# Presentation: 856276

## Pb RIA Analysis

- Update for OMB
- 4-04-08

## Purpose: to discuss the RIA analysis

- Benefits methodology
- Cost analysis
- Identified controls
- Unidentified controls
- Conclusions

## Benefits Methodology

- [ see attached Word file]

## Air Quality and Cost for Point Sources

- Distance weighted ambient impacts of emissions within 10 km of the design value monitor:
- List out all point sources within this predetermined distance from design value monitors;  sort by source type, and estimate % contribution to monitor violation
- Least cost optimization of reductions needed from each source type to get monitors to NAAQS levels
- The range of controls would include fabric filters, ESPs, wet suppression of dust or ash, covering coal or dust piles, etc. – but for sources down to 0.05 tons/year emissions (i.e. 100 lbs/year).
- This analysis does not include potential controls on piston-engine aircraft operating on leaded aviation gasoline
- Marginal cost cap for emission controls set at $27 million/ ton (1999$)
- Note:  just for comparison –at an ambient standard of 0.1:
-  $27M cost cap for Pb is roughly equivalent to a cap of $178,000 / ton for PM2.5, if all the PM2.5 consisted of Pb.  [0.1 ug/m3 is about .0066 the size of 15 ug/m3 PM2.5.]
**So....why are $/ton so high?**
- Small fraction of PM comprised by Pb (varies; avg is 1.1% of total PM)
- We’re controlling relatively small sources

## Top 10 Lead Emitting SCs within 10 km of Monitor > 0.05

**Top 10 Lead Emitting SCs within 10 km of Monitor > 0.05**

- Primary Lead:
- (59 tons, 34%)

- Secondary Lead
-  (33 tons, 19.5%)

- Int. Iron + Steel
- (20 tons, 11%)

-  1o Non-ferrous
-   (6 tons, 3.5%)

-  1o Copper
-  (4.4 tons, 3%)

-  MWCs
-  (4 tons, 2.4%)

-  Foundries
-  (2.3 t, 1.3%)

-   SSIs
-   (2 tons, 1%)

- Ind. Machine &
- Equip: Finishing
- (1.2 tons, 0.7%)

- All Other categories
- (32 tons, 19%)

- Notes:  Lead Emissions Estimates based on 2002 NEI.  SCs = Source Categories
- SSIs = Sewage Sludge Incinerators,  MWC = Municipal Waste Combustors

- Total = 169 tons

-  Utility Boilers
-  (3.2 tons, 2%)

