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To: US EPA OAQPS

From: SRA International, Inc.

Subject: Review of CoST Model Emission Reduction Estimates

Date: September 30 , 2014

EPA uses the Control Strategy Tool (CoST) to estimate the emission reductions and engineering costs

associated with control strategies applied to point, area, and mobile sources of air pollutant emissions to

support the analyses of air pollution policies and regulations. CoST accomplishes this by matching

control measures to emission sources using algorithms such as "maximum emissions reduction", "least

cost", and "apply measures in series". There was a concern that the baseline inventory used by CoST did

not completely account for emission control requirements already in place, and that the emission

reductions were perhaps overestimated.

SRA reviewed the CoST results and made recommendations for changing the CoST control measure

assignment and the estimated reductions for oxides of nitrogen (NOx). The recommendations were based

on a review of source permits, state regulations, enforcement actions, and other available information.

The analysis was conducted for a 24

- state area in the eastern two

- thirds of the U.S. The focus was on
stationary point sources other than electric generating units ( non

- EGUs). The purpose of this memo is to

document the data used and assumptions made in recommend ing changes to the CoST results, and to

summarize the differences between the CoST resu lts and the recommended changes.

T he findings in this memo are based on review of CoST results for a 2018 emissions inventory projected

from the 2011 N ational Emission Inventory (N EI ). This work was in support of EPA’s current Transport

Rule efforts for implementing the 75 ppb ozone standard. If EPA considers establishing a tighter ozone

standard in the future, it is likely that a more distant future year will be used and that some of the

conclusions reached in this memo could change.

CoST D ATA PROVIDED BY EPA

EPA provided SRA with the outputs from a CoST scenario that identified sources for which NOx controls

were available at a cost

- effectiveness level of less than $10,000 per ton. The CoST outputs included

source identifiers, control technology, baseline emissions and estimate s of NOx emission reductions . The

CoST results were divided into two groups. The first group included sources where CoST estimated NOx

emission reductions of more than 100 tons per year. There were 547 sources in this group where CoST

controls were initially applied. The second group included sources where CoST estimated emission

reductions for sources whose 2018 projected emissions were greater than 25 ton s /y ear, exclud ing those

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with reductions greater than 100 tons/year. There were 1,280 sources in this group where CoST controls

were initially applied.

Another contractor review ed the CoST results for additional source categories, and their

recommendations were merged w ith SRA’s recommendations in the summary tables and maps that

follow. The data use d

, assumptions made and results for IC engines are documented elsewhere 1



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REVIEW OF CoST RESULTS FOR THE GREATER THAN 100 TPY GROUP

Table 1 summarizes the source categories included in our analysis, the CoST recommendation for NOx

control, and the recommendation for changing the CoST control measure assignment and associated

emission reduction estimates. Following Table 1, there is a d iscussion for each source group to provide

more detail on the rationale for the recommended changes for each source group. Attachments 1 to 4 are

tabular comparisons of the initial CoST emission reduction estimate s and the recommended change s . All

Attachme nts present the results in terms of tons per ozone season, simply estimated by assuming that

ozone season emissions were equal to 5/12 of the annual emissions. Maps 1A and 1B graphically show

the location of sources and the magnitude of the recommended emi ssion reductions.

Table 1

– CoST Controls and Recommended Changes for

Greater than 100 TPY Sources

Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions

Ammonia

– NG

- fired
Reformers Selective Catalytic

Reduction Agreed with CoST recommendation of SCR except for those sources where a permit or state regulation already required the source
to be controlled.
By

- Product Coke Mfg; Oven Underfiring Selective Non

- Catalytic

Reduction Review of a source

- specific NOx RACT permit indicated that NOx controls were technically or economically infeasible.

Cement Kilns Biosolid Injection Technology Disa greed with CoST recommendation

based on concerns about biosolids availability and information from EPA’s ISIS (Industr ial Sector Integrated Solutions)

Model ; recommended SNCR for all sources, except those that already have SNCR due to NOx SIP Call, NSR requirement, Consent Decree, or other state regulation.

1 Update of NOx Control Measure Data in the CoST Control Measures Database for Four Industrial Source Categories: Ammonia Reformers, NonEGU Combustion Turbines,Glass Manufacturing, and Lean Burn Reciprocating Internal Combustion Engines

, " prepared by Research Triangle Institute, July 2014.

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Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions
Cement Manufacturing

- Dry Selective Non

- Catalytic

Reduction Agreed with CoST recommendation except when already controlled due to NOx SIP Call, NSR requirement, Consent Decree, or other state regulation.
Cement Manufacturing

– Wet Mid

- kiln Firing Disa greed with CoST recommendation

based on information from EPA’s I SIS Model ; recommended SNCR for all sources, except those that already controlled
Coal Cleaning

– Thermal Dryer Low NOx Burner Agreed with CoST recommendation

Comm/Inst Incinerators Selective Non

- Catalytic

Reduction Both sources are already controlled with
SNCR

External Combustion Boilers, Elec Gen, Solid

Waste Selective Non

- Catalytic

Reduction All 6 sources are already controlled with
SNCR

Fluid Catalytic Cracking

Units Low NOx Burner and Flue
Gas Recirculation Nearly all FCCUs are already controlle d due to the OECA global refinery consent decrees. There is one small refinery in West Texas that does not appear to be covered by a consent decree, so the CoST recommendation was accepted.
Glass Manufacturing

– Container, Flat,

Pressed OXY

- Firing Disagr eed with CoST recommendation.
OXY

- firing is not generally required under
recent OECA consent decrees. More common control is oxygen

- enriched air staging (OEAS). OXY

- firing can only be implemented at the time of furnace rebuild, which is generally done ever y 10

- 15 years. Changed recommended control to OEAS
with a 50% NOx reduction instead of OXY

firing at 85% NOx reduction, except for sources that already had NOx controls in place due to a consent decree, NSR requirement, or state regulation. Assumed
that a furnace with a NOx emission limit of less than 4 lbs/ton of glass pulled was already reasonably controlled.

