&EPA
           United States
           'Environmental Protection
           Agency
              Air and Radiation
              Research Triangle Park, NC 27711
              (MD-14)
EPA454-R-95-OOT
June 1995
National Annual Industrial
Sulfur Dioxide Emission Trends
1995-2015
Report To Congress
    Estimates (million short

    12
                       METALS PROCESSING CHEMICAL & ALLIED PRODUCT MFS
               FUEL COMB. INDUSTRIAL
             PETROLEUM & RELATED INDUSTRIES ALL OTHER INDUSTRIAL

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                              CONTENTS
TABLES AND FIGURES ...............................................  v

ACKNOWLEDGEMENT ...............................................  *ii

EXECUTIVE SUMMARY .............................................  ES-1
    A.  CLEAN AIR ACT AMENDMENTS OF 1990 MANDATE ...............  ES-1
    B.  SELECTION OF A BASELINE EMISSIONS INVENTORY METHODOLOGY ES-2
       1.  Emissions Levels from 1985-1990  .............................  ES-3
       2.  Selection of Base Year Emission Inventory ......................  ES-3
    C.  PROJECTED EMISSIONS LEVELS ..............................  ES-4
CHAPTER I
INTRODUCTION
CHAPTER II
HISTORIC INDUSTRIAL SO2 EMISSIONS .................................   3
    A.  INTRODUCTION ................ ..............................   3
    B.  NATIONAL LEVEL HISTORIC INDUSTRIAL SOURCE SO2 EMISSIONS
       ESTIMATES  ..................................................   4
    C.  HISTORIC EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
       SUBCATEGORIES .............................................   4
       1.  Fuel Combustion .......................... .................   4
       2.  Metals Processing  ..........................................   5
       3.  Chemical and Allied Product Manufacturing .......................   5
       4.  Petroleum and Related Industries  ..............................   5
       5.  Other Industrial Processes .......................... ..........   6
    D.  HISTORIC EMISSIONS SUMMARY ........................ ...... - •   6

CHAPTER III
 SUMMARY CHAPTER COMPARING EMISSIONS FROM BASELINE ANALYSIS
 REPORT [[[  17
    A.   1985 NAPAP EMISSION INVENTORY VERSION 2 ....................  17
        1.   Methodology ...............................................  17
        2.   Quality Assurance and Quality Control (QA/QC) ....................  19
    B.   1985 EPA NATIONAL AIR POLLUTANT EMISSION ESTIMATES .........  19
    C.   ANALYSIS ............... ....................................  20
        1.   Combustion Sources .........................................  21
        2.   Nonferrous Smelting Sources . . . ...... , ........ • ...............  22
        3.   Other Industrial Process Sources ...............................  23
    D.  CONCLUSIONS ____ - ...........................................  23
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CHAPTER IV
BASELINE INDUSTRIAL SO2 EMISSION INVENTORY	  27
   A.  INTRODUCTION	  27
   B.  CURRENT EMISSIONS LEVELS (1985-1990)	  27
   C.  CURRENT EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
       SUBCATEGORIES	  28
       1.   Fuel Combustion 	  28
       2.   Metals Processing 	  28
       3.   Chemical and Allied Product Manufacturing	  28
       4.   Petroleum and Related Industries  	  29
       5.   Other Industrial Processes	  29
   D.  SELECTION OF THE EMISSION PROJECTIONS BASE YEAR
       INVENTORY 	  29
   E.  TOP 100 INDUSTRIAL SO2 POINT SOURCES	  30
   F.  SECTION 405(g)(6) SOURCES  	  30

CHAPTERV     • '
INDUSTRIAL SO2 EMISSION PROJECTIONS  	  42
   A.  INTRODUCTION	42
   B.  PROJECTION METHODOLOGY 	  42
   C.  INDUSTRIAL SO2 EMISSION PROJECTIONS	  44
   D.  PROJECTED EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
       SUBCATEGORIES	,	45
       1.   Industrial Combustion	  45
       2.   Metals Processing 	  45
       3.   Chemical and Allied Products Manufacturing	  45
       4.   Petroleum and Related Industries  	  45
       5.   Other Industrial Processes	  45
   E.  EMISSION PROJECTIONS SUMMARY	  46

CHAPTER VI
EMISSION REDUCTIONS RESULTING FROM DIESEL DESULFURIZATION
REGULATIONS	  54
   A.  INTRODUCTION	  54
   B.  DIESEL DESULFURIZATION REGULATIONS  	  54
   C.  METHOD OF ESTIMATING EMISSION REDUCTIONS	  54
   D.. ESTIMATED SO2 EMISSION REDUCTIONS 	  55

REFERENCES	  59
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                         TABLES AND FIGURES
Tables                                                           ^ ^       PaSe
ES-1    National Sulfur Dioxide Emissions from Industrial Sources for the Years
        1985, 1993, and 2015 (thousand short tons)	 ES-4
III-l    Differences between 1985 Trends and NAPAP SO2 Emission Estimates	25
IV-1    Top 100 AIRS/AFS Industrial Plants Emitting Sulfur Dioxide	  31
IV-2    Analysis of Top 100 Industrial SO2 Point Sources by Industry	  34
V-l     National Tier 1 Emissions Projections, 1990 to 2015  	  47
VI-1    Estimated National SO2 Emission Reductions from Diesel Desulfurization  ...  56
VI-2    Estimated State-Level SO2 Emissions with and without Diesel Desulfurization 57
Figures                                                                        e
ES-1.   Industrial SO2 Emissions (1900-2015) 	  ES-5
ES-2.   Top 100 AIRS/AFS Plants Emitting Sulfur Dioxide from Industrial Sources -
        1993	  ES~6
II-l.    Historic Industrial SO2 Emissions (1900 - 1984)	  8
II-2.    Historic Industrial Combustion SO2 Emissions (1940 - 1980)	  9
II-3.    Historic Industrial SO2 Emissions from Metals  Processing (1940 - 1980)  .... 10
II-4.    Historic Industrial SO2 Emissions from Chemical & Allied Product Mfg (1940
        - 1980) 	 n
II-5.    Historic Industrial SO2 Emissions from Petroleum & Related Industries (1940
        - 1980) 	-	'	12
II-6.    Historic Industrial SO2 Emissions from Other Industrial Processes (1940 -
        1980)	 13
II-7.    Trends in Industrial SO2 Emissions and Energy Use (1945-1985)	 14
II-8.    Industrial Combustion SO2 Emissions and Energy Use (1940-1990)	 15
II-9.    Industrial Process SO2 Emissions and Primary Metals Index (1940 -1980)  . . 16
III-l.   Comparison of 1985 Trends and NAPAP by Source Category	 26
IV-1.   Industrial SO2 Emissions (1985 - 1990)	 35
IV-2.   Industrial Combustion SO2 Emissions (1985 - 1990)	36
rV-3.   Industrial SO2 Emissions from Metals Processing (1985 - 1990)	 37
IV-4.   Industrial SO2 Emissions from Chemical & Allied Product Mfg (1985 - 1990)  . 38
 IV-5.    Industrial SO2 Emissions from Petroleum & Related Industries (1985 - 1990)  39
 IV-6.    Industrial SO2 Emissions from Other Industrial Processes (1985 - 1990)  .... 40
 W-l.    Top 100 AIRS/AFS Plants Emitting Sulfur Dioxide from Industrial Sources -
         1993	41
 V-l.     Projected Industrial SO2 Emissions (1990 - 2015)	48
 V-2.     Projected Industrial Combustion SO2 Emissions (1990 - 2015)	49
 V-3.     Projected Industrial SO2 Emissions from Metals  Processing (1990 - 2015)  ... 50
 V-4.     Projected Industrial SO2 Emissions from Chemical & Allied Product Mfg
         (1990 - 2015)	 51
   Development of an Industrial SO,                                             Tables and Fi9ures
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V-5.     Projected Industrial SO2 Emissions from Petroleum & Related Industries
         (1990 - 2015)	  52
V-6.     Projected Industrial ,SO2 Emissions from Other Industrial Processes (1990 -
         2015)	  53
VI-1.    Graphical Comparison of 1993 Diesel Motor Vehicle SO2 Emissions with and
         without Fuel Desulfurization	  58
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Page vi
                                 Tables end Figures

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                          ACKNOWLEDGEMENT
    The Development of an Industrial SO2 Emissions Inventory Baseline and 1995 Report
to Congress involved the cooperative efforts of the following individuals of the U.S.
Environmental Protection Agency: J. David Mobley and Sharon Nizich, of the Office of
Air Quality Planning and Standards, Larry Montgomery, Dennis Leaf, and Rona
Birnbaum of the Office of Air and Radiation, and Sue Kimbrough and Chuck Masser of
the Office of Research and Development.  The EPA also would like to acknowledge E.H.
Pechan & Associates, Inc. for their assistance in preparing this report.
  Development of an Industrial SO,                                                Acknowledgement
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                          EXECUTIVE  SUMMARY
    This report provides an inventory of national annual sulfur dioxide (SO2) emissions
from industrial (i.e., nonutility) sources.  It also contains estimates of actual emission
reductions resulting from diesel fuel desulfurization regulations defined in section 211(i)
of the Clean Air Act Amendments of 1990 (CAAA), which became effective in October
1993.

    The major health effects associated with high exposures to SO2 in the ambient air
include problems in breathing, respiratory illness, alterations in  the lung's defenses, and
aggravation of existing respiratory and cardiovascular disease. Those most sensitive to
SO2 include asthmatics and individuals with chronic lung disease (such as bronchitis or
emphysema) or cardiovascular disease. Children and the elderly may also be sensitive.

    Sulfur dioxide also produces foliar damage on trees and agricultural crops. Sulfur
dioxide and nitrogen oxides (NOX) in the air cause acidic deposition, commonly known as
acid rain. Acid rain is associated with a number of effects including acidification of lakes
and streams, damage to high-elevation forests, and accelerated corrosion of buildings and
monuments. Sulfur dioxide and NOX emissions also form sulfates and nitrates in the
atmosphere that can significantly impair visibility.

    In 1990 the Congress amended the Clean Air Act (CAA) to address problems
associated with acid rain. Title IV of the 1990 Amendments requires a 10 million ton
reduction of SO2 and significant reductions of NOX to reduce the harmful effects of acid
rain. Title IV also calls for the establishment of a market-based allowance trading
program to minimize compliance costs and maximize economic efficiency.  In January
1993 EPA issued final regulations implementing the SO2 allowance trading program. The
SO2 reductions are to be achieved primarily from utilities, but also from industrial sources
that opt into the allowance trading program and from the desulfurization of diesel fuel.
Rulemaking on industrial sources, to be finalized in early 1995, allows  SO2 industrial
combustion sources to receive permits and allowance allocations. The remaining process
sources will fall under a second rulemaking, to be promulgated later in 1995.

A. CLEAN AIR ACT AMENDMENTS OF 1990 MANDATE

    This report provides information required under section 406 of the CAAA. The CAAA
of 1990 actually contains two section 406's in Title IV.  All references to section 406 in
this report refer to 42 USC 7651, (note also referred to as section 406,  Appendix B), which
deals with Industrial SO2 Emissions.  Section 406 states that:

         Not later than January 1, 1995 and every 5 years thereafter, the
         Administrator of the Environmental Protection Agency  (EPA)  shall
         transmit to the Congress a report containing an inventory of national
         annual SO2 emissions from industrial sources (as defined in title IV of


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        the Act), including units subject to section 405(g)(6) of the CAA, for all
        years for which data are available, as well as the likely trend in such
        emissions over the following 20-year period. The report shall also contain
        estimates of the actual emission reduction in each year resulting from
        promulgation of the diesel fuel desulfurization regulations under section
    Industrial sources are defined in section 402(24) of the 1990 CAAA.  An industrial
source is:

        a unit that does not serve a generator that produces electricity, a
        "nonutility unit" as defined in this section, or a process source as defined
        in section 410(e).

A nonutility unit is defined in section 402(25) as "a unit other than a utility unit."
Although reference is made to a process source definition in section 410(e), section 410(d)
actually deals with process sources, but no definition of a process source is given.  For the
purposes of this report, a process source is any source that emits SO2 as the result of the
production or manufacturing process and not as the result of any type of fuel combustion.

    Section 406 also provides that whenever the inventory required by this section
indicates that sulfur dioxide emissions from industrial sources,  including units subject to
section 405(g)(6) of the CAA, may reasonably be expected to reach levels greater than 5.60
million tons per year, the Administrator of the EPA shall take such actions under the
CAA as may be appropriate to ensure that such emissions do not exceed 5.60 million tons
per year. Such actions may include the promulgation of new and revised standards of
performance for new sources, including units subject to section 405(g)(6) of the' CAA,
under section lll(b) of the CAA, as well as promulgation of standards of performance for
existing sources, including units subject to section 405(g)(5)  of the CAA, under authority
of this section. Although the act refers to 405(g)(5), the actual reference should be
405(g)(6).

