# Presentation: 805589

## Lead NAAQS Final Controls & Cost Analysis

- August 18, 2008

## Purpose

- Baseline Overview
- Controls & Cost Analysis
- Overview
- Changes for Final
- Preliminary Results of Identified Controls Analysis
- Extrapolated Costs
- Emissions Extrapolation
- Ambient Extrapolation

## Emissions Baseline for this Analysis

- Base Year = 2002 National Emissions Inventory
- Baseline Projection to 2016:
- No growth factors applied.
- Consistent with current OAQPS interim approach for nonEGU point sources.
- Controls applied for:
- MACT rules with post 2002 compliance deadlines
- Illustrative PM NAAQS 15/35 controls applied to point sources
- Known plant closures
- Controls planned for Herculaneum Smelter as part of 2007 Missouri Lead SIP
- 24 Monitors that violate 0.1 μg/m3 or above

## Baseline Monitor Sites

- 9 sites that exceed 0.5 μg/m3
- 3 sites that exceed 0.3 μg/m3 for a total of 12
- 5 sites that exceed 0.2 μg/m3 for a total of 17
- 7 sites that exceed 0.1 μg/m3 for a total of 24

- Preliminary Results - Subject to Change

## Identified Controls Analysis Overview

- 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 controls needed from each source to get monitors to attainment.

## Changes to Cost Analysis for Final RIA

- Updated emissions and geo-coordinate information for sources
- Increased control efficiencies for several PM control measures as applied in 2016
- Control efficiencies increased for ESPs, fabric filters, venturi scrubbers
- Increase efficiencies based on review of data within control measure database;  similar reviews
- Previously performed similar reviews for PM and ozone RIA control strategy analyses
- Removed cost/ton cap for identified controls
- Included “Large” Sources (>1 ton/year) within 20km of monitors
- Identified & applied new control measure for Herculaneum Lead Smelter.

## Major Control Measures Applied

- Rebuild of Herculaneum Primary Lead Smelter
- A company in British Columbia rebuilt their primary lead smelter using the state-of-the-art Kivcet process.
- Through examination of annual reports and publicly available emissions information, we’ve been able to develop emission reduction and capital cost estimates that might be realized if Herculaneum went through a similar reconstruction.
- Still refining these estimates.
- Ferrous Metals Processing (Gray Iron Foundries, Iron & Steel Production, Steel Foundries)
- Fabric Filter (Mech. Shaker Type)
- Increased Monitoring Frequency (IMF) of PM Control
- CEM Upgrade & IMF of PM Controls
- Fabric Filter (Pulse Jet Type)
- Industrial Boilers (Coal)
- Fabric Filters (Pulse Jet Type)
- Non-Ferrous Metals Processing (Copper, Lead, Zinc)
- Fabric Filter (Mech. Shaker Type),
- Increased Monitoring Frequency (IMF) of PM Control
- CEM Upgrade & IMF of PM Controls,
- Fabric Filter (Pulse Jet Type)
- Wet ESP

## Monitor Sites Post Identified Control

- 1 Sites that exceed 0.5 ug/m3
- 4 sites that exceed 0.3 ug/m3 for a total of 5
- 4 sites that exceed 0.2 ug/m3 for a total of 9
- 5 sites that exceed 0.1 ug/m3 for a total 14
- 10 sites that do not exceed 0.1 ug/m3 for a total of 24

- Preliminary Results - Subject to Change

## Emission Reductions from Identified Controls

- Preliminary Results - Subject to Change

## Costs of Identified Controls

- Preliminary Results - Subject to Change

## Monitor Sites Needing Additional Control to Attain

| 
STANDARD
(2nd Max 
Monthly Mean) | Number of Sites Analyzed | Number of Sites in Attainment in Baseline | Total Number of Sites in Attainment with Identified Point Source Controls
 | Number of Sites Needing Unidentified Controls |
| --- | --- | --- | --- | --- |
| 0.50 μg/m3 | 24 | 15 | 23 | 1 |
| 0.30 μg/m3 |  | 12 | 19 | 5 |
| 0.20 μg/m3 |  | 7 | 15 | 9 |
| 0.10 μg/m3 |  | 0 | 10 | 13* |

- * Ottawa Co, OK remains at 0.114 ug/m3.  Due to the current Superfund situation and buyout of the town, we will not apply unidentified controls
- For this area.