ICI Boilers

– Coal/Cyclone Selective Catalytic

Reduction Agreed with CoST recommendation of SCR except for those sources where a permit or

state r egulation already required the source
to be controlled. LADCO/OTC also
recommends SCR

ICI Boilers

– Coal/Stoker Selective Catalytic

Reduction Disagreed with CoST recommendation of SCR. CoST has $2200/ton, which appears

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Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions
very low for ICI boilers. Used LADCO/OTC
recommendation of SNCR for Coal

- Stokers with a 50% reduction, except for those sources where a permit or state regulation already required the source to be controlled.

ICI Boilers

– Coal/Wall Low NOx Burner and Selective Catalytic

Reduction Agre ed with CoST recommendation of SCR except for those sources where a permit or state regulation already required the source
to be controlled. LADCO/OTC also
recommends LNB/SCR

ICI Boilers

– Gas, Natural Gas, Process
Gas Selective Catalytic

Reduction Disagr eed with CoST recommendation of SCR. CoST has $3456/ton, which appears very low for ICI boilers. Used LADCO/OTC recommendation of Low NOx Burners plus
Flue Gas Recirculation for Gas

- fire ICI boilers with a 60% reduction, except for those sources where a pe rmit or state regulation already required the source to be
controlled

Industrial Incinerators Selective Non

- Catalytic

Reduction Agreed with CoST recommendation of SNCR except for those sources where a permit or state regulation already required the source
to be controlled.

Iron & Steel Mills

– Reheating Low NOx Burner and Flue
Gas Recirculation Agreed with CoST recommendation except for those sources where a permit or state regulation already required the source to be
controlled.
Municipal Waste
Combustors Selective Non

- Catalytic

Reduction Agreed with CoST recommendation of SNCR except for those sources where a permit or state regulation already required the source
to be controlled.

Nitric Acid Manufacturing Nonselective Catalytic

Reduction Agree d with CoST recommendation of NSCR except for those sources where a permit or state regulation already required the source
to be controlled.
Petroleum Refinery

Process Heaters SCR

- 95% Nearly all refineries are already controlled due to the OECA global ref inery consent decrees, which generally require 40

- 60%
reductions across all boilers/heaters that each company operates. Not possible at present to identify the individual boilers/heaters that actually have been

controlled or are scheduled to be control led due to confidentiality agreements between EPA and companies.

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Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions

Taconite Ore Processing

– Induration

– Coal or Gas Selective Catalytic

Reduction Disagree with CoST recommendation of SCR. EPA Region V considers SCR/SNCR
to be infeasible. Used Low NOx Burners at 70% reduction instead as reasonable control, except for those sources where a permit or state regulation already required the source

to be controlled. .
Utility Boilers *

– Coal/Wall Selective Catalytic

Reduction Agreed with CoST recommendation of SCR

e xcept for those sources where a permit or state regulation already required the source
to be controlled.
Utility Boilers *

– Oil/Gas Selective Catalytic

Reduction Agreed with CoST recommendation of SCR except for those sources where a permit or state regul ation already required the source
to be controlled.

The utility boilers included in the context of this report are non

- IPM utility boilers . In the NEI, these units have an SCC of 1

- 01

— xxx

- xx (the SCC series generally used for electric generating units. H owever, the sources included in this analysis do not sell electricity to the grid.



### Ammonia

– NG

- fired Reformers

There are 15 sources in this category. The CoST control technology was selective catalytic reduction

(SCR) with a 90% reduction in NOx emissions. We determined that four of these sources were already

controlled by either SCR or ultra

- NOx burners and recommended no further control/reductions. For all

other sources, we agreed with the CoST control and emission re duction estimate.

By

- Product Coke Mfg; Oven Underfiring

There are 14 sources in this category. The CoST control technology was selective non

- catalytic reduction

(SNCR) with a 6 0% reduction in NOx emissions. We reviewed a detailed RACT analysis for a facili ty in

Pennsylvania that determined that no controls were feasible. For all sources in this category, we

recommended that no controls were feasible and thus no reductions were appropriate.

Cement Preheater/Precalciner Kiln s

There are 36 sources in this cat egory. The CoST control technology was biosolid injection technology

with a 23 % reduction in NOx emissions. We reviewed permits and consent decrees to identify those kilns

that are already controlled. Several kilns are already controlled based on NOx SIP C all requirements that

typically required low NOx burners, mid

- kiln firing, or an approved alternative that resulted in a 30%

reduction. Other kilns already had SNCR installed due to a consent decree, new source review

requirement, or other state

- level requ irement.

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EPA expressed a concern whether there was sufficient biosolids availability for use by the uncontrolled

kilns. Also, EPA has done considerable research on cement kiln NOx controls as part of its Industrial

Sector Integrated Solutions (ISIS) projec t. EPA uses the ISIS

- cement model help analyze policy options

for various rulemaking s. Based on the ISIS work , we recommended that low

- NOx burners and SNCR as
the appropriate control for all types of kilns.

For uncontrolled kilns, we applied a 65% reductio n in NOx emissions. For kilns already controlled with

low

- NOx burners or mid

- kiln firing, we applied a 35% incremental reduction to account for the additional

reductions from SNCR. For kilns already controlled with SNCR, we applied no additional emission

r eductions.