B.  SELECTION OF A BASELINE EMISSIONS INVENTORY METHODOLOGY
          ^

    The 5.60 million ton cap cited in section 406 was derived from emissions estimated for
industrial sources as part of the 1985 National Acid Precipitation Assessment Program
(NAPAP)  inventory. As a consequence, 1985 emissions serve as the baseline from which
all other emissions estimates are derived. The U.S. Environmental Protection Agency
(EPA) also produces annual emissions estimates, including those for 1985, as part of their
annual assessment of emission trends.  A comparison made between the 1985 NAPAP
emission inventory and the Trends data for 1985 (available  in the October 1992 EPA
Trends report) for industrial sources indicated that the two 1985 estimates (NAPAP and
Trends) compare favorably at the national level (NAPAP estimated 5.6 million tons SO2
and Trends estimated 6.0 million tons SO2). There were, however, individual source
category by source category discrepancies.  The 1985 NAPAP inventory still represents
the most  comprehensive and accurate emission estimates for 1985 because of its rigorous
quality assurance of emissions  and bottom-up derivation.  Therefore, the NAPAP
estimate, which is the basis for the emission cap in the CAAA,  should be used as the
starting point for all future comparisons.

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    1.   Emissions Levels from 1985-1990

    Estimates of industrial SO2 emissions over the period 1985 to 1990 show a moderate
decline from 5.6 million tons to slightly less than 5 million tons. Over that time period,
coal-related SO2 emissions dominate emissions from industrial fuel sources.  Emissions
from oil combustion in the industrial sector have declined slightly from the 1985 NAPAP
levels, while contributions from gas and other fuels have remained approximately the
same.

    Copper processing operations were the largest contributor to metals processing
emissions according to the 1985 NAPAP emission inventory.  Emissions from copper
processing operations have decreased dramatically from approximately 0.65 million tons
in 1985 to slightly over 0.2 million tons in 1990.  A large part of this decrease in
emissions is attributable to the demolition of the Phelps Dodge copper smelter (in
Arizona) in January 1987, resulting in a decrease in emissions  of 330,000 tons/year of
SO2. Emissions from other metals processing sources from 1985-1990 have stayed
approximately the same.

    SO2 emissions from chemical manufacturing processes are dominated by emissions
from inorganic sulfur compound production over the period 1985-1990. Emissions from
the other chemical processes remain relatively fiat for this time period.

    Emissions from petroleum and related industries from 1985-1990 shows that natural
gas production SO2 emissions  are approximately the same as those from fluid catalytic
cracking units at  petroleum refineries. Prior to 1985, natural gas production SO2
emissions were approximately one-half those from fluid catalytic cracking units at
petroleum refineries.

    Cement manufacturing is the leading other industrial processes subcategory SO2
emission producer. This source does show a slight,  but steady  decline in emission from
1985 to 1990. Emissions from wood, pulp and paper, and publishing operations remained
virtually constant over the same time frame, as did waste disposal operations, and the all
other industrial processes categories.  Mineral products (excluding cement manufacturing)
declined slightly over the period.

    2.   Selection of Base Year Emission Inventory

    In order to produce the emission projections required under section 406, a base year
emission inventory upon which to base these projections was required.  EPA feels that the
best inventory to use for developing the emission projections required under section 406 is
the 1990 Emission Trends inventory.  This decision was based on three criteria:

    •    It is based upon the 1985 NAPAP emission inventory, which is generally
         regarded as the most comprehensive inventory ever compiled,

    •    It is an outgrowth of the 1990 Interim Inventory which is currently being utilized
         in ROM  modeling efforts and is generally regarded as the best national level
         inventory currently available, and
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    •   The 1990 inventory coincides with the year of enactment for the CAAA.

C.  PROJECTED EMISSIONS LEVELS

    Industrial source SO2 emissions for the base year (1990) are approximately 5 million
tons. Starting with the base year emissions, emission projections were developed using
growth factors. No new national controls for any industrial SO2 sources were identified,
nor were changes in current "rule effectiveness." (Rule effectiveness reflects the ability of
a regulatory program to achieve all the emission reductions that could have been achieved
by full compliance with the applicable regulations at all sources at all times.) Thus the
emission projections developed represent growth with no new controls.

    Table ES-1 shows the 1985, 1993, and 2015 emission levels for five broad categories of
industrial SO2 emissions.  2015 was chosen as the last projection year, since it represents
a 20-year period from the January 1995 date required for this report. Table ES-1 shows
that emissions were 5.6 million tons in 1985, decreased to 4.7 million tons in 1993 and are
projected to increase slightly to 4.8 million tons in 2015.

    Figure ES-1 provides a long term look at emissions from industrial SO2 sources.  This
figure shows historic, current and projected emissions levels for the five categories
included in Table ES-1 as well as an indicator of the 5.6 million ton/year cap called for in
section 406. This figure shows that prior to 1970, emission levels were almost double the
5.6 million ton/year cap, but declined significantly after that.  This decline  is coincident
with the passage of the Clean Air Act of 1970. Figure ES-1 also shows that projected
emissions show a slight increase from 1990 to 2000 and then are projected  to level off in
the foreseeable future.

    Figure ES-2 provides a map showing the locations and relative emissions of the top
100 industrial point source emitters as derived from EPA's Aerometric Information
System Facility Subsystem (AIRS/AFS). These emissions were not used in the baseline
analysis.
                                     Table ES-1
  National Sulfur Dioxide Emissions from Industrial Sources for the Years 1985,
                       1993, and 2015 (thousand short tons)

  Source Category                      	   1985	1993	2015
  Fuel Combustion
  Metals Processing
  Chemical & Allied Product Manufacturing
  Petroleum & Related Industries
  All Other Industrial
  Total
               3,169
               1,042
                 456
                 505
                 440
               5,612
2,830
 580
 450
 409
 430
4,699
2,803
  584
  540
  312
  620
4,859
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                                                                      Executive Summary
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                                  CHAPTER I
                               INTRODUCTION
    This report provides information required under section 406 of the Clean Air Act
Amendments of 1990 (CAAA). The CAAA of 1990 actually contains two section 406's in
Title IV. All references to section 406 in this report refer to 42 USC 7651, note (also
referred to as section 406, Appendix B, which deals with Industrial SO2 Emissions.
Section 406 states that:

        Not later than January 1, 1995 and every 5 years thereafter, the
        Administrator of the Environmental Protection Agency (EPA) shall
        transmit to the Congress a report containing an inventory of national
        annual sulfur dioxide (SO2) emissions from industrial sources (as defined
        in title IV of the Act), including.units subject to section 405(g)(6) of the
        Clean Air Act (CAA), for all years for which data are available, as well
        as the likely trend in such emissions over the following 20-year period.
        The report shall also contain estimates of the actual emission reduction
        in each year resulting from promulgation of the diesel fuel
        desulfurization regulations under section 211(i) of the CAAA of 1990.

    It should be noted that although section 406 references diesel fuel desulfurization
regulations under section 214, the diesel fuel desulfurization regulations are actually
specified in section 211(i) of the 1990 CAAA.

    Industrial  sources are defined in section 402(24) of the 1990 CAAA. An industrial
source is:

        a unit that does not serve a generator that produces electricity, a
        "nonutility unit" as defined in this section, or a process source as defined
        in section 410(e).

A nonutility unit is defined in section 402(25) as "a unit other than a utility unit."
Although reference is made to a process source definition in section 410(e), section 410(d)
 actually deals  with process sources,  but no definition of a process source is given.  For the
 purposes of this report, a process source is any source that emits SO2 as the result of the
 production or manufacturing process and not as the result of any type of fuel combustion.

     Section 406 also provides that whenever the inventory required by this section
 indicates that sulfur dioxide emissions from industrial sources, including units subject to
 section 405(g)(5) of the CAA, may reasonably be expected to reach levels greater than 5.60
 million tons per  year, the Administrator of the EPA shall take such actions under the
 CAA as may be appropriate to ensure that such emissions do not exceed 5.60 million tons
 per year. Such actions may include  the promulgation of new and revised standards of
 performance for new sources, including units  subject to section 405(g)(5) of the CAA,


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under section lll(b) of the CAA, as well as promulgation of standards of performance for
existing sources, including units subject to section 405(g)(5) of the CAA, under authority
of this section.  Although the act refers to 405(g)(5), the actual reference should be
405(g)(6).                             '

    This report fulfills the requirements of section 406 by presenting information related
to 1) historic emissions from industrial SO2 sources, 2) current emissions from industrial
SO2 sources (i.e., a baseline emission inventory), 3) emission projections for a 20-year
period from the baseline emission inventory, and 4) emission reductions related to
changes in the diesel fuel desulfurization regulations. Chapter 2 of this report examines
historic emissions from industrial SO2 sources.  For the purposes of this report, historic
emissions are considered to be emissions prior to 1985. 1985 was chosen as the cutoff for
historic emissions for several reasons.  First, the 5.60 million tons per year level
mentioned in section 406 is derived from data collected during the development of the
1985 National Acid Precipitation Assessment Program (NAPAP) emission inventory effort.
Second, an evaluation of the differences between emission estimates developed as part  of
the 1985 NAPAP emission inventory and those developed by EPA for publication in the
annual report commonly referred to as the Emission Trends report, indicates that, while
the total national emissions estimates are similar, there are large differences between the
two inventories at the individual source category level and the 1985 NAPAP inventory is
thought to be a more comprehensive inventory.  Finally, the method used to estimate
emissions as part of EPA's current Emission Trends estimation procedure now
incorporates a method that is more closely aligned with the 1985 NAPAP inventory effort
than with the previous Emission Trends  method, thus 1985 represents a more appropriate
break between historic emissions and current emissions.

    Chapter 3 presents a broad overview of the differences between the emissions
estimated as part of the 1985 NAPAP emission inventory effort and the corresponding
emissions developed as part of EPA's Emission Trends effort.  Chapter 4 presents the
baseline emission inventory developed for this report. This baseline inventory represents
the year 1990.  1990 was  chosen to be consistent with the year of enactment of the CAAA.
Data are also presented for the years 1991-1993 in this chapter.  Chapter 5 presents the
emission projections for the "period 1994-2015 developed from the baseline 1990 emission
inventory. Chapter 6 describes emission reductions resulting from institution of the diesel
fuel desulfurization regulations.
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                                 CHAPTER  II
              HISTORIC  INDUSTRIAL SO2  EMISSIONS
A.  INTRODUCTION

    EPA has been preparing emissions estimates for industrial SO2 sources for a number
of years. These estimates have been prepared either as part of large-scale, bottom-up
emission inventory development efforts (such as the 1980 and 1985 NAPAP emission
inventories) or as part of EPA's on-going Emission Trends effort. As a consequence,
national emissions estimates for industrial SO2 sources are available from 1900 to the
present. This chapter presents historic national industrial SO2 emissions estimates for
the period 1900-1984. As indicated in Chapter 1, historic emissions estimates are
considered to be all emissions estimates developed prior to 1985, since the 1985 NAPAP
emission inventory served as the basis for the section 406 requirements.

    EPA has recently instituted a "tiered" source category assignment mechanism which
can be used to summarize emissions on a consistent basis. This system is comprised of
three tiers.  Tiers 1 and 2 are identical for all pollutants. Tier 3 categories are pollutant
specific. Additionally, a distinct naming convention has been instituted with the tier
categorization.  Tier 1 category names are given in all capital letters.  Tier 2 names are
given with the first letter of each word capitalized.  Tier 3 categories are shown in all
lower case letters.  Information presented in this report is consistent with that naming
convention.  For example, a full tier category name for distillate oil emissions from
industrial boiler operation would be:

                Tier 1 Name     FUEL COMBUSTION - INDUSTRIAL
                Tier 2 Name     Oil
                Tier 3 Name     distillate

    Information presented in this report is provided using the tier categorization scheme.
In some cases several tiers are combined together for presentation purposes. However,
when this combination is made, the naming convention is maintained.  For example, in
Figure II-l, ALL OTHER INDUSTRIAL is not a true Tier 1 category name, but
represents the sum of all the other Tier  1 industrial source emissions not presented
individually. Additional information concerning the tier categorization scheme can be
found in Barnard et al., 1993.

    In addition, historic SO2 emissions for selected industrial source subcategories (i.e.,
Tier 2 or 3 levels) are presented at 10-year intervals for the period 1940-1980.
Information presented in this chapter at the Tier 2 level or below is only provided from
, 1940-1980.  Differences in the way emissions estimates were developed for years  prior to
1940 prohibit Tier 2 or 3 reporting.
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    The original inventories, and large accompanying sets of now widely distributed
emission factors and activity data  have all been reported in English units; the estimated
emissions in this report also are reported in English short tons.

B.  NATIONAL LEVEL HISTORIC INDUSTRIAL SOURCE SO2 EMISSIONS
    ESTIMATES

    Figure II-l presents national level historic industrial source SO2 emissions estimates
for the period 1900-1984. Industrial SO2 emissions can result from industrial fuel
combustion, chemical and allied product manufacturing, metals processing, petroleum and
related industries, solvent utilization, storage and transport activities, industrial waste
disposal and recycling activities, and other industrial processes.  Figure II-l clearly shows
that two categories, industrial fuel combustion and metals processing, have historically
been the largest contributors to industrial source SO2 emissions. The 5.6 million ton cap
specified in section 406 is included for reference purposes in Figure II-l.

    Figure II-l also clearly, indicates the overall trend in emissions during the period
1900-1984.  From 1900 to the late 1920s, industrial source emissions steadily increased to
levels slightly below 8 million tons. However, the effects of the depression of 1929  can
clearly be seen in Figure II-l. Emissions from industrial sources dropped from peak pre-
depression levels of approximately 8 million tons to close to 5 million tons during the
depression years.

    Dramatic increases in industrial source SO2 emissions resulted from the increased
industrial activity resulting from the onset of World War II, with peak emissions levels of
approximately 10 million tons in the mid-1940s.  Emissions then declined to levels
approximately the same as those of the 1920s during the post-war years (i.e., late 1940s-
mid 1950s).

