Appendix A - Washington State Department of Ecology

i. Factor 1: Cost of Compliance
The cost effectiveness of controls is expressed in cost per
ton of pollutant reduced ($/ton). 40 CFR Part 51, App. Y,
IV.D.4.c. Cost effectiveness is calculated by first estimating
the total capital and annual costs of the BART controls. The
second step requires calculating the amounts of the pollutants
which will be reduced by the control technology selected as
BART. This second step compares the uncontrolled baseline
emissions (i.e. emissions from current operations) to the
proposed BART emissions limits. Id.
APS submitted cost estimates for all feasible control
options in January 2008 and submitted revised cost estimates for
SCR on March 16, 2009 to reflect higher costs of construction
services and materials. In our August 28, 2009 ANPRM, we
presented APS’s cost estimates for emissions controls for NOx,
which included the revised SCR costs submitted in March 2009,
and cost estimates from the National Park Service (NPS). In the
ANPRM, EPA revised the annual operating cost estimates submitted
by APS based on the ratio of annual to capital costs from other
facilities in the western United States. NPS conducted an
independent analysis strictly adhering to the EPA Control Cost
Manual and calculated significantly lower cost effectiveness. In
subsequent comments on the ANPRM, NPS submitted revised cost
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Final December 2010