33

BACT option for the proposed WCFU, even if reductions of all pollutants are summed together

and then the annualized cost in dollars-per-ton for emission reduction is calculated on that basis.

(As shown above, summing the pollutants yields $20,583/ton, which is a lower dollar-per-ton

BACT cost than looking at any one pollutant individually.)

The same annualized dollar-per-ton costs would be incurred if there was only a partial

switch to alternative coal from another mine (i.e., coal blending). This is because a partial switch

yields only partial emission reductions.

Regarding comparison to the cost of BACT that other similar sources have to bear (which

EPA believes is best evaluated in terms of dollars per ton of additional pollutant removed, not

simply in terms of what other sources pay for their coal as commenters on the draft WCFU

permit have suggested), EPA is not aware of any BACT determination for a CFB boiler project

anywhere in the U.S. where incremental cost effectiveness as high as $20,583/ton (the EPAcalculated economic cost for using coal from an alternative mine rather than waste coal from the

Deserado mine), or as high as $20,241/ton (the EPA-calculated economic cost for using ROM

coal from the Deserado mine rather than waste coal from the Deserado mine) has been

considered reasonable for BACT for any pollutants, regardless of the type of BACT option being

considered.

Although EPA considers the economic, energy and environmental costs associated with

use of alternative coal for Deseret Power’s project to be clearly excessive for BACT, EPA has

nevertheless looked at some recent BACT determinations by other permitting authorities for

similar projects, for purposes of comparison. EPA found the following:

1) In a PSD permit action in mid 2006 for Longleaf Energy Associates LLC, Longleaf

Energy Station project, Georgia indicated that incremental cost effectiveness of

$8,964/ton, comparing dry scrubbing to wet scrubbing for SO2 control at a pulverized

coal fired electric utility boiler, was excessive for BACT. Incremental and average cost

effectiveness of the selected BACT option (dry scrubbing) was listed as $724/ton.

(Ref: Georgia’s Preliminary Determination for SIP Permit Application #15846, page 62,

dated July 2006, available online at:

http://www.air.dnr.state.ga.us/airpermit/psd/dockets/longleaf/permitdocs/0990030pd.pdf.

2) In a PSD permit action in early 2007 for Southern Montana Electric Generation and

Transmission Cooperative’s CFB boiler project (Highwood Generating Station), Montana

indicated that a “cost effective value” of $27,365/ton for SO2 control, for a control option

employing a combination of limestone injection, low-sulfur coal and wet flue gas

desulfurization (FGD), was excessive for BACT. Montana also indicated that a “cost

effective value” of $7,939/ton for SO2 control, for a control option employing a

combination of limestone injection, low-sulfur coal and dry FGD, was excessive for

BACT.
34

The selected BACT option for SO2 control, with a “cost effective value” of $4,054/ton,

employed a combination of limestone injection, low-sulfur coal, and hydrated ash

reinjection. Montana did not indicate whether “cost effective value” means incremental

cost effectiveness or total cost effectiveness.

(Ref: Montana’s “Permit Analysis” for Air Quality Permit #3423-00, page 23, dated May

30, 2007, obtained from the Montana Department of Environmental Quality Air

Resources Management Bureau, Helena, Montana.)

3) In a PSD permit action in early 2005 for Rocky Mountain Power Inc.’s Hardin project,

Montana indicated that incremental cost effectiveness of $23,855/ton, comparing dry

FGD/spray dry absorber to wet FGD for SO2 control, at a pulverized coal fired electric

utility boiler, was excessive for BACT. Average cost effectiveness of wet FGD was

listed as $1,395/ton. Average cost effectiveness of the selected BACT option (dry

FGD/spray dry absorber) was listed as $918/ton.

(Ref: Montana’s Permit Analysis for Hardin project, Permit #3185-02, pages 15 and 17,

dated May 16, 2005, obtained from Montana Air Resources Management Bureau, in the

Montana Department of Environmental Quality.)

4) In a PSD permit action in late 2006 for Cargill’s Blair corn milling and ethanol

production plant, Nebraska indicated that incremental cost effectiveness of $5,900/ton,

comparing limestone injection alone to limestone injection plus dry FGD, for SO2 control

at a CFB boiler, was excessive for BACT.

(Ref: Nebraska permit action CP06-0008, page 12 of Fact Sheet, dated September 8,

2006, available online at

http://www.epa.gov/region07/programs/artd/air/nsr/archives/2006/finalpermits/

cargill_blair_final_psd_permit.pdf.)