    From the early 1960s, industrial SO2 emissions begin increasing steadily, reaching the
highest estimated levels of slightly less than 12 million tons in 1970.  Since 1970,
industrial SO2 emissions have steadily declined to levels approximately the same as the
early 1900s and the depression years.  1970 marked the passage of the Clean Air Act of
1970 CCAA).

C.  HISTORIC EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
     SUBCATEGORIES

     As indicated above, industrial fuel combustion and metals processing are the two
major industrial source Tier 1 category contributors, to historic industrial SO2 emissions
estimates from 1900-1984.  Figures II-l through II-5 provide additional detail related to
the Tier 2 and 3 subcategories that are the major contributors to the Tier 1 categories
shown in Figure II-l.

     1.  Fuel  Combustion

     Figure II-l clearly indicates that  industrial fuel combustion is the largest contributor
to industrial source SO2 emission  on an historic basis.  Figure II-2 provides a breakdown


  Development of an Industrial SO,                                               Historic Emissions
  Emissions Inventory Baseline and 1995            Page 4
  Report to Congress

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                                                                               '2
of emissions contributions from industrial combustion by fuel type at 10-year intervals for
the period 1940-1980. Coal burning is the major contributor to industrial combustion SO
emissions over this period. However, coal burning emissions show a steady decline from
slightly over 5 million tons in 1940 to approximately 1.5 million tons in 1980.

    Emissions from the burning of oil at industrial facilities has increased during the
same time period, from just over 0.5 million tons in 1940 to slightly over 1 million tons in
1980.  Peak emissions occurred in 1970 during the time period examined.

    Emissions of SO2 from the combustion of gas and other fuels have been relatively
small. Emissions accompanying gas burning have remained virtually constant over the
1940-1980 time period, while emissions from other fuels have steadily declined.

    2.  Metals Processing

    Metals processing has historically been the second largest industrial SO2 emissions
source. In particular, copper smelting activities have historically produced large SO2
emissions.  Figure II-3 clearly shows the dominance of copper producing activities in
production of SO2 emissions.  From 1940-1970, copper production contributed over twice
as much SO2 than any other metals processing operation.  However, the collapse of the
copper market in the 1970s has resulted in a dramatic decrease in copper smelting
activities.  This can be clearly seen in Figure II-3 where emissions levels dropped  from
approximately 3.5 million tons in 1970 to just over 1 million tons in 1980.

    Emissions from other metals processing sources show different patterns  than  that
exhibited by copper processing.  Lead processing emissions have declined slightly  over the
same time period.  However, aluminum processing emissions have increased during the
same timeframe.  Other nonferrous metal processing emissions have decreased steadily
since the 1950s.  Ferrous metals processing emissions have remained approximately the
same from 1940 to 1980.

    3.   Chemical and Allied Product Manufacturing

    Figure II-4 indicates that for the period  1940-1980, the only subcategory source of any
importance with respect to SO2 emissions from chemical and allied product manufacturing
is the production of inorganic sulfur compounds. These emissions increased steadily from
 1949 until 1970 producing peak emissions of approximately 0.6 million tons. By 1980,
however, the emission levels from this source were less than half the 1970 levels. Other
 chemical manufacturing activities provided minor emissions in 1980.

     4.  Petroleum and Related Industries

     SO2 emissions from petroleum and related industries (Figure II-5) generally show
 steadily increasing emissions from the 1940s to the 1970s, with slight declines after  1970.
 None of the emissions from the subcategories detailed in Figure II-5 are above 0.5 million
 tons even at their peak emissions levels. Fluid catalytic cracking units at petroleum
 refineries are the single largest subcategory contributor to SO2 emissions from petroleum
 and  related industries.
Development of an Industrial SO2                                               Historic
Emissions Inventory Baseline and 1995            Page 5
Report to Congress

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    5.   Other Industrial Processes

    Figure II-6 presents historic SO2 emissions from other industrial processes. Cement
manufacturing clearly is the largest contributor among these industrial source
subcategories, with emissions increasing from slightly over 0.3 million tons in 1940 to
over 0.6 million tons in 1980.  Figure II-6 also indicates that SO2 emissions from Wood,
Pulp and Paper, and Publishing activities have steadily increased through the same time
period, with 1980 emissions levels exceeding 0.2 million tons.

D.  HISTORIC EMISSIONS SUMMARY

    There are two principal routes by which industrial SO2 emissions reach the
atmosphere: fuel combustion and process releases. On a percentage basis, the industrial
sector's contribution to total U.S. emissions of SO2 has declined from about 50 percent in
1940 to approximately 25 percent in 1980.

    The downward trend, since the 1970s, in collective SO2 emissions from industrial fuel
combustion and process emissions could be attributed, at best, to cleaner operations; at
worst, to a dwindling industrial sector. Actually some of both, and more, unquestionably
is occurring as the complex U.S. economy evolves.  Figure II-7 compares trends in
industrial SO2 emissions with primary energy expended by the combustion of fossil fuels
in the industrial sector since 1950, in British thermal units (Btus) (Energy Information
Admin., 1993). This figure appears to show that in the 1950s and 1960s both SO2
emissions and industrial activity were increasing  along roughly parallel courses.
Electricity, classified as a secondary energy form, is excluded in this analysis. Through
the 1970s and 1980s, however, estimated industrial SO2 emissions decreased markedly
while primary energy expended in the industrial sector has fluctuated only gradually
downward.  Some of this reduction in primary industrial energy use can be credited to
increased efficiencies as new equipment and processes have been phased in.  Some can
also be attributed to overseas transfers. Certainly a portion results from  conversions to
electrically powered equipment, which merely transfers SO2 emissions out of the
industrial category and into the already sizeable electric utility category (if this electricity
was supplied by electric utility generators rather than industrial generators). Thus, the
actual trend in industrial activity may be more positive than this primary energy
indicator implies.  Consequently, use of a primary energy indicator as a surrogate for
evaluating emissions may provide a conservative assessment of the real and substantial
reduction in SO2 emissions, collectively, by the industrial sector of the U.S. economy.
Interestingly, the decrease in industrial emissions occurs starting in 1970, coincident with
the passage of the Clean Air Act of 1970.

    Figure II-8 shows the subcategory of industrial SO2 emissions from fuel combustion,
partitioned by the principal fuel types:  coal, oil, and natural gas. Emissions from
industrial combustion sources burning coal evidence the most reduction.  The bars in
Figure II-8 depict the same index of industrial activity used in Figure II-7. The
decreasing trend in the combustion component of industrial SO2 emissions through the
1960s took place while industrial energy use was  increasing; more recently, both
industrial combustion-generated SO2 emissions and primary energy use have leveled off.
  Davetopmant of an Industrial SO,                                               Historic Emissions
  Emissions Inventory Baseline and 1995            Page 6
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    Three industrial source categories contribute the majority of process-related SO2
emissions: chemical manufacturing and related products, metals refining and processing,
and petroleum refining and related products. The largest contributing category, metals,
increased its process emissions in the initial post-war decades, overriding reductions in
the combustion category.  In the 1970s and 1980s, process emissions from these sources
have substantially decreased.  Figure II-9 shows both industrial process emissions as well
as a surrogate indicator of emission, an economic index for the predominant source
category (the metals industry) compiled by the Federal Reserve (Statistical Abstracts,
1993). Apart from its somewhat conspicuous rise in 1965, this economic index exhibits a
pattern generally similar to that of primary energy use (as shown in Figure II-8).
Through the 1960s, both the process SO2 emissions and the economic index trended
generally upward. Subsequently, the economic index has leveled off or declined slightly,
while process emissions (most conspicuously from the metals category) have declined
markedly.

    In summary, this analysis indicates that the most significant reductions in
combustion emissions of SO2 by U.S. industries occurred early in the post-war period;
concurrently, process emissions were rising, resulting in  a net increase from the industrial
sector.  Through the  1950s and 1960s, the collective upward trend in estimated industrial
SO2 emissions occurred while the industrial sector of the U.S. economy, as gauged by two
indicators: energy use and an economic index of the metals industry, was also growing.
Since the 1970s, marked reductions in process emissions have been achieved, principally
in metals refining and processing leading to declining industrial SO2 emissions during a
period when industrial activity levelled off or perhaps declined slightly. Again, this
decrease is coincident with the passage of the CAA of 1970.
  Development of an Industrial SO.,                             .                   Historic Emissions
  Emissions Inventory Baseline and 1995            Page 7
  Report to Congress

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                                CHAPTER III
    SUMMARY CHAPTER COMPARING EMISSIONS  FROM
                    BASELINE ANALYSIS  REPORT
    Section 406 of the 1990 CAAA requires that the Administrator of the Environmental
Protection Agency transmit to Congress a report containing a national inventory of annual
sulfur dioxide (SO2) emissions from industrial sources not later than January 1, 1995 for
all years for which data are available, as well as the likely trend in SO2 emissions over
the following 20-year period (1995-2015).  Under the Act as amended, 1985 served as the
baseline for the 5.6 million tons industrial SO2 emission limit referred to in section 406.
To provide the 1995 analysis mandated by Congress, the 1985 baseline data must first be
examined to identify strengths and weaknesses in the available emissions and supporting
data. This chapter presents a summary of the analysis presented in the "Comparison of
the 1985 NAPAP Emissions Inventory with the 1985 EPA Trends  Estimates for Industrial
SO2 Sources" (EPA, 1994) (hereinafter referred to as the Comparison). The two major
sources of 1985 industrial emission data available at the time: the 1985 National Acid
Precipitation Assessment Program (NAPAP) Emissions Inventory  (EPA, 1989) and the
1985 National Air Pollutant Emission Estimates (EPA, 1992), referred to as the "Old
Trends" emission estimates, are compared in the report.

A. 1985 NAPAP EMISSION  INVENTORY VERSION 2

    The 1985 NAPAP emission inventory effort supported joint acid precipitation.
•deposition research with Canada, including atmospheric modeling, through
comprehensive, detailed source emission estimates provided by local and state agencies.
An inventory of emissions and facility data representing point and area source
classification code (SCO-level operating characteristics for 1985 was developed to provide
information for assessing acid deposition problems.  The U.S. portion of the 1985 NAPAP
Emissions Inventory covers the 48 contiguous states and the District of Columbia.  It is a
"bottom-up" inventory and should be considered a snapshot of the 1985 emissions.  The
SO2 emission data for significant [> 100 tons per year (TPY)] sources were systematically
quality assured, with greater effort expended on larger sources. The inventory included a
unique confirmation step, allowing individual plants emitting at least 2,500 TPY to review
their emission estimates prior to finalization. The resulting inventory is widely regarded
as the most comprehensive and accurate national inventory compiled to date.

     1.   Methodology

     The U.S. anthropogenic emissions data were collected through the EPA emissions
inventory data system known as the National Emissions Data System (NEDS) (EPA
 1986).  The annual anthropogenic  emissions are divided into two major categories, point
 and area sources. Point sources have precise location data and emit at least 100 TPY of
  Development of an Industrial SO.,                                                  Comparison
  Emissions Inventory Baseline and 1995            Page 17
  Report to Congress

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any of the criteria* pollutants: sulfur dioxide (SO2), nitrogen oxides (NOX), volatile organic
compounds (VOC), total suspended particulate (TSP)b, or carbon monoxide (CO). The U.S.
point source emissions and facility data were collected by state agencies using the NEDS
methodology.  In that methodology, process-level emissions were estimated directly for
each source. The emission estimates were based on source tests, emission factors, or
material balance. In some cases, when no other information was available, engineering
judgement was used to estimate the emissions.

    The U.S. point source facilities and emissions data were prepared by the state air
agencies and delivered to NAPAP through the EPA Regional Offices.  NAPAP worked
closely with the Office of Air Quality Planning and Standards  (OAQPS) to process the
point source data through NEDS.

    Emissions and facility data were requested for point source facilities that emitted at
least 100 TPY of SO2, NOX, VOC, TSP, or CO during 1985. An extensive quality
assurance and quality control (QA/QC) program was conducted during the  inventory
development process to correct erroneous, questionable, or missing data elements for a list
of high priority point source data items.  The QA/QC effort focused on points that emitted
at least 25 TPY that were located  at plants that emitted at least 1,000 TPY of any of the
three priority pollutants SO2, NOX, and VOC.

    Some states were able to provide emissions data for facilities that had emissions of
criteria pollutants below the target reporting levels. Those emissions records were
removed from the point source inventory and included as county-level area source
categories for minor  point sources.

    An inventory of area source emissions was developed to account for emissions from
sources that were not included in the point source inventory. .The area source inventory
was developed through a process quite different from the point source inventory. Area
source  emission  estimates were calculated by multiplying the  activity rate for each area
source  category by an emission factor. The activity rate data  from the United States were
developed through statistical procedures based on distributions of national activity rate.
Generally, emission factors developed by EPA were applied to the allocated activity levels
to produce annual emissions estimates for each area source category.