Cement Manufacturing

- Dry Process

There are 20 sources in this category. The CoST control technology was SNCR with a 50 % reduction in

NOx emissions. We reviewed permits and consent decrees to identify those kilns that are already

controlled. Several kilns are already controlled based on NOx SIP Call requirements that typically

required low NOx burners, mid

- kiln firing, or an approved alternative that resulted in a 30% reduction.

Other kilns already had SNCR installed due to a consent decree, new source review requirement, or other

state

- level requirement.

As discussed earlier, we recommended that low

- NOx burners and SNCR as the appropriate control for all

types of kilns based on the ISIS work

. For uncontrolled kilns, we applied a 65% reduction in NOx

emissions. For kilns already controlled with low

- NOx burners or mid

- kiln firing, we applied a 35%

incremental reduction to account for the additional reductions from SNCR. For kilns already controlled

with SNCR, we applied no additional emission re ductions.

Cement Manufacturing

– Wet Process

There are seven sources in this category. The CoST control technology was mid

- kiln firing with a 3 0%

reduction in NOx emissions. We determined that two of these kilns were installing a pilot SCR system as

part of a consent decree. One kiln recently went through NSR review and has state

- of

- the

- art control.

Another kiln is required to install SNCR as part of a consent decree. No additional reductions were

applied for these kilns. For the remaining kilns, we appli ed low

- NOx burners and SNCR as described in

the previous sections.

Coal Cleaning

– Thermal Dryer

There was one source in this category. The CoST control technology was a low

- NOx burner with a 5 0%

reduction in NOx emissions. We could not find any information on this source and accepted the CoST

controls.

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Comm/Inst Incinerators

There are two sources in this category. The CoST control technology was SNCR with a 45 % reduction in

NOx emissions. Both of these sources are alread y controlled by SNCR and we applied no additional

emission reductions.

External Combustion Boilers, Elec Gen, Solid Waste

There are six sources in this category. The CoST control technology was SNCR with a 50% reduction in

NOx emissions. All six of these sources are already controlled by SNCR and we applied no additional

emission reductions.

Fluid Catalytic Cracking Units

There are six sources in this category. The CoST control technology was low

- NOx burners and flue gas

recirculation with a 55 % reduction in NOx emissions. Nearly all sources are already controlled or
required to install controls as a result of the EPA’s global refinery consent decrees. There is one small

refinery in West Texas that does not appear to be covered by a consent decree, so the CoST

recommendation was accepted.

Glass Manufacturing

– Container, Flat, Pressed

There are 6 5 sources in this category. The CoST control technology was oxy

- firing with an 85 %

reduction in NOx emissions. There were several concerns about using oxy

- firing for this analysis. First,

there is a concern about the timing of installing oxy

- firing technology. Oxy

- firing is typically installed at

the time of a furnace rebuild, which is typically done every 10 to 15 year s. Second, oxy

- firing is not

generally required under recent EPA consent decrees. More common control is oxygen

- enriched air

staging (OEAS). We recommended that OEAS with a 50% NOx reduction instead of OXY

- firing at 85%

NOx reduction, except for sources t hat already had NOx controls in place due to a consent decree, NSR

requirement, or state regulation. We a ssumed that a furnace with a NOx emission limit of less than 4

lbs/ton of glass pulled was already reasonably controlled.

ICI Boilers

– Coal/Cyclone

T here are eight sources in this category. The CoST control technology was SCR with an 80% reduction in

NOx emissions. We reviewed the Evaluation of Control Options for Industrial, Commercial and

Institutional (ICI) Boilers Technical Support Document (TSD)

, March, 2011 prepared by the Lake

Michigan Air Directors Consortium (LADCO) and the Ozone Transport Commission (OTC).

LADCO/OTC also recommended SCR for coal

- cyclone boilers. Since the LADCO/OTC recommendation

was consistent with the CoST control, w e agreed with the CoST control technology for five sources

which we determined were uncontrolled. Two sources were determined to be already controlled. One

source appears to have shut down their coal

- fired boilers. No reductions were applied for these three

source s since they are already controlled.

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ICI Boilers

– Coal/Stoker

There are 4 5 sources in this category. The CoST control technology was SCR with an 80% reduction in

NOx emissions. The LADCO/OTC recommendation was for c omb ustion tuning and SNCR . We agreed

w ith the LADCO/OTC recommendation and assumed a 50% control efficiency. We determined that most

of these sources are currently uncontrolled. Two coal

- fired boilers are scheduled to be replaced with gas

fired boilers. Two other boilers recently installed SNC R.

ICI Boilers

– Coal/Wall

There are 54 sources in this category. The CoST control technology was low

- NOx burners and SCR with

a 91% reduction in NOx emissions. The LADCO/OTC recommendation was also for low

- NOx burners

and SC R . Since the LADCO/OTC recomm endation was consistent with the CoST control, we agreed

with the CoST control technology and emission reductions

.
ICI Boilers

– Gas, Natural Gas, Process Gas

There are 1 30 sources in this category. The CoST control technology was SCR with an 80 % reduction in

NOx emissions. The LADCO/OTC recommendation was for low

- NOx burners, flue gas recirculation, or

low

- NOx burners combined with flue gas recirculation. We agreed with the LADCO/OTC

recommendation of low

- NOx burners combined with flue gas recir culation and assumed a 60% control

efficiency.

Several of these sources are located in the OTR or ozone nonattainment areas, and as a result already have

a RACT control requirement or emission limitation that is consistent with the LADCO/OTC

recommendatio ns. A few of these sources are located at petroleum refineries and were assumed to be

already controlled due to EPA’s refinery enforcement initiative.