## Identified Controls

## Control Summary for Top 10 Industry Groups

| SIC | Major Sources
(Name: tons/year) | Description | Baseline 
Emissions
(annual 
tons/year) | Emissions potentially reduced by Identified Controls 
under cost cap |  |  Actual 
Reductions 
Needed 
(0.1 std) | # 
Emission
Points | # Emission Points
Potentially
controlled 
under cost cap |  | Actual
Sources
Controlled
(0.1 std) |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  |  |  |  | Current 
Cap | No Cap |  |  | 
Cap | No Cap |  |
| 333 | Herculaneum: 47.7
UT Smelter & Refinery: 4.4 | Primary Lead 
Smelters  | 58.18 | 14.93 | 15.34 | 11.15 | 78 | 49 | 49 | 40 |
| 334 | Buick: 12.3 tons, Sanders Lead Co.: 4.0, 
Gopher Resource Group: 3.1 | Secondary Lead 
Smelters  | 34.19 | 32.80 | 33.10 | 30.50 | 122 | 84 | 86 | 70 |
| 10 | Brushy Creek Mine/Mill: 15.4 tons | Copper Mines  | 15.44 | 0.00 | 0.00 | 0.00 | 1 | 0 | 0 | 0 |
| 331 | Oil Technology, Inc. Steel Plant: 3.9
Ispat Inland: 2.3 | Steel Mills  | 7.71 | 3.93 | 4.19 | 0.39 | 272 | 37 | 61 | 11 |
| 495 | Indianapolis Belmont WWTP: 1.6
Covanta Indianapolis: 1.2 | Municipal Waste 
Incinerators  | 3.92 | 0.00 | 0.00 | 0.00 | 63 | 0 | 0 | 0 |
| 36 | Delphi Energy & Chassis Sys: 1.7 | Battery Manufacturers  | 2.56 | 0.00 | 0.00 | 0.00 | 1 | 0 | 0 | 0 |
| 491 | Public Service Co Cherokee: 0.9 
PA Power Co Bruce Mansfield: 0.4 | EGUs  | 1.83 | 0.21 | 1.25 | 0.20 | 107 | 13 | 27 | 5 |
| 332 | Daimler Chrysler Corp Foundry: 0.9
Merdian Rail Products Corp: 0.3 | Iron Foundries  | 1.28 | 1.26 | 1.26 | 0.03 | 21 | 11 | 13 | 3 |
| 97 | Fort Carson USArmy: 0.5 
Navy Dept LB Shipyard: 0.4 | Government | 1.21 | 0.11 | 0.11 | 0.00 | 100 | 14 | 14 | 0 |
| 335 | Bridgeport Brass: 0.6 | Copper Rolling & Drawing | 0.79 | 0.03 | 0.04 | 0.00 | 40 | 6 | 6 | 4 |
| Other |  |  | 5.39 | 0.75 | 0.87 | 0.257 | 1425 | 45 | 89 | 15 |
| Total |  |  | 132.51 | 54.01 | 56.15 | 42.53 | 2230 | 259 | 345 | 148 |

## Control Measures Applied

- Major controls
- Dry ESP
- Fabric Filters (Mech. Shaker Type, Pulse Jet Type, and Reverse-Air Cleaned Type)
- Wet ESP – Wire Plate Type
- Venturi scrubbers
- Impingement plate scrubbers
- Minor controls
- Increased Monitoring Frequency (IMF) of PM controls
- CEM upgrade and IMF of PM Controls
- Diesel particulate filters on stationary sources

## Unidentified Controls

## Need for Unidentified Controls

- 14 of the 36 monitor areas are not expected to reach attainment for the 0.10 ug/m3  alternative following implementation of the controls identified in the AirControlNET analysis (i.e., identified controls).
- For the alternative of 0.05 ug/m3, 26 of the 36 monitors are unable to reach attainment from application of identified controls

## Large Sources First

- Started with 0.05 annual tpy (100 pound per year) sources.
-   Of the 2,230 point sources (excluding airports) in our analysis, 7.8 percent (174 sources) satisfy the 0.05 annual tpy (100 pound) or greater criteria, but they account for more than 97 percent of total adjusted baseline emissions

## Control Efficiency

- Used 90% efficiency applied in addition to any emissions controls already installed at each source.
- Based on measures of the efficiency of identified controls which could be applied to unidentified controls.  Identified controls had a mean at 70.2 percent and a median at 95.0 percent.

## Unidentified Controls Cost/Ton

- Fixed cost/ton used for unidentified controls
- Based on 98th Percentile of identified control for large (0.05 tons/year ) sources.
- Used $32 M/ton (2006 $) or $27M/ton (1999$)

## Conclusions

## Emission Reductions from Identified & Unidentified Controls

| REDUCTIONS IN LEAD EMISSIONS
(TONS/YEAR) | PROPOSED NAAQS:
 0.3 ΜG/M3 2ND 
MAXIMUM 
MONTHLY MEAN | PROPOSED NAAQS:
 0.2 ΜG/M3 2ND 
MAXIMUM
 MONTHLY MEAN | PROPOSED NAAQS: 
0.2 ΜG/M3 2ND 
MAXIMUM 
MONTHLY MEAN | PROPOSED NAAQS:
 0.05 ΜG/M3 2ND 
MAXIMUM 
MONTHLY MEAN |
| --- | --- | --- | --- | --- |
| Identified Controls | 35.3 | 38.4 | 43.9 | 51.3 |
| Unidentified Controls | 12.2 | 23.9 | 47.5 | 61.8 |
| Total | 47.5 | 62.3 | 91.4 | 113.1 |