     The majority of industrial SO2 emissions as reported in the 1985 NAPAP emission
inventory are reported as point sources.  Over 4,000 industrial facilities were listed as
 emitting SO2, one third of these facilities emitted a small amount of SO2 (< 100 tons of
 SO2). About 130 facilities account for approximately 50 percent of the industrial SO2
    "The CAA requires that the EPA Administrator publish a list of pollutants that have adverse effects on
 public health or welfare, and which are emitted from numerous and diverse stationary or mobile sources. For
 each pollutant, a "criteria" document must be compiled and published by the Administrator. The criteria are
 scientific compendia of the studies documenting adverse effects of specific pollutants at various concentrations
 in the ambient air. For each pollutant, National Ambient Air Quality Standards (NAAQS) are set at levels
 which, based on the criteria, protect the public health and the public welfare from any known or anticipated
 adverse effects. Regulated pollutants are therefore referred to as "criteria pollutants."

    "The current regulated size of particulate is < to 10 microns.


   Davolopmont of an Industrial SO2                                                     Comparison
   Emissions Inventory Baseline and 1995            Page 18
   Report to Congress

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 emissions. Based on data from the 1985 NAPAP inventory only 500 facilities account for
 80 percent of the industrial SO2 emissions.

     2.   Quality Assurance and Quality Control (QA/QC)

     The QA/QC activities were major efforts for the 1985 NAPAP Emissions inventory.
 The inventory data was collected through a cooperative effort involving EPA and the
 states. Early in the inventory planning, a decision was made to involve the state agencies
 to the maximum extent possible.  The 1985 NAPAP Emissions Inventory Version 2 is the
 first inventory to be developed with significant and repeated input from state agencies.
 Thus, the inventory is considered the most complete and accurate national inventory of
 air pollutants ever assembled.                  .       :

     The state inventories were submitted to EPA and subjected to various automated and
 manual quality  control checks.  As problems or questions were identified, procedures were
 implemented to refer these problems back to the state agencies for comment and/or
 correction. Each state was given two opportunities to review its entire point source
 inventory. The  state-level area source inventories developed by EPA were also submitted
 to each state for review.

     Specific  QA/QC procedures applied to the state annual inventories included checks for
 completeness, range checks, a separate analysis of utility records, an emissions
 confirmation by the  facilities-for the largest emitters and identification of emission values
 for a list of priority data items. All questions were referred back to the participating state
: agencies for  resolution. Although most problems were resolved through the state
 agencies, EPA corrected remaining problems involving emission and erroneous data.
 Many of the  additional corrections were addressed by the substitution of default
 parameters.                           .               .              -

 B.  1985 EPA NATIONAL AIR POLLUTANT  EMISSION  ESTIMATES

     The Trends emission estimates represent both current and historic emissions (1900 to
 present) and are compiled annually by OAQPS.  The annual Emissions Trends document
 presents the most recent estimates of national emissions of the criteria air pollutants.

     The emissions of each pollutant are estimated for many different source categories,
 which collectively account for nearly all anthropogenic emissions. The document presents
 the total emissions from all 48 contiguous states, Alaska, Hawaii, and the District of
 Columbia. The emission trends are the net effect of many factors, including changes in
 the nation's  economy and in industrial activity,  technology, consumption of fuels, traffic,
 and other activities which cause air pollution. The trends also reflect changes in
 emissions as a result of air pollution regulations and emission controls.  The emission
 trends presented in  the "Old Trends" document are based on consistent methods applied
 to all years.  The "Old Trends" emission estimates were developed for comparative
 purposes and the use of "Old Trends" emission estimates as an absolute value for any
 given year is inappropriate.
  Development of an Industrial SO2     '                                               Comparison
  Emissions Inventory Baseline and 1995           Page 19
  Report to Congress

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    National emissions are estimated annually by the U.S. EPA based on statistical
information about each source category, emission factors, and control efficiency.  The
estimates are made for over 450 individual source categories that include nearly all major
sources of anthropogenic emissions. The emission estimates for individual source
categories are aggregated to show the emission trends at the national levels by major
source category.

    Since it is impossible to annually measure the emission of every source individually, a
"top down" estimating procedure must be used.  The emissions are calculated either for
individual sources or for many sources combined, using indicators of emissions.
Depending on the source category, these indicators may include fuel consumption or
deliveries, raw material processed, etc.  When indicators are used, emission factors which
relate the quantity of emissions to the activity indicator must also be used.  This approach
provides a consistently derived national emission estimate at the emission category level
(e.g., industrial oil combustion) rather than the source (e.g., boiler) level.

    The basic "top down" calculation procedure may be represented by the following
equation:
 where:
     E   =    emissions
     p   =    pollutant
     s   =    source category
     A   -    activity level
     EF =    emission factor
     C   =    percent control efficiency
     National activity indicators for individual source categories are obtained from many
 different publications. Emission factors are generally obtained from the U.S. EPA's
 Compilation of Air Pollutant Emission Factors, AP-42 (EPA 1991).  The overall control
 efficiency of a source category was derived from NEDS.

     An exception to this approach is copper smelters.  SO2 emissions for this source were
 obtained from the plants directly through the respective state air pollution agencies.
  C. ANALYSIS0
     This section summarizes the analysis of the derivation of the individual industrial
  category 1985 emission estimates from NAPAP and "Old Trends" as presented in the
  Comparison.  Such an analysis is complicated by several factors:
     The source categories in this chapter are the same as those presented in the Comparison and do not
  match with those in the rest of the report.


   Development of an Industrial SO2                                                    Comparison
   Emissions Inventory Baseline and 1995            Page 20
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    •   1985 NAPAP is comprehensive and includes all reported industrial
        emission categories.  "Old Trends" is limited to categories thought to
        emit at least 10 thousand metric tons (11 thousand short tons) of a
        criteria pollutant per year.

    •   1985 NAPAP is source and plant specific. "Old Trends" is national and
        category-specific.  There is no opportunity to match individual data
        values between the inventories; in fact, category definitions differ
        between the two inventories.

    •   The 1985 NAPAP inventory is a single year inventory published in
        November of 1989 and is not updated. The "Old Trends" methodology
        was first applied  to 1985 in the annual report published in January of
        1987;  subsequent annual reports include adjustments to prior years
        based on the most current emission factors (dependent on time and
        resources).

    The Comparison presents a highly detailed view of the two inventories on a category
 by category basis, principally relying on emission activity (throughput data).
 Methodologies, data sources, emissions, and assumptions are documented and analyzed in
^as much detail as possible so that this information need not be recompiled for future
 examination. The analysis proved complex, especially when disaggregating data to create
 comparable categories between NAPAP and "Old  Trends" data sets, and raised a number
 of questions. (In particular, categories with significant in-process fuel emissions such as
 cement proved difficult to assess because the process and fuel emissions were treated
 differently in each data set.)

    The 1985 EPA "Old Trends" and 1985 NAPAP emission estimates and their
 differences are presented in Table III-l and Figure III-l. Overall, the two 1985 estimates
 (NAPAP and "Old Trends") compare favorably: NAPAP estimates 5.6 million tons SO2 (as
 reflected in the CAAA) and "Old Trends" estimated 6.0 million short tons.  When broken
 down, however, the two estimates show greater divergence for individual source
 categories.  The "Old Trends" estimate was larger than the 1985 NAPAP estimate and did
 not include as many source categories. The "Old  Trends" estimate systematically
 overestimated emissions, relative to the NAPAP inventory, and therefore on aggregate the
 estimates are very similar. The primary reason for the overestimation in the "Old
 Trends" method was the exclusion of SO2 control  technology for some categories. Several
 categories exceeding 100,000 tons of SO2 differ by more than 50 percent between the two
 data sets:  primary lead and zinc, iron and steel,  oil and natural gas production, pulp and
 paper, and cement.

     1. Combustion Sources

     The combustion estimates in "Old Trends" (2.5 million tons) and NAPAP (2.6 million
 tons) are very similar. This is due in part to the  method utilized by NAPAP to estimate
 area source emissions. In the NAPAP inventory, the industrial point source fuel usage is
 subtracted from national fuel use estimates provided by the Department of Energy, and
 emission from the unaccounted for fuel are allocated to the area source inventory. This
 method of determining area source emissions or alternatively of accounting for emissions

  Development of an Industrial SO2                                                   Comparison
  Emissions Inventory Baseline and 1995           Page 21
  Report to Congress

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from unaccounted for fuel use has several drawbacks.  First, many sources do not report
fuel use. Second, the state of Texas does not report any individual fuel use.  Instead, all
industrial fuel use reported in Texas is at the county level to ensure confidentiality. As a
result, the initial fuel use estimate  from point sources in Texas, reported through NAPAP,
is believed to be an underestimate.  Consequently, the NAPAP inventory may allocate too
much fuel to the area sources and,  therefore, too many fuel-related emissions to the area
source inventory.

    In the coal category for both the NAPAP (1.7 million tons) and the "Old Trends" (1.8
million tons) emission estimates, the majority of the emissions are from the combustion of
bituminous coal. The average sulfur content that is used in the computation of the
emission factor is extremely important. The "Old Trends" method has a complicated
procedure to determine an average fuel sulfur content based on statistics for the coal-
producing regions. The NAPAP estimate was reported by the source or State and may or
may not have been estimated using emission factors.  Therefore, it is not possible to
compare the average sulfur content used in the "Old Trends" methodology to the sulfur
content reported in NAPAP.  Additional research into average sulfur contents for all of
the fuels (bituminous coal, anthracite, lignite, residual oil, distillate oil, crude oil, and
process gas) would be needed to complete the comparison.

    2.  Nonferrous Smelting Sources

    Nonferrous smelting emissions are an important component of industrial SO2
 emissions because sulfur is present in the ores.  Consequently, sulfur recovery is an
 important component of the emission estimate.  The "Old Trends" method determines
 sulfur recovery through statistics reported through the Department of Interior s Minerals
 Yearbook. The "Old Trends" method includes emission estimates for primary copper,
 primary lead, primary zinc, primary aluminum, and secondary lead smelting.

     The primary copper estimates  were obtained on a point by point basis from domestic
 primary copper smelters obtained  through the EPA State or Regional offices. As a result
 the "Old Trends" (645 thousand tons) and NAPAP (655 thousand tons) estimates are
 consistent for primary copper smelters.

     The "Old Trends" method appears to overestimate the  emissions from primary lead,
 primary zinc, primary aluminum,  and secondary lead smelting.  The primary lead and
 primary zinc estimates are combined and reported as 242 thousand tons in the Old
 Trends" document.  The emissions in NAPAP are reported as only 106 thousand tons.
 "Old Trends" assumes that all  roasting is done in a multiple hearth roaster which has an
 emission factor of 1,100 Ibs/ton of concentrated  ore processed. NAPAP did not report the
 majority of emissions through the multiple hearth roaster.  Two other roasting processes,
 flash roaster and fluid bed roaster were reported in NAPAP with smaller emission factors
  of 404 4 and 223.5 Ibs/ton of concentrated ore processed, respectively.  Thus differences in
  the emission factors and the type  of roaster account for the majority of the differences
  between the two estimates for  these sources.

     The "Old Trends" emission estimate of 71 thousand tons of SO2 from primary
  aluminum smelters differs from the NAPAP emission estimate of 58 thousand tons of SO2.
  This difference is attributed to a higher emission factor and no controls for the Old

                . _,   • , »<-i                                                   Comparison
   Development of en Industrial SO2
   Emissions Inventory Baseline and 1995           Page 22
   Report to Congress

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 Trends" emission estimates.  The secondary lead emission estimate of 26 thousand tons of
 SO2 reported in "Old Trends" is slightly higher than the 21 thousand tons of SO2 reported
 in NAPAP due to the absence of control efficiency information for this source in the "Old
, Trends" methodology.

     3.  Other Industrial Process Sources

     Significant differences exist in the 1985 "Old Trends" (2.5 million tons) and NAPAP
 (2.1 million tons) SO2 emissions estimates for other industrial process emissions.  In
 general, the "Old Trends" estimates depend on national production figures developed by
 the Department of Energy and the Department of Commerce and an emissions factor.
 The emission factor chosen often represented the largest source(s) of emissions within the
 category. To compare the NAPAP and "Old Trends" estimates, the entire NAPAP
 estimate for the category is used. This would include in-process fuel, fugitive emissions,
 and processes that are not specifically cited in the "Old Trends" method.

     The NAPAP inventory includes many additional source categories that are not
 included in the "Old Trends" industrial SO2 emission estimation method.  The "Old
 Trends" method includes only three categories in the chemical manufacturing group:
 sulfur, sulfuric acid, and carbon black.  The NAPAP inventory includes ten additional
i chemical manufacturing source categories with  combined additional emissions of 127
 thousand tons of SO2.  The "Old Trends" method includes three categories in the mineral
.products manufacturing group; cement, glass, and lime. The NAPAP inventory includes
 nine additional mineral products manufacturing source categories with combined
 additional emissions of 51 thousand tons of SO2.

     The "Old Trends"  method, with very few exceptions, does not include the effects of air
; pollution control devices unless the effects are inherent in either the process (e.g., sulfur
.recovery) or in the emission factor.  The "Old Trends" estimates for most categories are
 significantly higher than the corresponding NAPAP estimates. A major exception to this
 is oil and natural gas  production.

     As a result, the net difference between NAPAP and "Old Trends" for other industrial
 process sources is 380 thousand tons. This is a result of overestimating the "Old  Trends"
 source categories by not applying controls (616 thousand tons) and excluding the  source
 categories listed above (236 thousand tons).

 D.  CONCLUSIONS

     The following conclusions were drawn as a result of the in-depth analysis reported in
 the Comparison of the 1985 NAPAP data and the October 1992 EPA "Old Trends" report
 for industrial sources.

