Western Resource Advocates (WRA) is asking that the Utah Public Service Commission review or rehear a May 10 approval for PacifiCorp to charge to its Utah customers some of the costs for new selective catalytic reduction (SCR) NOx controls on the coal-fired Jim Bridger Units 3 and 4 in Wyoming.
WRA noted in its June 10 request, which the commission had not acted on as of June 19, that it had argued during the course of this case that an economic alternative was to acquire a gas-fired replacement for one of the Jim Bridger units, along with significantly less expensive controls on the other. That would be similar to an outcome tentatively agreed to by the U.S. Environmental Protection Agency for the coal-fired San Juan Generating Station in New Mexico.
WRA said that a PacifiCorp witness testified that the company never explored the possibility of an alternative involving a conversion to natural gas of one unit and installation of less expensive, and less effective, selective non-catalytic reduction (SNCR) control technology at the second unit. According to PacifiCorp, SNCR technology would be 7 to 10 times less expensive than SCR. The company neglected to explore this alternative because of its view that such a combination of features would not be compliant with the Clean Air Act, WRA said.
“If PacifiCorp proceeds to install SCR on the two Bridger units when a less expensive compliance path could be available to it, there is certainly a prudence issue associated with the project,” WRA argued. “The Commission would be remiss in preapproving a project that neglected to consider such an obvious alternative. In fact, to protect the public interest, WRA believes the Commission should instruct PacifiCorp to approach EPA and the State of Wyoming about exactly such an alternative compliance path.”
The Utah commission, WRA noted, addressed this issue by summarily stating in its May 10 approval: “WRA, through its legal counsel, also introduced at hearing an agreement between the EPA, Public Service Company of New Mexico, and the state of New Mexico regarding the installation of selective non-catalytic reduction technology on the San Juan Generation Station’s (‘SJGS’) Units 1 and 4 and the retirement of SJGS Units 2 and 3. WRA questions whether a similar approach would be applicable to Bridger units and whether the parties had enough time to investigate this option in the analysis. No WRA witness offered testimony regarding this option.”
WRA says recent events support the unit shutdown option
Recent events and developments appear to indicate that EPA would indeed be open to considering a SNCR/repowering alternative to installing SCR at Bridger, WRA said. Specifically, it added:
- In a March 9 report in the Albuquerque Journal, EPA Region 6 Administrator Curry confirmed that EPA views the San Juan outcome as a collaborative model that it intends to develop and adopt elsewhere;
- On June 6 in Arizona, EPA Region 9 confirmed that it will reconsider its SCR requirements at the Apache coal plant, and instead consider repowering one unit with natural gas and installing less expensive SNCR at the second unit;
- On June 10, the day it filed this appeal with the Utah commission, WRA sent a letter to newly appointed EPA Region 8 Administrator Shaun McGrath asking him to confirm that EPA would consider an alternative for Bridger that included retirement or repowering, and SNCR controls.
Given these developments, WRA believes the public interest can only be served if the Utah commission reconsiders its May 10 decision, and denies pre-approval of PacifiCorp’s request to install SCR controls at Bridger Units 3 and 4, WRA said.
PacifiCorp was prompted to make NOx cuts at Bridger due to a settlement agreement in November 2010 with the Wyoming Department of Environmental Quality in a regional haze Best Available Retrofit Technology (BART) case. To achieve the required NOx emission limits, the company said it needs to install SCR systems or alternative add-on NOx control systems on Unit 3 by the end of 2015 and by the end of 2016 for Unit 4.
The Wyoming Public Service Commission on May 29 approved a Certificate of Public Convenience and Necessity for Rocky Mountain Power (the doing business name for PacifiCorp in Wyoming) for the construction of SCR on Jim Bridger Units 3 and 4. The Jim Bridger plant is located near Point of Rocks, Wyo., and is two thirds owned by PacifiCorp and one-third owned by Idaho Power. Those two parties also co-own in those same proportions adjacent surface and deep coal mines that supply the plant with much of its coal. The plant’s total generating capability is 2,120 MW, with 1,411 MW of that controlled by PacifiCorp.