## Results

- After applying unidentified controls using the process described above, all monitor areas reached attainment with the 0.3 :g/m3 proposed standard and the 0.2 :g/m3 proposed standard.
-   For the 0.1 :g/m3 proposed standard, three monitor areas required unidentified controls at sources that fell below the 0.05 tpy threshold in order to reach attainment
-    while one area did not reach attainment with any application of unidentified controls.
-  For the 0.05 :g/m3 alternative standard, eight monitor areas could not reach attainment with any application of unidentified controls.

## Number of Monitor Sites Reaching Attainment with Each Alternative Standard Using Identified and Unidentified Controls

| 
STANDARD | Number of Sites Analyzed | Number of Sites in Attainment with No Additional Controls | Number of Sites in Attainment with Identified Point Source Controls | Number of Sites in Attainment with Unidentified and Identified Point Source Controls |
| --- | --- | --- | --- | --- |
| 0.30 ΜG/M3  SECOND MAXIMUM MONTHLY MEAN | 36 | 24 | 30 | 35 |
| 0.20 ΜG/M3 SECOND MAXIMUM MONTHLY MEAN |  | 18 | 26 | 35 |
| 0.10 ΜG/M3 SECOND MAXIMUM MONTHLY MEAN |  | 10 | 20 | 31 |
| 0.05 ΜG/M3 SECOND MAXIMUM MONTHLY MEAN |  | 0 | 10 | 19 |

## Total Engineering Costs

|   | Annual Cost of Identified and Unidentified Controls in 2020 (Millions of 2006$) |  |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  | Proposed NAAQS: 0.3 μg/m3 2nd Maximum Monthly Mean |  | Proposed NAAQS: 0.2 μg/m3 2nd Maximum Monthly Mean |  |  | Proposed NAAQS: 0.1 μg/m3 2nd 
Maximum 
Monthly Mean |  |  | Alternative Standard: 0.05 μg/m3 2nd 
Maximum 
Monthly Mean |  |  |
|  | 3% Discount rate | 7% Discount rate | 3% Discount rate |  | 7% Discount rate | 3% Discount rate |  | 7% Discount rate | 3% Discount rate |  | 7% Discount rate |
| Identified Controls | $47  | $49  | $55  |  | $57  | $63  |  | $66  | $84  |  | $88  |
| Unidentified Controls | $400  |  | $790  |  |  | $1,600  |  |  | $2,000  |  |  |
| Total Engineering Costs | $450  | $450  | $840  | $840  |  | $1,600  | $1,600  |  | $2,100  | $2,100  |  |

## Average Costs

|   | Average Cost/ton of Identified and Unidentified Controls in 2020 (Millions of 2006$) |  |  |  |  |  |  |  |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- | --- | --- | --- |
|  | Proposed NAAQS: 0.3 μg/m3 2nd Maximum Monthly Mean |  | Proposed NAAQS: 0.2 μg/m3 2nd 
Maximum 
Monthly Mean |  |  | Proposed NAAQS: 0.1 μg/m3 2nd 
Maximum 
Monthly Mean |  | Alternative Standard: 0.05 μg/m3 2nd 
Maximum 
Monthly Mean |  |  |
|  | 3% Discount rate | 7% Discount rate | 3% Discount rate |  | 7% Discount rate | 3% 
Discount rate | 7% 
Discount rate | 3% 
Discount rate | 7%
Discount rate |  |
| Identified Controls | $1.3  | $1.4  | $1.4  |  | $1.5  | $1.4  | $1.5  | $1.6  | $1.7 |  |
| Unidentified Controls | $32 |  | $32 |  |  | $32 |  | $32 |  |  |
| Average Cost/Ton | $9.4  | $9.5  | $14  |  $14  |  | $18  | $18 | $18 |  | $18 |