     The "Old Trends" methodology uses broad assumptions for emission factors and
 controls across a source category.  Adjustments for individual plant controls and operating
 characteristics are impossible. Some industrial emission categories, notably processes
rwithin oil and natural gas production, are missing from the "Old Trends" method. The
 "Old Trends" method contains outdated activity and emission factor data that have been
  Development of an Industrial SO2                                                   Comparison
  Emissions Inventory Baseline and 1995           Page 23
  Report to Congress

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revised after the initial estimations were made. The "Old Trends" method relies on
average fuel consumption values for some industrial processes and does not account for
any control measures in the majority of the industrial SO2 emission estimates.

    Activity data in the 1985 NAPAP inventory were not subject to the same standard of
QA or completeness checking as emissions data.  Some data were unreported due to
confidentiality restrictions, and activity data from small sources (i.e., < 100 TPY) passed
only the grossest QA checks.  The accuracy and representativeness of activity data in the
NAPAP inventory are hest evaluated source by source; category-level summaries are
unreliable without adjustments. The NAPAP activity data are not complete enough to
provide a reliable estimate of industrial production; therefore, the NAPAP activity data do
not support the generation of source category level emission factors or control efficiencies
for future use in the "Old Trends" methodology.

    Overall, the two 1985 estimates (NAPAP and "Old Trends") compare favorably at the
national level: NAPAP estimates 5.6 million tons SO2 and "Old Trends" estimates 6.0
million tons SO2. There are , however,  individual source category by source category
discrepancies.  The 1985 NAPAP inventory still represents the most comprehensive and
accurate emission estimates for 1985 because of its rigorous QA of emissions and bottom-
up derivation. Therefore, the NAPAP estimate, which is the basis for the  emission cap in
the CAAA, should be used as the starting point for all future comparisons.
  Dovolopment of an Induslrial SO,                                                   Comparison
  Emissions Inventory Baseline and 1995           Page 24
  Report to Congress

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                                  Table 111-1
    Differences between 1985 Trends and NAPAP SO2 Emission Estimates
                            (thousand short tons)

Source Category
COMBUSTION
Coal
anthracite
bituminous
Oil
residual
distillate
Natural gas
Wood
Miscellaneous fuels
coke
coke oven gas
kerosene
LPG
other*
NONFERROUS SMELTING
Primary copper
Primary lead and zinc
Primary aluminum
Secondary lead
Other*
OTHER INDUSTRIAL PROCESSES
* Iron and steel
Iron and steel foundries
Oil and natural gas production
Pulp and paper
Cement
Glass
Lime
Sulfuric acid
Carbon black
Petroleum Refineries
Other*
TOTAL
'NOTE: * A list of sources can be found in *
Estimate for Industrial SO2 Sources
Emissions
"Old Trends"
2,467
1,841
9
1,832
537
467
70
2
6
81
35
43
3
<1

984
645
242
71
26

2,513
359

164
253
623
29
27
213
15
830

5,964
Comparison of the 1985

NAPAP
2,595
1,721
11
1,710
712
605
107
33
42
87
11
3
<1
<1
73
882
655
106
58
21
42
2,133
204
16
332
130
291
23
32
217
28
640
220
5,610
NAPAP Emissions

Delta
103tons
-128
120
-2
122
-175
-138
-37
-31
-36
-6
24
40
3

-73
102
-10
136
13
5
-42
380
155
-16
-168
123
332
6
-5
-4
-13
190
-220
354
Inventory with the

percent
-5%
7%
-18%
7%
-25%
-23%
-35%
-94%
-86%
-7%
218%
1333%
-100%

-100%
12%
-2%
128%
22%
24%
-100%
18%
76%
-100%
-51%
95%
114%
26%
-16%
-2%
-46%
30%
-100%
6%
1985 EPA Trends

Development of an Industrial SOZ
Emissions Inventory Baseline and 1995
Report to Congress
Page 25
                                    Comparison

-------
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   Davotopment of an Industrial SO2

   Emissions /nwentory Baseline and 1995

   Report to Congress
                            Page 26
                                                                                           Comparison

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                                 CHAPTER IV
       BASELINE INDUSTRIAL SO2 EMISSION  INVENTORY
 A.  INTRODUCTION

     As indicated earlier, the baseline for the 5.6 million ton "cap" on industrial SO2
 emissions is the 1985 NAPAP emissions inventory. This chapter presents information
 related to current emissions levels (1985-1990), selection of the appropriate emission
 inventory to use as the starting point for developing emission projections, the top 100
 industrial SO2 point source emitters (as derived from EPA's Aerometric Information
 Retrieval System [AIRS]), and information related to sources subject to section 405(g)(6).

 B.  CURRENT EMISSIONS LEVELS (1985-1990)

     Industrial SO2 emissions as reported in the 1985 NAPAP emission inventory were 5.6
 million tons.  Figure IV-1  provides emissions levels for industrial fuel  combustion, metals
 processing, chemical and allied products manufacturing, petroleum and related industries,
. and all other  industrial sources for the period 1985-1990. At the time of passage of the
 "1990 CAAA, industrial SO2 emissions were just under 5 million tons.

     The emissions estimates presented in Figure IV-1 are derived from EPA's Emission
«Trends document. Effective with the October 1993 edition of that report ("National Air
 Pollutant Emission Trends, 1900-1992," EPA-454/R-93-032), EPA instituted a new method
 of developing emission estimates for most sources. The new methodology utilizes an
 approach that is more representative of a "bottom-up" inventory approach than the old
 method, which was a "top-down" approach. The Trends emissions compared in the
 Comparison report described in the previous chapter were prepared using the old "top-
 down" approach. For many source categories, the new Trends method is analogous to the
 NAPAP method. As a  consequence, for many sources, values presented in the EPA
 Emission Trends report for 1985 are identical to the 1985 NAPAP emissions. This is the
 case for industrial SO2 sources.

     The new  approach to developing emission trends has been instituted for all years
 from 1985 forward (EPA, 1993a). The new emissions estimates are prepared using an
 approach that is similar to that used to develop the 1990 Interim Inventory (EPA, 1993b).
 The 1990 Interim Inventory utilized the 1985 NAPAP emissions inventory as the basis for
 developing 1990 emissions estimates for soine categories. The 1990 Interim  Inventory
 provides a point level emission inventory suitable for use in Regional  Oxidant Modeling
 (ROM). For industrial sources, 1990 Interim Inventory emissions estimates were
 developed using Bureau of Economic Analysis (BEA) growth factors to grow 1985 NAPAP
 emissions.  In a review of the SO2 emissions baseline used to develop  SO2 emission
 reductions under the CAAA of 1990, NAPAP's Office of the Director concluded that for
 nonutility sources, a method of estimating emission trends developed  by Argonne National
   Development of an Industrial SO-,                                              Baseline Emissions
   Emissions Inventory Baseline and 1995           Page 27
   Report to Congress

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Laboratory (ANL) for the Department of Energy (DOE) that extrapolated the 1985
NAPAP inventory using growth rates (which were based upon EPA's "Old Trends" values)
was preferred to the "top-down" approach in use by EPA at the time of the review for
developing emission trends (Mahoney, 1990).  EPA's new methodology for developing
emission trends now uses economic indices to develop emission trends, with the 1985
NAPAP emission inventory serving as the basis for many source categories. This
approach is consistent with the preferred approach of the NAPAP Office of the Director
and that used by ANL/DOE.  However, the new Trends methodology allows EPA to
update the data with reviewed and approved State emission inventory data when
available, thus it can account for plant-level operating changes and pollution control
initiatives that the ANL/DOE methodology cannot currently account for.

C.  CURRENT EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
    SUBCATEGORIES

    As Figure IV-1 indicates, emissions levels over the 1985-1990 time frame show a
moderate decline from 5.6 million tons to slightly less than 5 million tons. This section
looks at contributions from selected industrial source subcategories during that time
period.

    1.   Fuel Combustion

    As described in Chapter II, coal-related SO2 emissions dominate emissions from
industrial fuels. Emissions from oil  combustion have declined slightly from the 1985
NAPAP levels, while contributions from gas and other fuels have remained approximately
the same (see Figure IV-2).   Total industrial fuel combustion SO2 emissions for 1990 were
3,106 thousand tons.

    2.   Metals Processing

    Copper processing operations were the largest contributor to metals processing
 emissions according to the 1985 NAPAP emission inventory.  Figure IV-3 shows that
 emissions from copper processing operations have decreased dramatically from
 approximately 0.65 million tons in 1985 to slightly over 0.2 million tons in 1990.  A large
 part  of this decrease in emissions is attributable to the demolition of the  Phelps Dodge
 copper smelter (in Arizona) in January 1987, resulting in a decrease in emissions of
 330,000 tons/year of SO2. Emissions from other metals processing sources from 1985-1990
 have stayed  approximately the same. Total 1990 SO2 emissions for metals processing
 operations were 578 thousand tons.

    3.  Chemical and Allied  Product Manufacturing

    Figure IV-4 provides a noticeable contrast to the historic emissions picture given in
 Chapter II, Figure II-4. The major reason for the appearance of several of these
 categories is the change in emissions estimation methodology between the years  1984 and
 1985, for EPA's Emission Trends reporting. Emissions prior to 1985 were developed using
 the "top-down" methodology, while post-1984 were developed using the "bottom-up"
 method, which is capable of being summarized at the Tier 2 (or Tier 3) level. Tier 2 level


  Development of an Industrial SO,                                              Baseline Emissions
  Emissions Inventory Baseline and 1995           Page 28
  Report to Congress

-------
 emissions for this category could not be derived for the "Old Trends" method. Thus the
 abrupt inclusion of emissions from some chemical and allied manufacturing sources (e.g.,
 Organic Chemical Manufacturing) is an artifact, not the sudden appearance of new
 emissions sources.                    ;

    Figure IV-4 does show that for the period 1985-1990, inorganic sulfur compound
 production continues to dominate emissions from this category. Emissions from the other
 chemical processes remain relatively flat for this time period.  Total emissions in 1990
 from this category were 440 thousand tons.

    4.   Petroleum and Related industries

    Figure TV-5 shows emissions from petroleum and related industries from 1985-1990.
 This figure shows that natural gas production SO2 emissions are approximately the same
 as those from fluid catalytic cracking units at petroleum refineries. This is in distinct
 contrast to the information presented in Figure II-5 which showed that natural gas
 production SO2 emissions,  even as late as 1980, were approximately one-half those from
 fluid catalytic cracking units at petroleum refineries.  Figure IV-5 shows  that the .two
 petroleum refinery sources have decreased slightly from 1985 to 1990.  Natural gas
 production showed decreasing emissions until 1990, where a slight increase was observed.
 'Total SO2 emissions from petroleum and related industries for 1990 were 440 thousand
 tons.

    5.   Other Industrial  Processes

    As with  the historic emissions information presented in Chapter II, cement
 manufacturing is the leading other industrial processes subcategory SO2  emission
 producer.  This source does show a slight, but steady decline in emission from 1985 to
, 1990 (Figure IV-6).  Emissions from wood, pulp and paper, and publishing operations
 remained virtually constant over the same time frame, as did waste disposal operations,
 and the all other industrial processes categories.  Mineral products (excluding cement
 manufacturing) declined slightly over the period.  Total national SO2 emissions for 1990
 from other industrial processes were 417 thousand tons.

 D.  SELECTION OF THE EMISSION PROJECTIONS BASE YEAR INVENTORY

     Based upon the information presented above, EPA feels that the best inventory to use
 for developing the emission projections required under section 406 is the 1990 Emission
 Trends inventory. This decision was based on three criteria:

     •   It is based upon the 1985 NAPAP emission inventory, which is generally
         regarded as the most comprehensive inventory ever compiled,

     •   It is an outgrowth of the 1990 Interim Inventory which is currently being utilized
         in ROM modeling efforts and is generally regarded as the best national level
         inventory currently available, and

     •   The 1990 inventory coincides with the year of enactment for the CAAA.
  Development of an Industrial SO,                                              Baseline Emissions
  Emissions Inventory Baseline and 1995           Page 29
  Report to Congress

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E.  TOP 100 INDUSTRIAL SO2 POINT SOURCES

    Table IV-1 presents the current top 100 industrial point source SO2 emitters based on
information extracted from the AIRS Facility Subsystem (AFS) and reviews and updates
by State air pollution control agencies. The data presented in this table are not the same
as that found in the base year inventory used for projections.  The data in Table IV-1 are
presented for informational purposes only.  In addition to presenting information relative
to the emissions from these sources, information concerning the 4-digit Standard
Industrial Classification (SIC) code and SIC grouping, the latest year-of-record for
emissions, and the State, county and EPA region are also presented.

    Table TV-2 groups these top 100 industrial point sources by general industry
groupings, including SIC codes.  Figure IV-7 maps the locations of the sources listed in
Table IV-1 and classifies the emitters by the magnitude of their emissions.

F.  SECTION 405(g)(6) SOURCES

    Section 406(a) of Appendix B specifically states  that the Administrator of the EPA
shall transmit to Congress no later than January 1, 1995 and every five years thereafter a
report containing an inventory of national sulfur dioxide emissions from industrial
sources, including units subject to section 405(g)(6) of the CAA. Section 406(b) then states
that whenever the inventory required by section 406 indicates that sulfur dioxide
emissions from industrial sources, including units subject to section 405(g)(6) may
reasonably be expected to reach levels greater than 5.60 million tons per year, then the
Administrator of the EPA shall take such actions to ensure that such emissions do  not
exceed 5.60 million tons per year.