5) In a PSD permit action in late 2006 for ADM’s Columbus corn milling and ethanol

production plant, Nebraska indicated that incremental cost effectiveness of $5,600/ton for

NOx control (comparing Selective Non-Catalytic Reduction (SNCR) at 0.07 lb/MMBtu to

SNCR at below 0.07), and incremental cost effectiveness of $6,700/ton for

SO2/H2SO4/HF control (comparing limestone injection to “additional” limestone

injection) at a CFB boiler, were excessive for BACT. Nebraska listed incremental costeffectiveness of $2,174 for the selected BACT option for NOx control (SNCR at 0.07

lb/MMBtu). Nebraska also listed average cost-effectiveness of $5,200/ton for the

selected BACT option for VOC control at the CFB boiler (wet scrubbing/packed tower),

(Ref: Nebraska permit action CPM02-0006, page 14 of Appendix B of Fact Sheet; pages

8, 9, 19 and 20 of Appendix D of Fact Sheet, dated August 4.2006, available online at:

http://www.epa.gov/region07/programs/artd/air/nsr/archives/2006/finalpermits/

adm_columbus_final_psd_permit.pdf.)
35

6) In a PSD permit in early 2005 for Montana-Dakota Utilities/Westmoreland Power,

Gascoyne Generating Station project, North Dakota indicated that incremental cost

effectiveness of $14,339/ton, comparing Selective Catalytic Reduction (SCR) at 0.04

lb/MMBtu to SNCR at 0.09 lb/MMBtu, for NOx control at a CFB boiler, was excessive

for BACT. Average cost effectiveness of SCR was listed as $7,545/ton. Average and

incremental cost effectiveness of the selected BACT option (SNCR) was listed as

$2,926/ton.

(Ref: North Dakota’s Permit Application Analysis for Gascoyne Project, pages 65 and

68, dated March 2005, obtained from the North Dakota Department of Health,

Environmental Health Section, Air Quality Division, Bismarck, ND.)

7) In a PSD permit action in early 2004 for Red Trail Energy’s Richardton, ND, ethanol

production plant, North Dakota listed incremental cost effectiveness of $10,252/ton,

comparing wet FGD plus limestone injection to dry FGD (spray dryer absorber) plus

limestone injection, for SO2 control at a CFB boiler. Average cost effectiveness of wet

FGD plus limestone injection was listed as $1,041/ton. Average cost effectiveness of dry

FGD plus limestone injection was listed as $527/ton. North Dakota rejected wet FGD

and determined that BACT is represented by dry FGD plus limestone injection.

(Ref: North Dakota’s Permit Application Analysis for Red Trail Energy project, pages 38

and 40, dated May 2004, obtained from the North Dakota Department of Health,

Environmental Health Section, Air Quality Division, Bismarck, ND.)

8) In a PSD permit action in early 2005 for River Hill Power Company’s CFB boiler

project, Pennsylvania indicated that incremental cost effectiveness of $15,975/ton,

comparing use of the waste coal proposed by the permit applicant to use of the nearest

alternative source of coal with lower sulfur content, for SO2 control at the CFB boiler,

was excessive for BACT.

Pennsylvania also indicated that all SO2 BACT options involving wet FGD systems

“were economically infeasible at an incremental dollar per ton value greater than $5,000

per ton of SO2 removed.”

Pennsylvania concluded that use of a spray dryer absorber or flash dryer absorber (i.e., dry

FGD) was “economically feasible for the control of SO2 at an incremental cost of

$1,511.01 per ton of SO2 removed.”

(Ref: Pennsylvania’s “Plan Approval Application Review Memo, Plan Approval

Application #17-00055A,” pages 10-11, dated May 2, 2005, obtained from the

Commonwealth of Pennsylvania, Department of Environmental Protection, Northcentral

Region, Air Quality Program.)
36

9) In a PSD permit action in early 2005 for Wellington Development’s Greene Energy

Resource Recovery Project, Pennsylvania indicated that incremental cost effectiveness of

at least $20,000/ton, comparing use of the waste coal proposed by the applicant to precombustion cleaning of the waste coal (excluding additional coal disposal costs after

cleaning of the waste coal), for SO2 control at the CFB boiler, was excessive for BACT.

Pennsylvania also indicated that overall cost effectiveness of $5,764/ton, for limestone

injection plus wet FGD for SO2 control at the CFB boiler, was excessive for BACT.

(Ref: Pennsylvania’s “Comment and Response Document,” Air Quality File PA-30-

00150A, page 6, dated June 21, 2005; Table 5-4 of PSD Permit Application, prepared by

ENSR International, August 2004, page 5-29. Both documents were obtained from the

Commonwealth of Pennsylvania, Department of Environmental Protection, Southwest

Regional Office, Air Quality Program.)

