January 7, 2009

Reply to

Attn Of: OEA-095

MEMORANDUM

SUBJECT: Comments on the PGE Letter to ODEQ dated December 17, 2008

FROM: Paul Boys, P.E.

Environmental Engineer, ESU, OEA

TO: Keith Rose, Environmental Scientist

State and Tribal Air Programs Unit, OAWT

As you requested, I have reviewed the PGE letter to ODEQ dated December 

17, 2008 regarding their preliminary comments on the proposed regional haze rules. 

You had asked for comments on the PGE letter by January 9, 2009. Since I’ll be out 

of the office most of the next two weeks I wanted to get you the comments I have on 

the letter at this time so that you could consider them prior to communicating with 

ODEQ. My comments are listed below. 

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

PGE states that “These controls (SCR) were demonstrated not to constitute 

BART due to their extreme cost and their limited effectiveness in addressing 

visibility impacts.” This statement may represent the opinion of PGE, but not 

necessarily ODEQ or EPA. Even though ODEQ did not propose SCR as 

BART, they did propose SCR to ensure future reasonable progress. I think 

the ODEQ report demonstrated that SCR would result in significant visibility 

improvement. 

2. Page 5. As an argument to support continued operation of the PGE 

Boardman power plant until the year 2020 without installing the SDFGD 

system determined to represent BART, PGE presents the cost effectiveness 

for this one option (a 2020 shutdown date) and concludes that the $5200 per 

ton of SO2 removed is high enough to justify not installing the SDFGD. 

Assuming it is proper to even consider operating the facility without BART 

controls after the date that ODEQ determined in the BART analysis, a more 

appropriate analysis would be to present a series of cost effectiveness 
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calculations for each year beyond 2014 so that the decision makers could see 

how the cost effectiveness values vary by the proposed shutdown date (as 

reflected in the life of the control equipment in the capital recovery factor 

calculation). It is quite likely that the decision makers may find that some date 

other than 2020 would represent the point at which the cost effectiveness 

value becomes “too large” to justify the commitment of capital investment for 

the SDFGD. 

3. Page 7 and 13. The attempt of justifying operation of the Boardman facility 

after 2014 without installation of controls representative of BART for SO2

(SDFGD) 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.

4. Page 10. In a statement similar to the one on page 3 (item 1 above), PGE 

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, this statement may represent the 

opinion of PGE, but not necessarily ODEQ or EPA. Even though ODEQ did 

not propose SCR as BART, they did propose SCR to ensure future 

reasonable progress. I think the ODEQ report demonstrated that SCR would 

result in significant visibility improvement. 

5. Page 12. PGE states that “The cost-effectiveness of the SCR based on a 

useful life of 12.5 years (i.e., 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.” This cost effectiveness value seemed high 

to me, so I obtained the Table 1 associated with the PGE December 17, 2008 

letter from the ODEQ web site. 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). I checked the calculations in Table 1 and 

found them to be accurate. However, the cost effectiveness of SCR alone 

compared to the baseline was not presented. Another important cost 

effectiveness value for decision makers to consider is the cost effectiveness 

of the total NOx control package (LNB/OFA/SCR) 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/OFA/SCR 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 
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cost value for LNB/OFA of $3.718 million which is based on 20 year 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. 

6. Page 12. Similar to the comment in item 2 above, it would be informative for 

PGE to present a series of cost effectiveness calculations for each year 

beyond 2017 so that the decision makers could see how the cost 

effectiveness values vary by the proposed shutdown date (as reflected in the 

life of the control equipment in the capital recovery factor calculation). It is 

quite likely that the decision makers may find that some date other than 2029 

would represent the point at which the cost effectiveness value becomes “too 

large” to justify the commitment of capital investment for the SCR.

If you have any questions about these comments, please call me at 3-1567. 

cc. John Keenan, OCE

Keven McDermott, OEA