- Preliminary Results - Subject to Change

## Areas Needing Additional Control

| County, State | Baseline Monitor Value | Monitor Values Post Identified Control |  |  |  |
| --- | --- | --- | --- | --- | --- |
|  |  | 0.50 μg/m3 | 0.30 μg/m3 | 0.20 μg/m3 | 0.10 μg/m3 |
| Adams, CO | 0.4396 |  | 0.4396 | 0.4382 | 0.4382 |
| Denver, CO | 0.2291 |  |  | 0.2050 | 0.2050 |
| El Paso, CO | 0.1314 |  |  |  | 0.1309 |
| Madison, IL | 0.1281 |  |  |  | 0.1041 |
| Jefferson, MO | 1.9980 |  |  | 0.2361 | 0.2361 |
| Cuyahoga, OH | 0.3362 |  | 0.3008 | 0.3008 | 0.3008 |
| Fulton, OH | 0.5300 | 0.5296 | 0.5296 | 0.5296 | 0.5296 |
| Logan, OH | 0.3600 |  | 0.3600 | 0.3600 | 0.3600 |
| Beaver, PA | 0.2278 |  |  |  | 0.1956 |
| Berks, PA | 0.5176 |  | 0.3323 | 0.3323 | 0.3323 |
| Carbon, PA | 0.2942 |  |  | 0.2942 | 0.2942 |
| Sullivan, TN | 0.2360 |  |  | 0.2360 | 0.2360 |
| Dallas, TX | 0.1014 |  |  |  | 0.1010 |

- Bolded monitor values signify no progress made toward attainment (i.e. no identified controls could be applied).

- Preliminary Results - Subject to Change

**Notes:**
Make bold the ones that make no progess

## Extrapolated Costs

- Two extrapolated cost methodologies
- Emissions Extrapolation
- Uses emissions reduction and ambient air quality data to calculate the additional increment needed to attain, and calculates a $/ton for each standard that is applied to the total increment needed to attain.
- Ambient Extrapolation
- Uses ambient air quality changes by area and calculates a $/μg for each geographic area and standard that is applied to the increment needed to attain.
- Methodologies address 2 types of geographic areas:
- Areas that make some progress towards attainment
- Areas that make no progress towards attainment

## Advantages over Proposal Unidentified Controls

- Less heroic assumptions required
- New methodology doesn’t assume control efficiency and costs for specific point sources.
- Doesn’t assume all additional control will occur at currently known facilities.
- More generalized approach acknowledges the lack of good quality source data and works with increments to attainment.

## Emissions Extrapolation (lower bound)

- Calculations
- Solve for the emission reductions needed for attainment.
- Total Emissions Reductions divide by identified emissions reductions and multiply by the identified cost.
- Yields total cost of attainment for each standard.

## Ambient Extrapolation	(upper bound)

- Calculations
- Areas that make progress
- Calculate the additional ug needed to attain
- Calculate the $/ug for the identified control by area
- Multiply to get total cost by area to attain.
- Areas that make no progress
- Calculate the additional ug needed to attain
- Used the highest $/ug from identified control & applied to each area
- Multiply to get total cost by area.
- Sum to obtain total extrapolated cost

## Ambient Extrapolation Example

| Geographic Area | Monitor Values 
(ug/m3) |  | Ambient Increments 
(ug/m3) |  | Annualized Costs
(M $2006) |  |  |
| --- | --- | --- | --- | --- | --- | --- | --- |
|  | Baseline  | Post 
Identified 
Control | Increment Achieved from Identified Controls | Additional Increment to Attain 0.1 ug/m3 | Identified Controls | Cost/ug | Total 
Extrapolated 
Cost |
| Madison, IL | 0.1281 | 0.1041 | 0.0239 | 0.0041 | $13.9  | $580 | $2.4 |
| Beaver, PA | 0.2278 | 0.1956 | 0.0322 | 0.0956 | $37.2 | $1,160 | $111 |

- Calculate Increment Achieved from Identified Controls
- 0.1281 - 0.1041 = 0.0239
- Calculate $/ug
- $13.9M/0.0239 = $580M
- Calculate Increment to Attain 0.1 ug/m3
- 0.1041 – 0.1000 = 0.0041
- Calculate Total Cost for Additional Increment to Attain
- $580M * 0.0041 = $2.4M

- Preliminary Results - Subject to Change

## Advantages of Using Two Approaches

- Emissions Extrapolation
- Acknowledges the lack of further progress may be missing information versus an absence of emissions controls.
- Ambient Extrapolation
- Acknowledges that the areas we know the least about may have a more difficult time attaining, and therefore a higher per unit cost.

## Next Steps

- Finish incorporating model updates for identified controls
- Investigate areas with difficulty attaining to examine local conditions
- Finish emissions & ambient extrapolation calculations
- Generate Results