Municipal Waste Combustors

There are 5 5 sources in this category. The CoST control technology was SNCR with a 45 % reduction in

NOx emissions. We determined that 35 of these sources are already controlled with SNCR and no

additional reductions were applied. For the remaining uncontrolled sources, we agreed with the CoST

controls and emission reductions.

Nitr ic Acid Manufacturing

There are seven sources in this category. The CoST control technology was non

- selective catalytic

reduction (NSCR) with a 9 8 % reduction in NOx emissions. All but one of these sources is already

controlled by NSCR or SCR.

Petroleum R efinery Process Heaters

There are 28 sources in this category. The CoST control technology was SCR with a 9 5 % reduction in

NOx emissions. All of the sources in this category are covered sources under EPA’s global refinery

enforcement initiative. The settlements generally require 40

- 60% reductions across all boilers/heaters that

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each company operates. Companies have submitted NOx compliance p lans to OECA that identify the

specific sources that have been controlled or are planned to be controlled, along with the technology used.

But it is n ot possible at present to identify the individual boilers/heaters that actually have been controlled

or ar e scheduled to be control led due to confidentiality agreements between EPA and companies. No

additional reductions were included for this category.

Taconite Ore Processing

– Induration

– Coal or Gas

There are 1 0 sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. All o f the sources in this category are already subject to Best Available Retrofit

Technology (BART) requirements under the Regional Haze program. EPA Region V determined that

BART is low

- NOx burner s and agreed that SCR controls are infeasible for indurating furnaces . No

additional reductions were included for this category.

Utility Boilers

– Coal/Wall , Oil, Gas

There are 11 s ources in this category. The CoST control technology was SCR with a 80 to 90% reduction

in NOx emissions depending on fuel type. All of the sources in this category appear to be uncontrolled

and we agreed with the CoST control and emission reduction estimate.

REVIEW OF CoST RESULTS FOR THE 25 TO 100 TPY GROUP

Due to the large number of sources in this group, we were not able to review individual permits to

determine whether the individual source was already controlled. Instead, our recommendations were

based on of state regulations, enforcement actions, enginee ring judgment, and other available information.

We generally assumed that sources located in areas with stringent NOx rules are already well controlled

and we assumed that no additional reductions were likely from these sources. This assumption was

general ly applied in New Jersey, New York and sources located in the Houston nonattainment area.

Given more time, we would like to have also applied this assumption in other areas with stringent existing

regulations, such as Chicago, Milwaukee, and Baton Rouge. I n any future analysis, it would be useful to

examine the stringency of rules that apply strictly to nonattainment areas.

Table 2 summarizes the source categories included in our analysis, the CoST recommendation for NOx

control, and the recommendation fo r changing the CoST control measure assignment and associated

emission reduction estimates. Following Table 2, there is a discussion for each source group to provide

more detail on the rationale for the recommended changes for each source group. Attachment s 5 to 8 are

tabular comparisons of the initial CoST emission reduction estimates and the recommended changes. All

Attachments present the results in terms of tons per ozone season, simply estimated by assuming that

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ozone season emissions were equal to 5/1 2 of the annual emissions. Maps 3A and 3B graphically show

the location of sources and the magnitude of the recommended emission reductions.

Table 2

– CoST Controls and Recommended Changes for

25 to 100 TPY Sources

Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions

Ammonia

– NG

- fired Reformers Selective Catalytic Reduction Agreed with CoST recommendation of SCR except for those sources where a permit or state regulation already required the source to be controlled.

Cement Kilns Biosolid Injection Technology Because of low emissions, assume that the kiln is already controlled or have very low usage which would result in a unreasonably high cost

- effectiveness Cement Manufacturing

– Wet Mi d

- kiln Firing Because of low emissions, assume that the kiln is already controlled or have very low usage which would result in a unreasonably high cost

- effectiveness Ceramic Clay Mfg; Drying Low NOx Burner Questions about technical feasibility for these category, assume zero reductions Coal Cleaning

– Thermal Dryer Low NOx Burner Agree with CoST recommendation

Comm/Inst Incinerators Selective Non

- Catalytic
Reduction Agree with CoST recommendation

External Combustion Boilers, Elec Gen, Sub/Bit Coal Selective Non

- Catalytic
Reduction Agree with CoST recommendation, although questions as to whether the source is already controlled or very low usage which would result in a unreasonably high cost

effectiveness Fluid Catalytic Cracking Units Low NOx Burne r and Flue Gas Recirculation Nearly all FCCUs are already controlled due to the OECA global refinery consent decrees.

Gas Turbines Low NOx Burners Agreed with CoST recommendation except for those sources where a state regulation already required the source to be controlled. Glass Manufacturing

– Container, Flat, Pressed OXY

- Firing Because of low emissions, assume that the furnace is already controlled or have very low usage which would result in a unreasonably high cost

- effectiveness

ICI Boilers

– Coal/Stoker Selective Catalytic Reduction Disagreed with CoST recommendation of SCR. CoST has $2200/ton, which appears very low for ICI boilers. Used LADCO/OTC recommendation of SNCR for Coal

- Stokers with a 50% reduction, except for those sources where a state regulation already required the source to be controlled.

