source is but one of the factors the state considers 

in determining "the best system of continuous emission reduction" for the particular 

source. The PGE proposal appears lacking in this regard. 

The process for including PGE's alternative BART for Boardman into the RH SIP would 

be the same as the process for including ODEQ's proposed BART for Boardman into the 

RH SIP. Also, in accordance with the Regional Haze Rule, BART needs to be installed 

as expeditiously as practicable, but no later than 5 years after EPA approval of the RH 

SIP (40 CFR Part 51.308(e)(1)(iv)). This is the case regardless of whether 
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BART is based on a shorter useful source life or not. In other words, no matter· which 

alternative PGE decides to implement, BART for that alternative, as identified in the RH 

SIP, must be installed as expeditiously as possible, but no later than 5 years after 

approval of the RH SIP. 

2) PGE proposed an alternative to further reasonable progress that would allow 

Boardman to shut down in 2029 instead of installing Selective Catalytic Reduction (SCR) 

for further NOxcontrol in 2017. EPA is concerned that this option would allow 

Boardman to operate for an additional 12 years (2017-2029) without further NOx 

controls. EPA recommends that if ODEQ allows this option, PGE should be required to 

shut down the Boardman facility as soon as possible after PGE makes the decision not to 

install SCR at Boardman. This would allow the impacted Class I areas to attain the 

visibility "glidepath", identified in the Regional Haze Rule, in the shortest possible time. 

3) The public should be provided notice and opportunity to comment on the regulations 

that ODEQ intends to propose to EPA as its Regional Haze SIP. Therefore, additional 

public notice and opportunity to comment should be provided if any of the above 

alternatives are considered to be a significant change to ODEQ's proposed BART 

determination or further reasonable progress for Boardman, as proposed by ODEQ in the 

current public comment period. 

Enclosed are EPA's technical comments on PGE's proposed alternatives for Boardman. 

If you would like discussing our concerns with you, please contact me at (206) ~53-6985. 

Sincerely, 

r ~~ Mahbubul Islam, Manager 

State and Tribal Program Unit 

Office of Air, Waste and Toxics 

Enclosure 

Cc: 	 Brian Finneran, ODEQ 

Rick Graw, USFS 

Elizabeth Wadell, NPS 

Bruce Polkowsky, NPS 

Paul Koprowski, 000 

Julie Matthews, ORC 
Enclosure 1 

EPA Comments on POE's Proposed Options for the 

Boardman Power Plant 

1. 	 Page 3. In the last sentence of the second to last paragraph in section 1, POE states 

that "These controls (SCR) were demonstrated notto constitute BART due to their 

extreme cost and their limited effectiveness in addressing visibility impacts." Even 

though ODEQ did not propose SCR as BART, they did propose SCR to ensure 

future reasonable progress because SCR results in significant visibility 

improvement in the Class I areas impacted by emissions from the Boardman Power 

Plant. 

2. 	 Page 7 and 13. The attempt ofjustifying operation of the Boardman facility after 

2014 without installation of controls representative of BART for S02 (SDFOD) by 

comparing the aggregate emissions under various facility life cycle times is 

somewhat deceptive because the "benefits" of zero emissions after facility 

shutdown come. in the distant years whereas no improvements (emissions reduction 

and corresponding visibility improvement) are achieved until the shutdown date. 

The analysis also does not address the emissions from any electrical generation 

facility needed to replace the power from the shutdown Boardman facility. A 

similar comment applies to the table of aggregate emissions shown on page 13 

based on a shutdown date of 2029. 

3. 	 Page 10. In a statement similar to the one on page 3 (item 1 above), POE states that 

"The technology is not cost-effective, does not provide material benefits to 

visibility in the mandatory Class 1 areas and has material non-air quality 

environmental impacts." Again, even though ODEQ did not propose SCR as 

BART, they did propose SCR to ensure future reasonable progress because SCR 

results in significant visibility improvement in the Class I areas impacted by 

emissions from the Boardman Power Plant. 

4. 	 Page 12. POE states that "The cost-effectiveness of the SCR based on a useful life 

of 12.5 years (Le., the number of years after July 1, 2017 that the control would be 

operated if the plant had to close by the end of 2029) is over $7,300 per ton of NOx 

removed." The cost effectiveness value of $7,300 per ton of NOx removed is 

actually the incremental cost effectiveness value of SCR compared not to the 

baseline, but to the installation of low NOx burners and overfire air ports 

(LNB/OFA). However, the cost effectiveness of SCR alone compared to the 

baseline was not presented. Another important cost effectiveness value for decisionmakers to consider is the cost effectiveness of the total NOx control package 

(LNB/OFAJSCR) using the shorter life (12.5 years) in the capital recovery portion 

of the calculation for SCR and comparing that to the baseline case. I estimate the 

cost effectiveness of the LNB/OFAJSCR option compared to baseline to be about 

$3,709 per ton of NOx removed (based on a 12.5 year life for SCR, but using the 

ODEQ annual cost value for LNB/OFA of $3.718 million which is based on 20 year 

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life). Since the SCR annual cost of $28.347 million is much larger than the annual 

cost of LNB/OFA, the error introduced by not recalculating the capital recovery 

cost of the LNB/OFA portion is small. In any case, there is a significant difference 

between the total cost effectiveness value of about $3,709 and the incremental cost 

effectiveness value of $7,300. 

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