    Section 405(g)(6) indicates that the provisions of Title IV shall not apply to either
qualifying small power production facilities or qualifying cogeneration facilities or to a
new independent power production facility as defined by section 416  unless certain
conditions apply at the date of enactment of the CAAA of 1990.

    EPA's Acid Rain Division estimates that there are approximately 125 independent
power producers, and several hundred qualifying facilities exempt from Title IV under
 section 405(g)(6).  It is  not currently possible to estimate the emissions from these
facilities since no inventory currently includes these sources.  The emissions from these
 sources should be in the baseline inventory.  Many of these facilities have gas turbines
 and EPA's EDB is in the process of adding these facilities to the 1990 base year emission
 inventory.
  Development of an Industrial SO,                                               Baseline
  Emissions Inventory Baseline and 1995            Page 30
  Report to Congress

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                                     Table IV-1
          Top 100 AIRS/AFS Industrial Plants Emitting Sulfur Dioxide
Rank
1
2
3
4
5
6
7
8
g
10
11
12
13
14
15
16
17
18
19
20
21
22
23
24
' 25
26
27
28
29
30
31
32
33
34
35
36
37
38
39
40
41
... 42
43
-.. 44

EPA
Plant Name Region
ALCOA (Aluminum Company of America)
Copper Range Company
ASARCO Incorporated
ASARCO Incorporated
Shell Oil Co., Wood River Mfg. Complex
Dakota Gasification Company
Phelps Dodge Mining/Hidalgo Smelter
USS/Kobe Steel Co. - Lorain Works
Mead Corporation
Star Enterprise, Delaware City
ASARCO Incorporated
Kodak Park Div.
James River Corporation
Phillips 66 Company, Division of Phillips
Kennecott
ARMCO Steel Company L.P.
Phelps Dodge/Chino Mines
Mobil Oil Corp.
Bethlehem Steel Corporation
Exxon Co. USA
Mobil Joliet Refining Corp.
Wheeling Pittsburgh Steel Steubenville
Conoco Inc.
Inland Steel Flat Products, Part 2
Tenn Eastman Co.
Westvaco
Champion Int., Corp.
Fort Howard Corporation
Uno-ven Company
Florida Power
Union Camp Corp./Fine Paper Div.
Shell Western E & P
Reynolds Metals Co.
Grain Processing Corp.
ADM Corn Processing - Clinton
Carolina Power and Light Skyland
Clark Oil & Refining Corporation
Mobil Oil Corporation
PPG Industries
Goudey Station - Johnson
Westvaco Corp.
Pekin Energy Company
U.S. Doe Y-12 Plant
Magma Metals Company - San Manuel
Smelter
6
5
6
7
5
8
6
5
5
3
9
2
5
6
8
5
6
2
5
4
5
5
6
5
4
3
4
5
5
4
3
4
6
7
7
4
5
6
3
2
3
5
4
9

State
TX
Ml
TX
MO
IL
ND
NM
OH
OH
DE
AZ
NY
Ml
TX
UT
OH
NM
NJ
IN
AL
IL
OH
OK
IN
TN
MD
NC
Wl
IL
FL
VA
MS
LA
IA
IA
NC
IL
TX
WV
NY
VA
IL
TN
AZ

County
331
131
'141
93
119
57
23
93
141
3
7
55
77
233
35
17
17
15
127
53
197
81
71
89
163
1
87
9
197
101
93
121
33
139
45
21
31
245
51
7
5
179
1
21

NEDS
ID
1
2
1
8
104
13
3
5004
5001
16
4
258
39
15
30
5002
1
6
1
7
89
5006
10
317
3
11
159
328
77
17
6
36
21
25
30
628
2448
18
2
292
3
44
1020
32

SIC
SIC Grouping
3334
1021
3331
3332
2911
1311
3331
3312
2621
2911
3331
3861
2621
2911
3331
3312
3331
2911
3312
1311
2911
3312
2911
3312
4961
2621
2621
,.2621
2911
4953
2621
2819
2999
2869
2046
4411
2911
2911
2819
3573
2631
2869
3499
3331

A)
other
CS
Lead
PR
O&NG
CS
I&S
P&P
PR
CS
other
P&P
PR
CS
I&S
CS
PR
I&S
O&NG
PR
I&S
PR
I&S
other
P&P
P&P
P&P
PR
other
P&P
H2S04
PR
other
other
other
PR
PR
H2SO4
other
P&P
other
other
CS

Year
92
90
90
90
93
93
91
90
90
92
90
90
90
92
90
90
91
87
90
92
93
90
87
90
93
91
89
90
93
87
92
86
90
92
92
85
93
90
85
90
92
93
90
90

Emissions
(short tons)
67,988
65,156
47,341
44,136
40,063
37,394
34,592
34,467
33,921
33,574
32,959
32,718
32,714
30,661
30,047
29,132
28,058
26,240
26,029
25,876
24,824
22,714
22,494
21,242
19,236
18,901
18,613
18,071
18,021
17,742
17,398
17,116
16,628
15,885
15.654
15,349
14,791
14,628
14.422
13,933
13,513
13,355
12,800
12,553

Development of an Industrial SOS
Emissions Inventory Baseline and 1995
Report to Congress
                                                                         Baseline Emissions
Page 31

-------
                                Table IV-1   (continued)
Rank
45
46
47
48
49
50
51
52
53
54
55
56
57
58
59
60
61
62
63
64
65
66
67

68
69
70
71
72
73
74
75
76
77
78
79
80
81
82
83
84
85
86
87
88
89
90
EPA
Plant Name Region
Medusa Cement Company
Total Petroleum, Inc.
Wheeling Pitts. Steel, Steubenviile North
Atlantic Cement Co.
Exxon Co., USA
Rna Oil and Chemical Company
Citgo Petroleum Corp.
LaFarge Corporation
BP Oil Company
Indian Refining Limited Partnership
LTV Steel Company - Pittsburgh Works
Chesapeake Paper Products Co.
E. I. Du Pont De Nemours and Company
Weyerhaeuser Valliant
Phibro Energy USA, Inc.
LTV Steel Co. (Rep)
Western Gas Resources, Inc.
Conoco, Inc.
ASARCO Incorporated
Packaging Corp of America
ALCOA (Aluminum Co. of America)
Holnam Inc.
International Paper Company -
Androscoggin
LaFarge Corporation
Bowater, Great Northern
Great Lakes Carbon Corporation
Coastal Refining & Marketing, Inc.
Coastal Eagle Point Oil Co.
Co ri ox
Inland - Rome Inc.
Inland Steel Flat Products
Rhone Poulenc
Lone Star Industries, Inc.
General Electric Co.
Phillips Petroleum Company
Westvaco - Kraft Div.
Bowater Southern Paper Co.
Archer Daniels Midland Com Sweeteners
Amoco Oil Company
GPM Gas Corporation
Geneva Steel
River Cement Co.
Stone Container Corporation
Koch Refining
Glatfelter, P. H. Co. •
Calciner Industries, Inc.
5
6
5
2
8
6
6
6
6
5
3
3
4
6
6
5
6
6
8
5
5
7
1

5
1
6
6
2
8
4
5
6
3
3
6
4
4
5
6
6
8
7
9
5
3
6
State
Ml
OK
OH
NY
MT
TX
LA
TX
LA
IL
PA
VA
TN
OK
TX
OH
TX
OK
MT
OH
IN
MO
ME

IL
ME
TX
TX
NJ
MT
GA
IN
TX
PA
PA
TX
SC
TN
IL
TX
TX
UT
MO
AZ
MN
PA
LA
County
29
19
81
1
111
227
19
439
75
101
3
101
85
89
201
35
467
71
49
169
173
163
7

127
19
245
355
15
111
115
89
201
95
49
39
19
107
143
167
103
49
99
17
37
133
87
NEDS
ID
7
209
5008
40
13
1
16
24
15
15
22
1
7
700
65
5050
1
202
1
5008
7
1
21

12
56
23
18
4
12
21
316
37
31
9
10
8
12
41
1
6
27
2
7
11
16
6
SIC
SIC Grouping
3241
2911
3312 .
3241
2911
2911
2911
3273
2911
2911
3312
2621
2816
2631
2911
3312
1321
2911
3332
2631
3334
3241
2611

3241
2611
2999
2911
2911
2911
2631
3312
2819
3241
3743
2911
2631
2611
2869
2911
1311
3312
3241
2611
2911
2621
3334
CP
PR
I&S
CP
PR
PR
PR
other
PR
PR
I&S
P&P
other
P&P
PR
I&S
O&NG
PR
Lead
P&P
At
CP
P&P

CP
P&P
other
PR
PR
PR
P&P
I&S
H2S04
CP
other
PR
P&P
P&P
other
PR
O&NG
I&S
CP
P&P
PR
P&P
Al
Year
90
88
90
90
93
90
90
85
90
93
90
92
90
92
92
• 88
90
90
93
90
92
90
90

93
90
92
92
87
93
90
• 90
92
85
90
92
91
93
93
92
88
92
90
90
90
90
90
Emissions
(short tons)
12,476
12,361
11,815
11,759
11,626
11,531
11,466
11,308
11,220
11,144
11,004
10,908
10,674
10,673
10,602
10,597
10,484
10,323
10,315
10,125
10,065
10,028
9,940

9,773
9,473
9,412
9,201
9,082
8,966
8,877
8,871
8,716
8,712
8,580
8,447
8,437
8,391
8,384
8,325
8,134
8,120
8,085
8,081
8,045
8,031
8,009
Development of an Industrial SO2
Emissions Inventory Baseline and 1995
Report to Congress
                                                                                Baseline Emissions
Page 32

-------
                                       Table IV-1   (continued)
Rank
91
92
93
94
95
96
97
98
99
100
Plant Name
AMAX, Inc.
Lake Charles Calc. Plant
Amerada Hess Corp.
Chevron USA
Goodyear Tire & Rubber Co.
GA Pacific
Kimberly-Clark Corp.
Lone Star Industries
Roanoke Cement Co. (formerly Tarmac)
Tosco Corp., Avon Refinery
EPA^
Region
2
6
4
9
5
4
4
7
3
9
State
NJ
LA
MS
HI
OH
FL
AL
MO
VA
CA
County
23
19
73
3
153
107
121
31
23
13
NEDS
ID
2
69
1
52
5041
5
6
21
3
13
SIC
SIC Grouping
3341
2999
2911
2911
3011
2621
2621
3241
3241
2911
other
other
PR
PR
other
P&P
P&P
CP
CP
PR
Year
86
90
86
83
90
90
92
87
92
90
Emissions
(short tons)
7,932
7,919
7,847
7,845
7,841
7,834
7,744
7,705
7,667
7,660
NOTES:   These data were reported as found in AIRS/AFS. EPA recognizes that there may be inaccuracies and
          incompleteness in the data, and the data may not accurately reflect the current emissions of facilities.
          Although some sources listed in this table may appear to be associated with electric utilities, their SIC codes are
          indicative of an industrial source.
  Development of an Industrial SO,,
  Emissions Inventory Baseline and 1995
  Report to Congress
                                          Baseline Emissions
Page 33

-------
                                    Table IV-2
        Analysis of Top 100 Industrial SO2 Point Sources by Industry
industry SIC
Grouping
Petroleum Refinery PR



Pulp & Paper P&p

Iron & Steel l&s

Cement Production CP
Primary Copper Smelters CS
Oil & Natural Gas O&NG
Primary Aluminum Al
Sulfuric acid Production H2SO4
Primary Lead Lead
Carbon Black CB
Glass 9|ass
Lime lime
Other other
copper ore mining
wet corn milling
inorganic pigments
inorganic chemicals nee
products of petroleum and coal nee
tires & inner tubes
ready mix concrete
secondary smelting & refining of
nonferrous metals
fabricated metals products nee
electronic computer equipment
railroad equipment
photographic equipment & supplies
deep sea foreign transportation
freight
refuse systems
steam & air conditioning supply 	
NOTE: * SIC is Jrom a 1977 SIC listing and is not listed in the
SIC Number of
CODE(s) Facilities
29xx



26xx

331 x, 332x

324x
3331
13xx
3334
2819
3332*



various
1021
2046
2816
2869
2999
3011
3273
3341

3499
3573*
3743
3861
4411

4953
4961
1987 manual.
29



17

10

8
6
4
3
3
2
0
0
0
18
1
1
1
3
2
1
1
1

1
1
1
1
1

1
1

Facility Ranks
5, 10, 14, 18, 21, 23, 29,
33, 37, 38, 46, 49, 50, 51 ,
53, 54, 59, 62, 71,72,73,
79, 83, 88, 93, 94, 96, 97,
100
9, 13, 26, 27, 28, 31, 41,
56, 58, 64, 67, 69, 74, 80,
81,87, 89
8, 16, 19, 22, 24, 47, 55,
60, 75, 85
45, 48, 66, 68, 77, 86, 98,
99
3, 7, 11, 15, 17,44
6, 20, 61, 84
1,65, 90
32, 39, 76
4, 63




2
35
57
34, 42, 82
70, 92
95
52
91

43
40
78
12
36

30
25

Development of an Industrial SO,
Emissions Inventory Baseline and 1995
Report to Congress
                                                                        Baseline Emissions
Page 34

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Development of an Industrial SO2
Emissions Inventory Baseline and 1995
Report to Congress
Page 41
                                                                                         Baseline Emissions

-------
                                 CHAPTER V
            INDUSTRIAL  SO2  EMISSION PROJECTIONS
A.  INTRODUCTION

    In addition to a national inventory of SO2 emissions, section 406 of the CAAA of 1990
also calls for presentation of the likely trend in such emissions over the following 20-year
period. Thus, emission projections for industrial SO2 emissions are required under section
406. This chapter discusses the methods used to develop these emission projections, the
emission projected for the period 1990-2015, and selected information on the emission
projections of certain industrial sources subcategories.