ICI Boilers

– Coal/Wall Low NOx Burner and Selective Catalytic
Reduction Agreed with CoST recommendation of SCR except for those sources where a state regulation already required the source to be

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Source Group CoST Control Recommendation Summary of Recommended Changes to CoST Controls and Reductions
controlled. LADCO/OTC also recommends LNB/SCR

ICI Boilers

– Distillate Oil or Process Gas Selective Catalytic Reduction Because of low emissions, assume that the boiler is already controlled or have very low usage which would result in a unreasonably high cost

- effectiveness

ICI Boilers

– Natural Gas Low NOx Burner and Selective Catalytic
Reduction Disagreed with CoST recommendation of SCR. Used LADCO/OTC recommendation of Low NOx Burners plus Flue Gas Recirculation for Gas

- fire ICI boilers with a 60% reduction, except for those sources where a permit or state regulation already required the source to be controlled

ICI Boilers

– Residual Oil Low NOx Burner and Selective Non

- Catalytic
Reduction Agreed with CoST recommendation of SCR except for those so urces where a state regulation already required the source to be controlled.

Industrial Incinerators Selective Non

- Catalytic Reduction Agreed with CoST recommendation of SNCR except for those sources where a state regulation already required the source to be controlled.

Iron & Steel Mills

– Reheating Low NOx Burner and Flue Gas Recirculation Agreed with CoST recommendation except for those sources where a state regulation already required the source to be controlled. Municipal Waste Combustors Selective Non

- Catalytic Reduction Agreed with CoST recommendation of SNCR except for those sources where a state regulation already required the source to be controlled.

Nitric Acid Manufacturing Nonselective Catalytic Reduction Agreed with CoST recommendation of N SCR except for those sources where a state regulation already required the source to be controlled. Petroleum Refinery
Process Heaters SCR or Ultra

- Low NOx
Burner Nearly all refineries are already controlled due to the OECA global refinery consent decrees

, which generally require 40

- 60% reductions across all boilers/heaters that each company operates. Not possible at present to identify the individual boilers/heaters that actually have been controlled or are scheduled to be control due to confidentiality a greements between EPA and companies. Utility Boilers

– Coal/Wall Selective Catalytic
Reduction Agreed with CoST recommendation of SCR except for those sources where a state regulation already required the source to be controlled Utility Boilers

– Oil/Gas Selective Catalytic Reduction Because of low emissions, assume unreasonably high cost

- effectiveness for SCR; use LNB/FGR as reasonable control.

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Ammonia

– NG

- fired Reformers

There are seven sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. For all other sources, we agreed with the CoST control and emission reduction estimate.

Cement Kilns

There are six sources in this category. The CoST control technology was either biosolid injection

technology with a 23% reduction in NOx emissions or mid

- kiln firing with a 30% reduction. Because of

the low baseline emissions for these kilns, we assumed that the kilns were already controlled or have low

usage which would result in a very high cost

- effectiveness. We dete rmined that no reductions be applied

for these sources.

Coal Cleaning

– Thermal Dryer

There are 10 sources in this category. The CoST control technology was a low

- NOx burner with a 5 0%

reduction in NOx emissions. We agreed with the CoST control and emiss ion reduction estimate.

Comm ercial /Inst itutional Incinerators

There are four sources in this category. The CoST control technology was S N CR with a 45 % reduction in

NOx emissions. We agreed with the CoST control and emission reduction estimate.

External Combustion Boilers, Elec tric Gen eration , Coal

There are 14 sources in this category. The CoST control technology was S N CR with a 4 0% reduction in

NOx emissions. It appears that the sources in this category are low usage spreader stokers. Although there

may be a concern about the cost

- effectiveness for these sources, we agreed with the CoST control and

emission reduction estimate.

Fluid Catalytic Cracking Units

There are 21 sources in this category. The CoST control technology was low

- NOx burners and flue gas

recirculation with a 55 % reduction in NOx emissions. All sources in this category are assumed subject to

existing control requirements resulting from the OECA global refinery enforcement initiative.

Additionally, eight of the s ources are located in the Houston nonattainment area and are likely subject to

stringent controls. For these reasons, we assumed no further control or emission reductions for the

FCCUs.

Gas Turbines

There are 438 sources in this category. The CoST control technology was for low

- NOx burners with a

68 % reduction in NOx emissions. We agreed with the CoST control and emission reduction estimate,

except for those sources located in the OTR and Houston ozone nonattainment area, where we assumed

that these source s already had RACT controls.

Glass Manufacturing

– Container, Flat, Pressed

### 13

There are eight sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. Because of the low baseline emissions for these furnaces, we a ssumed that the furnaces

were already controlled and determined that no reductions be applied for these sources.

ICI Boilers

– Coal/Stoker

There are 1 33 sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. The LADCO/OTC recommendation was for c omb ustion tuning and SNCR . We agreed

with the LADCO/OTC recommendation and assumed a 50% control efficiency.

ICI Boilers

– Coal/Wall

There are 1 1 sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. The CoST control technology was low

- NOx burners and SCR with a 91% reduction in

NOx emissions. The LADCO/OTC recommendation was also for low

- NOx burners and SCR. Since the

LADCO/OTC recommendation was consistent with the CoST c ontrol, we agreed with the CoST control

technology and emission reductions.

ICI Boilers

– Natural Gas

There are 376 sources in this category. The CoST control technology was low

- NOx burners and SCR

with a 9 1 % reduction in NOx emissions. The LADCO/OTC recommendation was for low

- NOx burners,

flue gas recirculation, or low

- NOx burners combined with flue gas recirculation. We agreed with the

LADCO/OTC recommendation of low

- NOx burners combined with flue gas recirculation and assumed a

50% co ntrol efficiency, except for those sources located in the OTR and Houston ozone nonattainment

area, where we assumed that these sources already had RACT controls.

