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 QualityPlanning Oregon Department ofEnvironmental Quality 811 SW Sixth Avenue Portland, OR97204-1390

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

DearMr. Collier:

In a letter dated December 17,2008, to Oregon Department ofEnvironmental Quality (ODEQ), Portland General Electric Company (PGE) provided comments on ODEQ's proposed Regional Haze rulemaking. In their comments, PGEproposed an alternative to ODEQ's proposed BART for the PGEBoardman power plant ("Boardman"), and an alternative to ODEQ'sproposed 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 onthe process ODEQ must follow, and issues that mustbe addressed, ifone orboth ofPGE's alternatives for Boardman are incorporated into the Oregon Regional Haze State Implementation Plan ("RH SIP").

1) PGE's proposed a BART alternative ofshutting down the Foster-Wheelerboiler at the Boardman facility in 2020 instead ofinstalling Semi-Dry Flue Gas Desulfurization (SDFGD), which ODEQ proposed as BARTfor S02 at Boardman. As explained in the BART Guidelines, a BART alternative that considers an enforceable permitlimit 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
mustbeevaluated. For example, the analysis should include identification and evaluation ofemission control alternatives, notjust a cost effectiveness analysis ofone control option. The remaining useful life ofa source is but one ofthe factors the state considers in determining "the best system ofcontinuous emission reduction" for the particular

source. The PGEproposal appears lacking inthis 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, BARTneeds to be installed

as expeditiously as practicable, but no laterthan 5 years afterEPA approval ofthe RH SIP (40 CFR Part 51.308(e)(1)(iv)). This is the case regardless ofwhether2

BART is based on a shorteruseful source life or not. Inother 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 ofthe RH SIP.

2) PGE proposed an alternative to further reasonable progress that would allow Boardman to shut down in 2029 instead ofinstalling 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 ifODEQ 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 ifany ofthe above alternatives are considered to be a significant change to ODEQ'sproposed BART determination orfurther 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. Ifyou 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 ofAir, Waste and Toxics

Enclosure

Cc: Brian Finneran, ODEQ Rick Graw, USFS Elizabeth Wadell, NPS Bruce Polkowsky, NPS Paul Koprowski, 000 Julie Matthews, ORCEnclosure 1

EPA Comments on POE's Proposed Options for the Boardman PowerPlant

1. Page 3. Inthe last sentence ofthe second to lastparagraph in section 1, POE states that "These controls (SCR) were demonstrated notto constitute BARTdue 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 SCRresults in significant visibility improvement in the Class I areas impacted by emissions from the Boardman Power Plant.

2. Page 7 and 13. The attempt of justifying operation ofthe Boardman facility after 2014 without installation ofcontrols representative ofBART for S02 (SDFOD) by comparing the aggregate emissions under various facility life cycle times is somewhat deceptive because the "benefits" ofzero 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 similarcomment applies to the table ofaggregate emissions shown on page 13 based on a shutdown date of2029.

3. Page 10. In a statement similar to the one on page 3 (item 1above), POE states that "Thetechnology 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 didpropose SCRto ensure future reasonable progress because SCR results in significant visibility improvement in the Class I areas impacted by emissions from the Boardman PowerPlant.

4. Page 12. POE states that "Thecost-effectiveness ofthe SCR based on a useful life of 12.5 years (Le., the numberofyears afterJuly 1, 2017 that the control would be operated ifthe plant had to close by the end of2029) is over$7,300 per ton ofNOx removed." The cost effectiveness value of$7,300per ton ofNOx removed is actually the incremental costeffectiveness value ofSCRcompared not to the baseline, but to the installation oflow NOx burners and overfire airports (LNB/OFA). However, the cost effectiveness ofSCR alone compared to the baseline was not presented. Another important cost effectiveness value for decisionmakers to consideris the costeffectiveness ofthe total NOxcontrol package (LNB/OFAJSCR) using the shorter life (12.5 years) in the capital recovery portion ofthe calculation for SCR and comparing that to thebaseline case. I estimate the cost effectiveness ofthe LNB/OF AJSCR option compared to baseline to be about $3,709 perton ofNOxremoved (based on a 12.5 year life for SCR, but using the ODEQannual cost value for LNB/OF A of$3.718 million which is based on 20 year

1life). Sincethe SCRannual cost of$28.347 million is much larger than the annual
cost ofLNB/OF A, the errorintroduced by not recalculating the capital recovery cost ofthe LNB/OF A portion is small. 

### In any case, there is a significant difference between the total cost effectiveness value ofabout $3,709 and the incremental cost effectiveness value of$7,300.

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