    Although section 406 calls for development of the likely trend in emissions for a 20
year period, emission projections were developed from 1990 (the base year) to 2015, since
2015 represents 20 years from the due date of the required report to Congress (January 1,
1995).

    It is important to remember that the projections presented in this chapter represent
the best estimate of what emissions from industrial SO2 sources will be in the future.  As
with any type of projection, values presented for periods of time more than 3-4 years away
from the base year will become increasingly speculative and should be treated with some
degree of skepticism.  It is also important to realize that the factors used to develop the
projections typically only reflect changes in activity levels and may not capture changes in
technology or emission factors over time.

B.  PROJECTION METHODOLOGY

    Industrial source SO2 emissions were projected using the Industrial SO2 and NOX
Tracking System (ISNTS).  This "system" is actually a composite of several different
computer systems.  The ISNTS is not a computer system designed to be distributed to
State or local air pollution personnel, nor is it designed to  be used by personnel who do
not have a knowledge of the various system components, or a familiarity with data base
management systems. ISNTS is not  an integrated computer system, but rather is
comprised of various component pieces developed either specifically for the purpose of
projecting SO2 emissions or for use in other EPA related projection purposes.  ISNTS is
comprised of the following components:

 •>  Multiple Projections System (MPS).  The version utilized is an in-house version
    specifically modified to project yearly SO2 emissions.

 *•  Economic Growth Analysis System (E-GAS).
  Davolopmant of an Industrial SO2                                                   Projections
  Emissions Inventory Baseline and 1995           Page 42
  Report to Congress

-------
*   A British thermal unit (Btu) efficiency neural network (BENNET) specifically
    designed to provide growth factors for industrial combustion sources that account for
    fuel switching and the consequent variability in fuel quality (i.e., fuel sulfur content).
                                     i.
>   An industrial fuel price neural network (FUNET) specifically designed to provide
    projected fuel price information for use in BENNET.

    Two of the components of this "system" (E-GAS and MPS) are distributed stand-alone
computer systems that have been provided by EPA for State and local air pollution control
agencies. Each of these systems has a user's manual and/or reference manual that
describes how to develop economic growth factors (E-GAS) or emission projections (MPS).
The reader is referred to the following EPA publications for additional information
concerning these programs:

    "Economic Growth Analysis System:  Reference Manual," EPA-600/R-94-139a,
    April 1993.

    "Economic Growth Analysis System:  User's Guide," EPA-600/R-94-139b,
    April 1993.

    "Multiple Projections System (MPS): User's Manual Version 1.0," EPA-600/R-94-
    085, May 1994.

    E-GAS is an economic and activity forecasting model that projects growth factors by
source classification code (SCO for nonattainment areas and attainment portions of
States for the  48 contiguous States.  The system is composed of a national economic tier, a
regional economic tier, and a growth factor tier which includes energy consumption
models for the residential, commercial, and industrial sectors, modules which forecast
industrial physical output and vehicle miles travelled, and a crosswalk which matches the
appropriate growth factor with each point, area,  and mobile  source SCC.  The growth
factor tier from E-GAS is used in ISNTS to provide growth factors for projecting emissions
from noncombustion industrial sources.

    MPS is  a projection model that uses a base year inventory, source-specific growth
factors,  and projected changes in (source-specific) control efficiency and rule effectiveness
to develop inventories for future years.  MPS is used to store the appropriate SO2 base
year emissions data, and generate forecasts of industrial process emissions using activity
growth factors from E-GAS (for noncombustion sources and industrial combustion area
sources) and BENNET (for industrial combustion point sources). In addition, MPS can be
used to  generate summary tables and graphs.

    The Fuel Price Neural Network (FUNET) estimates/forecasts prices paid by industrial
consumers in each of the 4 census regions for any of 5 fuels (coal, natural gas, distillate,
residual, LPG), and electricity. As options, sulfur content may be specified for residual oil
and coal and heat content may be specified for coal. Because coal ranks (anthracite,
bituminous, sub-bituminous, and lignite) can be distinguished by heat content,  the ability
to specify heat content effectively gives FUNET the ability to estimate/forecast coal price
by rank.
 Development of an Industrial SOS                                                     Projections
 Emissions Inventory Baseline and 1995            Page 43
 Report to Congress

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    BENNET forecasts gross SO2 emissions (GSE) resulting from combustion of coal,
residual, and distillate by the manufacturing industries, Standard Industrial Codes (SIC)
20 - 39. GSE are defined for purposes of this report as emissions resulting from
conversion of sulfur contained in the fuel to SO2 by combustion.  Since BENNET does not
account for removal of SO2 from combustion gas by ash removal, scrubbers, precipitators,
or any other physical or chemical process designed to reduce the release of air pollutants
into the atmosphere, the GSE are used as relative growth factors applied to net base year
emissions, that is, with existing control systems in operation.

    GSE were calculated by forecasting the amount, in Btu, of each of 6 fuels used by
each of 20 manufacturing SICs in each state during each future year and then calculating
the SO2 which would result from combustion.  Btu consumption includes the effects of fuel
switching due to price differences among fuels plus the effects of capital investment,
which include both fuel switching and changes in efficiency. Six fuels were considered
when forecasting Btu consumption:  coal, distillate, electricity, natural gas, LPG, and
residual.  Although electricity is, strictly speaking, not a fuel, it is an alternative to the
other 5 in many industrial applications and is therefore included. Only 3 of the fuels are
considered to produce SO2:  coal, residual,  and distillate.  Both  natural gas and LPG
contain small amounts of sulfur but these  amounts are considered negligible and were
therefore ignored.

    As indicated  above, GSE  forecast by BENNET are expressed as growth rates relative
to the base year.  In other words, for the base year, GSE for any state and SIC equals
100.0. GSE for any other state/year/SIC would be a number like 98.5 or 102.3, which
indicates that GSE for the state/year/SIC would be 98.5 or 102.3 percent of its base year
value.

    Details of the theory and development of the neural networks and additional details
concerning how the industrial SO2 emissions projections were prepared  are given in
Pechan, 1994.

 C. INDUSTRIAL SO2 EMISSION  PROJECTIONS

    As indicated in the previous chapter, industrial source SO2 emissions for the base
 year, 1990, are approximately 5 million tons. Starting with the base year emissions,
 emission projections were developed using either E-GAS growth factors (for
 noncombustion sources and combustion area sources) or BENNET growth factors for
 industrial combustion sources.  E-GAS growth factors were utilized for the combustion
 area sources since these sources are felt to be too small and too disperse to be able to
 effectively switch fuels.

    No new  national controls for any industrial SO2 sources were identified, nor were
 changes in current rule effectiveness. Thus the emission projections presented in this
 chapter represent growth with no new controls.

     Figure V-l shows the results from the emission projections developed using ISNTS.
 Values presented for 1990-1993 represent emission estimates developed as part of EPA's
 Emission Trends effort. 1994-2015 values represent projected  emissions using the 1990
 base year inventory discussed in the previous chapter.

  Development of an Industrial SOf                                 .                  Projections
  Emissions Inventory Baseline and 1995           Page 44
  Report to Congress

-------
    Figure V-l shows that emissions decreased slightly from 1990-1993, and then show a
 slightly increasing trend to the year 2005.  From 2005 to 2015 projected emissions are
 basically flat. In all cases, the emissions projections show that total national industrial
 SO2 emissions remain below 5 million tons, well below the 5.60 million ton per year cap
 established by section 406. As with historic emissions and the base year, industrial
 combustion emissions continue to be the largest contributor to future industrial SO2
 emissions.

 D. PROJECTED EMISSIONS FOR SELECTED INDUSTRIAL SOURCE
    SUBCATEGORIES

    1.  Industrial Combustion

    Figure V-2 shows the  projected emissions from the industrial SO2 combustion sector
 by fuel type at five year intervals from 1990-2015.  This figure indicates that for coal,
 emissions decrease slightly from 1990-1995, then rise from 1995-2005 followed by another
 decline after 2005.  Oil-related emissions, on the other hand, decrease steadily from their
 base year levels, while the contribution from gas remains virtually constant for the period.
 Emissions from other fuels decline slightly.

    2.  Metals Processing

    Industrial SO2 emission projections for various subcategories in the metals processing
-.sector are shown in Figure V-3. Projected emissions for all subcategories examined
 basically show virtually no growth in emissions from this sector.

    3.  Chemical and Allied Products Manufacturing

    Inorganic chemical manufacturing (sulfur compounds) shows increasing emissions
 over the period 1990-2015, rising from slightly over 300 thousand tons in 1990 to over 400
 thousand tons in 2015 (Figure V-4).  Figure V-4 also shows that the remaining chemical
 and allied products manufacturing subcategories show only slight growth in emissions (if
 any) over the same time period.

    4.  Petroleum  and Related Industries

    Figure V-5 indicates that emissions from all petroleum and related industry
 subcategories decline steadily from 1990-2015 with the exception of oil and natural gas
 production which shows declining emissions until 2005 and then increasing emissions
 until 2015.

    5.  Other Industrial Processes

    Other industrial process emissions increase steadily over the period 1990-2015
 (Figure V-6). Wood, pulp  and paper, and publishing emissions increase from slightly
 below 150 thousand tons to over 200 thousand tons by 2015. Cement manufacturing
 shows an even greater increase, rising from just over 150 thousand tons in 1990 to well
  Development 'of an Industrial SO2                                                   Projections
  Emissions Inventory Baseline and 1995           Page 45
  Report to Congress

-------
over 250 thousand tons in 2015. Other subcategories in the other industrial processes
sector show slight increases as well.

E.  EMISSION PROJECTIONS SUMMARY

    Industrial SO2 emission projections show a slight decrease from the base year to
approximately 1994-1995.  From 1995, emission levels increase slightly to a peak about
2005. From 2005 to 2015,  collective emission levels for all categories decrease very
slightly. Two subcategories, chemical and allied products manufacturing and other
industrial processes, are forecast to produce small increases in emissions over the period
1990-2015.

    Table V-l summarizes the Tier 1 level emission projections from 1990-2015. Values
for 1990-1993 are derived from EPA's Emission Trends effort.  Only values from 1994-
2015 represent projected emissions values.
  Development of an Industrial SOZ                                                     Projections
  Emissions Inventory Baseline and 1995           Page 46
  Report to Congress

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                                       Table V-1
               National Tier 1 Emissions Projections, 1990 to 2015
1990 1991
Fuel Combustion -
Industrial
Chemical and Allied Prod.
Mfg.
Metals Processing
Petroleum & Related
Industries
Other Industrial Processes
Solvent Utilization
Storage and Transport'
Waste Disposal &
Recycling
TOTAL
3,106 3

440

578
440

401
1
5
11

4,981 4
,139

442

544
444

391
1
5
11

,977
1992
2,947

447

557
417

401
1
5
11

4,786
1993
2,830

450

580
409

413
1
5
11

4,699
1994
2,878

462

579
405

430
1
5
11

4,769
1995 1996
2,884 2,866

462

579
397

435
1
5
11


467

579
390

445
1
5
11

4,773 4,763
1997
2,863

471

579
383

456
1
5
11

4,768
1998 1999
2,867 2,887

475

579
377

467
1
5
11


479

579
371

477
1
5
11

4,781 4,811
2000
2,908

483

580
364

488
1
5
11

4,840


Fuel Combustion -
Industrial
Chemical and Allied Prod.
Mfg.
'Metals Processing
Petroleum & Related
- Industries
Other Industrial Processes
Solvent Utilization
Storage and Transport
Waste Disposal &
Recycling
TOTAL
2001 2002
2,937 2,958

487 491

580 580
358 352

499 510
1 1
5 5
11 11

4,878 4,908
2003
2,968

494

580
347

521
1
5
11

4,927
2004
2,966

498

581
341

533
1
5
11

4,935
2005 2006
2,962 2,930

501 507

581 581
335 333

545 553
1 1
5 5
11 11

4,941 4,921
2007
2,919

511

582
331

559
1
5
11

4,919
2008 2009
2,912 2,890

516 520

582 582
328 326

566 572
1 1
5 5
11 11

4,920 4,907
2010
2,882

524

583
323

578
1
5
11

4/907
2011
2,857

528

583
321

584
1
5
11

4,891
2012 2013
2,842 2,820

532 535

583 584
319 316

590 594
1 1
5 5
11 11

4,883 4,866
2014
2,800

537

584
314

599
1
5
11

4,851
2015
2,803

540

584
312

603
1
5
11

4,858
Development of an Industrial SO2                                                        Projections
Emissions Inventory Baseline and 1995            Page 47
Report to Congress

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                               CHAPTER VI
     EMISSION  REDUCTIONS RESULTING FROM DIESEL
                 DESULFURIZATION REGULATIONS
A.  INTRODUCTION

    Section 406 of the 1990 CAAA requires that EPA's industrial SO2 emissions report to
Congress include estimates of the emission reductions resulting from the diesel fuel
desulfurization regulations mandated by Section 211(i) of the CAAA. The first two
sections of this chapter of the report describe the desulfurization regulations and the
methods used to estimate the SO2 emission reductions from these regulations. The final
section of this chapter presents estimates of SO2 emission reductions in 1993, the first
year they were implemented.