ICI Boilers

– Process Gas

There are 57 sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. Most of these sources are located at petroleum refineries and are assumed subject to

existing control requirements resulting from the OECA global refinery enforcement initiative, or are

located in the Houston nonattainment area and are likely subject to stringent controls. For these reasons,

we assumed no further control or emission reductions

.
ICI Boilers

– Residual Oil

There are 28 sources in this category. The CoST control technology was low

- NOx burner and S N CR with

a 69.5 % reduction in NOx emissions. We agreed with the CoST control and emission reduction estimate,

except for those sources located in the OTR and Houston ozone nonattainment area, where we assumed

that these sources already had RACT controls.

Industrial Incinerators

There are 21 sources in this category. The CoST control technology was S N CR with a 45 % reduction in

NOx emissions. We agreed with the CoST control and emission reduction estimate, except for those

### 14

sources located in the OTR and Hou ston ozone nonattainment area, where we assumed that these sources

already had RACT controls.

Iron & Steel Mills

– Reheating

There are 32 sources in this category. The CoST control technology was low

- NOx burners and flue gas

recirculation w ith a 77 % reduction in NOx emissions. We agreed with the CoST control and emission

reduction estimate.

Municipal Waste Combustors

There are 25 sources in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. RTI identified the sou rces are already controlled and no additional reductions were

applied for these sources. For the remaining sources, we agreed with the CoST controls and emission

reductions.

Nitric Acid Manufacturing

There are 1 4 sources in this category. The CoST control technology was N SCR with a 9 8 % reduction in

NOx emissions. We agreed with the CoST control and emission reduction estimate.

Petroleum Refinery Process Heaters

There are 3 0 sources in this category. The CoST cont rol technology was SCR with a 90

- 98 % reduction or

ultra

- low NOx burners with a 30

- 50% reductions i n NOx emissions. Most of these sources are located at

petroleum refineries and are assumed subject to existing control requirements resulting from the OECA

gl obal refinery enforcement initiative, or are located in the Houston nonattainment area and are likely

subject to stringent controls. For these reasons, we assumed no further control or emission reductions.

Utility Boilers

– Coal/Wall

There are three source s in this category. The CoST control technology was SCR with a 90% reduction in

NOx emissions. We agreed with the CoST control and emission reduction estimate.

Utility Boilers

– Oil/Gas

There are 27 sources in this category. The CoST control technology was SCR with a 8 0% reduction in

NOx emissions. The LADCO/OTC recommendation was for low

- NOx burners or flue gas recirculation.

We agreed with the LADCO/OTC recommendation of low

- NOx burners combined with flue gas

recirculation and assumed a 60% control effici ency.

### 15 Attachment 1

– NOx Emission Reductions by State for Sources in the > 100 Ton per Year Reduction Group

State Number of

Sources NOx emissions

reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 s eason )

( B ) Size of correction in NOx emission reductions (tons/ O3 season )

( A

- B )

Alabama 24 2,855 2,287 568

Arkansas 6 455 293 162

Delaware 2 206 0 206

Florida 20 2,158 1,370 788

Illinois 21 2,659 1,472 1,187

Indiana 41 5,405 4,510 896

Iowa 10 1,226 999 227

Kansas 7 735 452 283 Kentucky 11 915 838 77

Louisiana 57 7,623 3,622 4,000 Maryland 10 1,933 355 1,578 Michigan 27 2,758 1,768 990
Mississippi 7 1,054 516 538

Missouri 15 1,698 1,562 136 New Jersey 15 417 0 417

New York 30 3,091 281 2,810

Ohio 37 4,098 2,039 2,058

Oklahoma 20 2,949 1,864 1,086 Pennsylvania 52 5,637 2,215 3,422

Tennessee 13 4,741 1,987 2,755

Texas 65 8,860 6,383 2,477 Virginia 28 3,337 3,033 303 West Virginia 9 1,180 793 387

Wisconsin 20 4,092 3,416 676

547 70,082 42,054 28,028

### 16

Attachment 2

– NOx Emission Reductions by Source Group for Sources in the > 100 Ton per Year Reduction Group

S ource Group Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )

Ammonia

- NG

- Fired Reformers 15 2,427 1,551 875 By

- Product Coke Mfg; Oven Underfiring 14 1,199 0 1,199

Cement Kilns 36 3,932 6,586

- 2,654 Cement Manufacturing

- Dry 20 3,672 2,234 1,438 Cement Manufacturing

- Wet 7 1,294 1,120 174 Coal Cleaning

- Thrml Dryer; Fluidized Bed 1 50 50 0

Comm./Inst. Incinerators 2 137 0 137
External Combustion Boilers, Solid Waste 6 472 0 472 Fluid Cat Cracking Units; Cracking Unit 6 607 52 556 Fuel Fired Equip; Process Htrs; Pro Gas 2 143 143 0 Glass Manufacturing

- Container 34 2,759 678 2,081 Glass Manufacturing

– Flat 23 10,241 6,024 4,217 Glass Manufacturing

- Pressed 8 684 402 282

ICI Boilers

- Coal/Cyclone 8 2,987 1,840 1,147

ICI Boilers

- Coal/FBC 3 233 180 53

ICI Boilers

- Coal/Stoker 45 4,688 2,938 1,750

ICI Boilers

- Coal/Wall 54 12,041 7,996 4,045

ICI Boilers

– Gas 10 1,266 910 356

ICI Boilers

- Natural Gas 84 7,578 3,452 4,126

ICI Boilers

- Process Gas 36 3,868 1,229 2,639

ICI Boilers

- Residual Oil 2 199 82 117

Indust. Incinerators 9 586 124 461

In

- Proc;Process Gas;Coke Oven/Blast Furn 3 299 0 299

### 17

S ource Group Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )

In

- Process; Bituminous Coal; Cement Kiln 2 290 295

- 5

Iron & Steel

- In

- Process Coal Combustion 4 419 0 419

Iron & Steel Mills

– Reheating 2 156 156 0 Municipal Waste Combustors 55 1,591 876 715 Nitric Acid Manufacturing 7 687 82 605 Petroleum Refinery Gas

- Fired Process Heaters 28 2,025 0 2,025

Taconite Iron Ore

- Induration

- Coal or Gas 10 829 451 379 Utility Boiler

- Coal/Wall 5 555 555 0 Utility Boiler

- Oil

- Gas/Tangential 2 526 526 0 Utility Boiler

- Oil

- Gas/Wall 4 1,645 1,524 121

547 70,082 42,054 28,028

### 18

Attachment 3

– NOx Emission Reductions by 3

- Digit NAICS Code for Sources in the > 100 Ton per Year Reduction Group

3

- Digit NAICS Code Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )
211 Oil and Gas Extraction 1 46 30 16 212 Mining (except Oil and Gas) 11 879 500 379

221 Utilities 10 1,186 853 333 311 Food Mfg 12 1,181 815 366 312 Beverage and Tobacco Product Mfg 7 761 761 0 322 Paper Mfg 70 11,616 7,968 3,648

324 Petroleum and Coal Products Mfg 49 3,942 239 3,703 325 Chemical Mfg 132 19,689 10,753 8,937 3272 Glass and Glass Product Mfg 64 13,588 7,047 6,540 3273 Cement and Concrete Product Mfg 64 9,113 10,183

- 1,070 3274 Lime & Gypsum Product Mfg 1 75 52 22 331 Primary Metal Mfg 50 4,908 1,837 3,070 333 Machinery Mfg 1 57 35 21 336 Transportation Equipment Mfg 2 148 103 46
424 Merchant Wholesalers, Nondurable Goods 2 160 0 160

531 Real Estate 1 72 0 72 562 Waste Mgmt and Remediation Services 65 2,366 843 1,523

611 Educational Services 5 295 34 261

547 70,082 42,054 28,028

### 19

Attachment 4

– NOx Emission Reductions by 3

- Digit NAICS Code for Sources in the > 100 Ton per Year Reduction Group

Recommended Change to CoST Control Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B ) Already Controlled 138 12,973 0 12,973 Already Controlled by Glass CD 12 1,034 0 1,034 Already Controlled By Refinery CD 52 4,300 0 4,300 Control Technically or Economically Infeasible 18 1,618 0 1,618

Fuel Switch Already Occurred 4 2,370 0 2,370

Low NOx Burner 7 629 500 129

Low NOx Burner and Flue Gas Recirculation 88 8,792 6,022 2,769

Low NOx Burner and S CR 44 7,996 7,996 0

Low NOx Burner and SNCR 41 5,895 10,236

- 4,341

Non

- Selective Catalytic Reduction 1 82 82 0 Oxygen Enriched Air Staging 47 12,077 7,104 4,973 Selective Catalytic Reduction (SCR) 27 6,088 6,088 0

Selective Non

- Catalytic Reduction (SNCR) 62 5,109 4,026 1,083 Source Already Shutdown 6 1,120 0 1,120

547 70,082 42,054 28,028

### 20 Attachment 5

– NOx Emission Reductions by State for Sources in the 25 to 100 Ton per Year Reduction Group

State Number of

Sources NOx emissions

reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction in NOx emission reductions (tons/ O3 season )

( A

- B )

Alabama 38 641 517 123

Arkansas 14 277 203 74

Delaware 5 73 58 15

Florida 27 532 399 133

Illinois 91 1,519 845 675

Indiana 44 894 580 314

Iowa 19 422 309 113

Kansas 31 562 421 140 Kentucky 33 619 407 212

Louisiana 101 2,046 1,467 579 Maryland 18 353 209 144 Michigan 67 1,149 844 304
Mississippi 22 366 343 23

Missouri 13 224 179 45 New Jersey 7 72 11 61

New York 41 685 59 625

Ohio 86 1,476 1,075 402

Oklahoma 40 749 669 81 Pennsylvania 79 1,359 423 936

Tennessee 42 742 514 228

Texas 374 6,444 3,311 3,133 Virginia 30 450 350 100 West Virginia 21 421 334 87

Wisconsin 37 697 471 226

1280 22,774 14,000 8,774

### 21

Attachment 6

– NOx Emission Reductions by Source Group for Sources in the 25 to 100 Ton per Year Reduction Group

S ource Group Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )

Ammonia

- NG

- Fired Reformers2 7 200 155 45

Cement Kilns 4 93 0 93 Cement Manufacturing

- Wet 2 60 0 60 Ceramic Clay Mfg; Drying 4 29 0 29 Coal Cleaning

- Thrml Dryer; Fluidized Bed 10 188 188 0

Comm./Inst. Incinerators 4 47 47 0 Ext Comb Boilers, Elec Gen, Nat Gas (2) 1 28 28 0 Ext Comb Boilers, Elec Gen, Sub/Bit Coal (3) 14 158 158 0 Fbrglass Mfg; Txtle

- Type Fbr; Recup Furn 2 9 9 0

Fluid Cat Cracking Units; Cracking Unit 21 393 0 393 Fuel Fired Equip; Furnaces; Natural Gas 3 18 18 0 Fuel Fired Equip; Process Htrs; Pro Gas 7 86 86 0