10) In a PSD permit action in early 2004 for Intermountain Power’s Unit 3 project, Utah

indicated that incremental cost effectiveness of about $14,000/ton to $16,350/ton,

comparing different types of baghouse fabric filter bags (Ryton-type bags versus specialty

coated bags) for PM/PM10 control at a pulverized coal fired electric utility boiler, was

excessive for BACT. Average cost effectiveness of the selected BACT option for PM10

control (a baghouse with Ryton-type bags) was $31/ton.

(Ref: Utah’s Modified Source Plan Review for IPP3 project, pages 132-133, dated March

22, 2004, available online at:

http://www.airquality.utah.gov/Permits/PmtPowerPlants.htm.)

11) In a PSD permit action in early 2007 for Basin Electric’s Dry Fork Station project (a

pulverized coal-fired electric utility boiler),Wyoming indicated that incremental cost

effectiveness of $23,755/ton for NOx control (comparing Selective Catalytic Reduction

(SCR) at 0.043 lb/MMBtu to SCR at 0.040 lb/MMBtu) was excessive for BACT.

Average cost effectiveness for SCR at 0.040 lb/MMBtu was listed as $2,004/ton.

Average cost effectiveness for SCR at 0.043 lb/MMBtu was listed at $1,751/ton.

Although Wyoming determined that incremental cost effectiveness of $10,303/ton was

reasonable for SCR at 0.043 lb/MMBtu, for other reasons described by Wyoming the

selected BACT option for NOx control was SCR at 0.05 lb/MMBtu, with incremental cost

effectiveness of $3,512/ton and average cost effectiveness of $1,511/ton.

Wyoming also indicated that incremental cost effectiveness of $15,299/ton for SO2

control (comparing dry FGD/spray dry absorber at 0.073 lb/MMBtu to wet FGD at 0.054

lb/MMBtu), was excessive for BACT. Average cost effectiveness of wet FGD at 0.054

lb/MMBtu was listed as $1,595/ton.
37

Although Wyoming determined that incremental cost effectiveness of $9,296/ton was

reasonable for a spray dry absorber at 0.043 lb/MMBtu, for other reasons described by

Wyoming the selected BACT option for SO2 control was a spray dry absorber at 0.08

lb/MMBtu, with average cost effectiveness of $1,159/ton; no incremental cost

effectiveness listed by Wyoming for this BACT option..

(Ref: Wyoming’s Permit Application Analysis for the Dry Fork project, NSR-AP-3546,

pages 6, 7, 8, 10 and 11, dated February 5, 2007, obtained from Wyoming Air Quality

Division, Cheyenne, WY.)

12) In a PSD permit action in early 2002 for Black Hills Power & Light’s WYGEN2

project, Wyoming indicated that incremental cost effectiveness of $7,742/ton, comparing

low-NOx burners plus SCR at 0.06 lb/MMBtu to low-NOx burners plus SCR at 0.08

lb/MMBtu, for NOx control at a pulverized coal fired electric utility boiler, was

reasonable for BACT. However, for other reasons described by Wyoming, the selected

BACT option was low-NOx burners plus SCR at 0.07 lb/MMBtu, with “total” (i.e.,

average) cost effectiveness somewhere between $4,067/ton (the average cost

effectiveness to achieve 0.08 lb/MMBtu) and $4,156/ton (the average cost effectiveness

to achieve 0.06 lb/MMBtu).

(Ref: Wyoming’s Permit Application Analysis for the WYGEN2 project, NSR-AP-92,

page 7, dated April 24, 2002, obtained from Wyoming Air Quality Division, Cheyenne,

WY.)

13) In a PSD permit action in late 2006 for Black Hills Power & Light’s WYGEN3

project, Wyoming indicated that incremental cost effectiveness of $14,609/ton,

comparing a baghouse with fiberglass or polyphenylene sulfide filter bags (listed as

capable of achieving 0.012 lb/MMBtu) to a baghouse with specialty filter bags such as

Teflon (listed as capable of achieving 0.011 to 0.010 lb/MMBtu), for PM/PM10 control at

a pulverized coal fired electric utility boiler, was excessive for BACT.

Average cost effectiveness of the selected BACT option (a baghouse with fiberglass or

polyphenylene sulfide filter bags) was listed as $130/ton. Average cost effectiveness of a

baghouse with specialty filter bags was listed as $134/ton.

(Ref: Wyoming’s Permit Application Analysis for the WYGEN3 project, NSR-AP-3934,

pages 10 and 11, dated October 9, 2006, obtained from Wyoming Air Quality Division,

Cheyenne, WY.)

The pages cited above, for each of the 13 examples, are included in the Administrative

Record for issuance of the final Deseret WCFU permit.