B.  DIESEL DESULFURIZATION REGULATIONS

    Section 211(i) of the CAAA outlines the sulfur content requirements for diesel fuel.
Congress mandated that all motor vehicle diesel fuel that contains a concentration of
sulfur in excess of 0.05 percent by weight or which fails to meet a minimum cetane index
of 40, be banned from commerce beginning on October 1, 1993. The EPA published
regulations on August 21, 1990 (54 FR 35276) which govern the desulfurization of diesel
motor fuel.

C.  METHOD OF ESTIMATING EMISSION REDUCTIONS

    The first step in estimating the SO2 emission reductions resulting from the diesel
desulfurization regulations is to assemble data characterizing the sulfur content of motor
fuel. To estimate 1993 emission reductions, government agencies and private
organizations were contacted to assess the availability of sulfur content data for motor
fuel produced or consumed during 1993. Because specific fuel composition data were not
available,'SO2 emission reductions were estimated based on assumed sulfur content levels
of pre- and post-desulfurization motor fuel. For pre-desulfurization months in 1993 (i.e.,
January-September), the average sulfur content of motor fuel as reported in U.S. EPA's
AP-42 publication was used. For post-desulfurization months (October-December), it was
assumed that all motor diesel fuel contained 0.05 percent sulfur content, the maximum
permitted by law.

    The general procedure followed in estimating SO2 emission reductions  was to subtract
the estimated SO2 emissions in 1993 (based on the assumed sulfur content of motor fuel
in each month) from the estimated SO2 emissions in 1993 assuming no desulfurization
took place (i.e., assuming the pre-desulfurization diesel fuel sulfur content for the entire
year).  Emissions were estimated by first calculating pre- and post-desulfurization
emission factors by each of the eight vehicle types (e.g., light-duty diesel vehicle). Next,


 Development of an Industrial SO,                                               Desulfurization
 Emissions Inventory Baseline and 1995          Page 54
 Report to Congress

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the percentage sulfur content data were then combined with fuel density data from AP-42
and fuel economy data from the MOBILE4.1 fuel consumption model to estimate pre- and
post-desulfurization emission factors for each vehicle type. The appropriate emission
factors were then multiplied by State-level vehicle miles traveled data by vehicle type,
which are available from the Highway Performance Monitoring System.  The final step
involved subtracting the estimated 1993 SO2 emissions (with implementation of the
regulation) from the estimated 1993 emissions if no desulfurization regulations were in
place (i.e., assuming that pre-regulation motor fuel sulfur content continues for the entire
year).

D.  ESTIMATED SO2 EMISSION REDUCTIONS

    Figure VI-1 displays a month-by-month comparison of 1993 diesel motor vehicle SO2
emissions with and without the desulfurization program. This figure shows a large
decline in SO2 emissions from diesel motor vehicles for October-December, the first three
months of desulfurization.  Table VI-1 presents the estimated national SO2 emission
reductions for all of 1993 from the diesel desulfurization regulations. This table indicates
that the amount of SO2 emitted from all motor vehicles was reduced by approximately
10 percent  in 1993 due to diesel desulfurization.  A 19 percent  decline in SO2 emissions
was registered for diesel vehicles.  It is important to remember that this reduction was
realized even with the regulations only in place for the last three months of 1993.  If only
the three months that the desulfurization regulations were in effect are analyzed, total
SO2 emissions from all motor vehicles (including non-diesel fueled vehicles) declined an
estimated 42 percent, and SO2 emissions from diesel vehicles for the same period declined
an estimated 75 percent.

    Table VI-2 displays State-level 1993 SO2 emissions estimates, both with and without
the desulfurization program.  South Dakota and Montana had the biggest overall
percentage reduction in motor vehicle SO2 emissions from the desulfurization program at
11.9 percent; the smallest reduction occurred in the District of Columbia (8.2 percent).
The slight differences seen between the various States is the result of differences in the
vehicle fleet in each state.  The percentage reduction column in Table VI-2 is based on
reductions from all vehicles (i.e.,  diesel-fueled as well as non-diesel fueled).  Thus,
although diesel vehicles are the largest emitters of sulfur from mobile sources, emissions
from non-diesel fueled vehicles account for a significant (but variable) fraction of the
emissions and create the slight differences among the overall percentage reductions
among the  various States.
 Development of an Industrial SO,                                                  Desulfurization
 Emissions Inventory Baseline and 1995           Page 55
 Report to Congress

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                                     Table VI-1
    Estimated National SO2 Emission Reductions from Diesel Desulfurization
                                  (Oct.-Dec., 1993)
                                     (short tons)
SO2 Emissions SO2 Emissions
without with SO2 Emission Percentage
Vehicle Type Desulfurization Desulfurization Reductions Reduction
DIESEL VEHICLE
Light-Duty Diesel Vehicle
Light-Duty Diesel Truck
Heavy-Duty Diesel Vehicle
NONDIESEL VEHICLE
TOTAL, diesel and nondiesel
268,304
12,033
2,235
254,036
220,085
488,389
217,336
9,813
1,823
205,701
220,085
437,421
50,968
2,220
412
48,335
0
50,968
19
18
18
19
0
10
Noto: Numbers may not sum due to rounding.
  Development of an Industrial SO2
  Emissions Inventory Baseline and 1995
  Report to Congress
                                                                            Desulfurization
Page 56

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                                     Table VI-2
 Estimated State-Level SO2 Emissions with and without Diesel Desulfurization
                                 (Oct.-Dec., 1993)
                                     (short tons)
L.DDV
LOOT

HDDV
All Vehicle Types*
percentage
State without
Alabama
Alaska
Arizona
Arkansas
California
Colorado
Connecticut
Delaware
Dist. of Columbia
Florida
Georgia
Hawaii
Idaho
Illinois
Indiana
Iowa
Kansas
Kentucky
Louisiana
Maine
Maryland
Massachusetts
Michigan
Minnesota
Mississippi
Missouri
Montana
Nebraska
Nevada
New Hampshire
New Jersey
New Mexico
New York
North Carolina
North Dakota
Ohio
Oklahoma
Oregon
Pennsylvania
Rhode Island
South Carolina
South Dakota
Tennessee
Texas
Utah
Vermont
Virginia
Washington
West Virginia
Wisconsin
Wyoming
LDDV:
• Includes nondiesel vehicles.
245
21
190
121
1,418
159
145
37
20
625
421
44
56
475
304
126
126
201
182
62
226
256
458
221
141
286
44
76
59
52
324
96
589
352
30
514
189
146
476
43
183
38
272
895
90
31
332
265
' 86
256
32
with without with
199
17
155
99
1,156
129
119
30
16
510
343
36
46
387
248
102
103
164
148
51
184
209
373
180
115
233
36
62
48
43
264
78
480
287
25
419
154
119
388
35
150
31
222
730
73
25
270
216
70
209
26
Light-Duty Diesel Vehicle


47
4 .
35
24
252
29
26
7
3
114
79
8
11
87
58
25
24
39
35
12
41
46
85
42
28
54
9
15
11
10
58
19
107
67
6
95
36
28
89
8
36
8
51
165
17
6
62
49
17
49
6
LDDT

38
3
29
19
206
24
21
6
3
93
64
6
9
71
47
20
20
32
28
10
34
37
69
34
23
44
7
12
9
8
47 '
15
87
54
5
78
29
23
73
6
29
6
42
134
13
5
51
40
14
40
5
without
5.803
496
4,010
3,317
23,566
3.277
2,508
775
243
11,702
9,114
793
1,543
9,265
7569
3,406
3,086
5,032
4,420
' ' 1,836
4,294
4,174
9,406
5,140
3,925
6.546
1.343
2,011
1.258
1,402
5,375
2,575
10,788
8565
907
10,812
4,449
3,627
10,338
672
4,786
1.177
6.117
18,014
1,831
892
7,532
5^68
2,496
6508
944
': Light-Duty Diesel Truck


with
4,699
402
3547
2,686
19,082
2,654
2,031
628
197
9.476
7,380
642
1550
7,502
5.886
2,758
2,499
4,075
3,579
1,487
3,477
3,380
7,616
4,162
3,178
5,300
1,088
1,629
1,019
1,135
4,352
2,085
8,735
6,692
734
8,754
3,603
2,937
8.371
544
3,875
953
4,953
14,587
1,482
722
6,099
4566
2,021
5,027
764
HDDV:

without
10,612
900
7,708
5,729
50,715
6.360
5,300
1,494
618
23,770
17,334
1.637
2,657
18,463
13557
5,905
5,574
9,004
8,002
3,084
8,656
9,079
18,301
9,472
6.746
12,147
2,236
3,527
2,404
2,442
11,571
4,476
22,134
15,178
1.520
20,821
8,163
6,502
19,631
1.501
8.424
1.945
11,436
35,387
3,570
1,510
14,027
10,407
4519
11.252
1,583
Heavy-Duty Diesel

with reduction
9,454
801
6,904
5,072
45,923
5,702
4,791
1.338
567
21.407
15,507
1.477
2,351
16,597
11,807
5530
4,959
8,002
7,121
2,720
7,790
8.229
16,412
8,445
5,968
10,838
1,970
3,127
2,151
2,164
10,478
3,965
19,953
13,528
1,341
18.651
7575
5,779
17,560
1,364
7,473
1,713
10,213
31,763
3502
1.333
12,521
9,347
3,725
10,014
1,397
Vehicle

10.9
11.0
10.4
11.5
9.4
10.3
9.6
10.4
8.2
9.9
10.5
9.8
11.5
10.1
10.9
11.4
11.0
11.1
11.0
11.8
10.0
9.4
10.3
10.8
11.5
10.8
11.9
11.3
10.5
11.4
9.4
11.4
9.9
10.9
11.8
10.4
10.9
11.1
10.6
9.1
11.3
11.9
10.7
10.2
10.3
11.7
10.7
10.2
11.7
11.0
11.8


Development of an Industrial SO2
Emissions Inventory Baseline and 1995
Report to Congress
                                    Desulfurization
Page 57

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Development of an Industrial SO2

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                                                                           Desulfurization
Page 58

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                                REFERENCES
Barnard, W., E. Laich, S. Bromberg, et al. "Development ofTier Categories for the
    Collection, Management, and Reporting of Emissions Inventory Data." In
    Proceedings of the 1993 U.S. EPA/A&WMA Emission Inventory Specialty
    Conference, Air and Waste Management Association, Pasadena, CA  1993.
                                                                           »
EPA, 1994:  U.S. Environmental Protection Agency, Joint Emissions Inventory
    Oversight Group, "Comparison of the 1985 NAPAP Emissions Inventory with the
    1985 EPA Trends Estimates for Industrial SO2 Sources," EPA-600/R-94-012,
    Research Triangle Park, NC, January 1994.

EPA, 1993a: U.S. Environmental Protection Agency, "National Air Pollutant Emission
    Trends 1900-1992," EPA-454/R-93-032, Research Triangle Park, NC, October
    1993.

EPA, 1993b: U.S. Environmental Protection Agency, "Regional Interim Emission
    Inventories (1987-1991), Volume I: Development Methodologies," EPA-454/R-93-
    021a, Research Triangle Park, NC, May, 1993.

EPA, 1991:  U.S. Environmental Protection Agency, "Compilation of Air Pollutant
    Emission Factors, Fourth Edition, and Supplements through D, AP-42," Research
    Triangle Park, NC, September 1991.

EPA, 1992:  U.S. Environmental Protection Agency, "National Air Pollutant Emission
    Estimates,  1900-1991," EPA-454/R-92-013, Research Triangle Park, NC, October
    1992.

EPA, 1989:  U.S. Environmental Protection Agency, "The 1985 NAPAP Emission
    Inventory (Version 2): Development of the Annual Data and Modeler's Tapes,"
    EPA-600/7-89-012a, Cincinnati, OH, November 1989.

EPA, 1986:  U.S. Environmental Protection Agency, National Air Data Branch, Office
    of Air Quality Planning and Standards, "Standard Computer Retrievals from the
    National Emissions Data System (NEDS)," unpublished computer report available
    from NADB, Research Triangle Park, NC. (This system is no longer operational.)

Mahoney, James R., 1990: Letter to Representative John D. Dingell, concerning
    review of NAPAP's evaluation of SO2 emission baseline for use in calculating
    emission reduction credits under H.R. 3030, February 5, 1990.

Pechan, 1994: "Industrial SO2 and NOX Tracking System," Final Report prepared for
    U.S. EPA by E.H. Pechan and Associates, Inc., for Contract # 68D10146, Work
    Assignment # 2/033, Pechan Report # 94.09.003/1010.033, September 1994.
  Development of an Industrial SOz   _                                               References
  Emissions Inventory Baseline and 1995           Page 59
  Report to Congress

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 1. REPORT NO.
  EPA-454-R-95-001
                                    TECHNICAL REPORT DATA
                             (Please read Instructions on the reverse before completing)
               3. RECIPIENT'S ACCESSION NO.
4. TITLE AND SUBTITLE
  National Annual  Industrial Sulfur  Dioxide
  Trends  1995-2015,  Report to Congress
Emission
               5. REPORT DATE
June 1995
                                                             6. PERFORMING ORGANIZATION CODE
7.AUTHOR
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