Gas Turbines

- Natural Gas 438 7,193 5,749 1,444 Glass Manufacturing

- Flat 8 190 0 190

ICI Boilers

- Coal/FBC 1 35 22 13

ICI Boilers

- Coal/Stoker 133 2,502 1,629 873

ICI Boilers

- Coal/Wall 11 246 246 0

ICI Boilers

- Distillate Oil 4 75 0 75

ICI Boilers

- Gas 26 601 0 601

ICI Boilers

- Natural Gas 350 6,814 3,705 3,109

ICI Boilers

- Oil 2 41 0 41

ICI Boilers

- Process Gas 31 609 0 609

ICI Boilers

- Residual Oil 28 484 437 47

### 22

S ource Group Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )

Indust. Incinerators 21 230 118 113

In

- Proc;Process Gas;Coke Oven/Blast Furn 4 33 8 25

Iron & Steel

- In

- Process Comb

- Coal 1 19 0 19

Iron & Steel Mills

- Reheating 32 481 481 0 Municipal Waste Combustors 25 472 228 243 Nitric Acid Manufacturing 14 363 289 74 Petroleum Refinery Gas

- Fired Process Heaters 30 456 0 456 Solid Waste Disp;Gov;Other Incin;Sludge 1 6 6 0 Space Heaters

- Natural Gas 2 17 13 4 Steel Foundries; Heat Treating Furn 7 122 122 0 Surf Coat Oper;Coating Oven Htr;Nat Gas 2 11 0 11 Utility Boiler

- Coal/Wall 2 48 48 0 Utility Boiler

- Coal/Wall2 1 13 13 0 Utility Boiler

- Oil

- Gas/Tangential 8 99 62 37 Utility Boiler

- Oil

- Gas/Wall 19 307 137 170

1280 22,774 14,000 8,774

### 23

Attachment 7

– NOx Emission Reductions by 3

- Digit NAICS Code for Sources in the 25 to 100 Ton per Year Reduction Group

3

- Digit NAICS Code Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B )
211 Oil and Gas Extraction 146 2,674 2,573 100 212 Mining (except Oil and Gas) 12 247 227 20 213 Support Activities for Mining 1 20 20 0

221 Utilities 96 1,575 1,035 540 311 Food Manufacturing 46 715 450 266 312 Beverage and Tobacco Product s 9 151 91 60

313 Textile Mills 1 24 15 9

314 Textile Product Mills 1 12 7 4 316 Leather and Allied Product Manufacturing 1 10 7 3 321 Wood Product Manufacturing 6 100 56 44 322 Paper Manufacturing 79 1,662 1,028 634

324 Petroleum and Coal Products 115 2,083 527 1,556 325 Chemical Manufacturing 332 6,480 3,218 3,262

326 Plastics and Rubber Products 13 206 142 65 327 Nonmetallic Mineral Product Manufacturing 24 417 32 385 331 Primary Metal Manufacturing 87 1,380 1,094 285 332 Fabricated Metal Product Manufacturing 4 80 46 33 333 Machinery Manufacturing 2 20 14 6 334 Computer and Electronic Product s 1 9 9 0 336 Transportation Equipment Manufacturing 13 261 192 69

337 Furniture and Related Product s 2 18 18 0

447 Gasoline Stations 1 7 0 7

454 Nonstore Retailers 1 9 0 9

### 24

3

- Digit NAICS Code Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B ) 482 Rail Transportation 3 37 23 14

486 Pipeline Transportation 156 2,551 2,034 517 488 Support Activities for Transportation 1 18 12 6

531 Real Estate 8 147 0 147

541 Professional Services 6 81 77 4 561 Administrative and Support Services 1 8 0 8

562 Waste M gmt and Remediation Services 21 376 184 192

611 Educational Services 62 963 617 346
622 Hospitals 7 116 36 80 713 Amusement, Gambling, and Recreation 2 49 45 4

721 Accommodation 2 25 10 15 922 Justice, Public Order, and Safety Activities 4 29 17 12

923 Administration of Human Resource s 1 12 8 4 928 National Security and International Affairs 13 201 135 66

1280 22,774 14,000 8,774

### 25

Attachment 8

– NOx Emission Reductions by 3

- Digit NAICS Code for Sources in the 25 to 100 Ton per Year Reduction Group

Recommended Change to CoST Control Number of Sources NOx emissions reduced from controls in CoST (tons/ O3 season )

( A ) Recommended

NOx emissions reduced from controls in CoST (tons/ O3 season )

( B ) Size of correction

in NOx emission reductions (tons/ O3 season )

( A

- B ) Already Controlled 207 3,380 0 3,380 Already Controlled by Refinery CD 40 704 0 704

Low NOx Burner 362 6,087 6,087 0

Low NOx Burner and Flue Gas Recirculation 361 6,726 4,491 2,235

Low NOx Burner and SCR 11 246 246 0

Low NOx Burner and SNCR 24 437 437 0

Natural Gas Reburn 1 28 28 0

Non

- Selective Catalytic Reduction 12 289 289 0 Questions About Feasibility 1 22 0 22 Questions About Feasibility

- Cement 6 154 0 154 Questions About Feasibility

- Ceramic Clay Mfg 4 29 0 29 Questions about Feasibility

- Coating Ovens 2 11 0 11 Questions about Feasibility

- Distillate Oil 6 116 0 116 Questions About Feasibility

- Glass 7 167 0 167 Questions about Feasibility

- Process Gas 50 1,070 0 1,070 Selective Catalytic Reduction 8 216 216 0

Selective Non

- Catalytic Reduction 178 3,094 2,207 886

1280 22,774 14,000 8,774