6-020
PRIORITIES
AND PROCEDURES
FOR DEVELOPMENT
OF STANDARDS
OF PERFORMANCE
FOR NEW
ATIONARY SOURCES
•SPHERIC EMISSIONS
:ARY
NMENTAL PROTECTION AGENCY
[>f Air and Waste Management
r Quality Planning and Standards
iangle Park, North Carolina 27711
-------
EPA-450/3-76-020
PRIORITIES
AND PROCEDURES
FOR DEVELOPMENT
OF STANDARDS
OF PERFORMANCE
FOR NEW
STATIONARY SOURCES
OF ATMOSPHERIC EMISSIONS
Loren J. Habegger, Richard R. Cirillo, and Norman F. Sather
Argonne National Laboratory
9700 South Class A\enue
Argonne, Illinois 60-439
Interagency Agreement No. EPA-IAG-D4-0463
Project No. 2
EPA Project Officer: Gary McCutchen
Prepared for
ENVIRONMENTAL PROTECTION AGENCY
Office of Air and Waste Management
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina 27711
.„...,;., iAL PROltGTiON
W. J. 08317
-------
This report is issued by the Environmental Protection Agency to report technical
data of interest to a limited number of readers. Copies are available free of
charge to Federal employees, current contractors and grantees , and nonprofit
organizations - as supplies permit - from the Air Pollution Technical Information
Center, Environmental Protection Agency, Research Triangle Park, North
Carolina 27711; or, for a fee, from the National Technical Information Service,
5285 Port Royal Road, Springfield, Virginia 22161.
This report was furnished to the Environmental Protection Agency by
Argonne National Laboratory, Argonne, Illinois 60439, in fulfillment of
Interagency Agreement No. EPA-IAG-D4-0463. The contents of this report
are reproduced herein as received from Argonne National Laboratory. The
opinions, findings, and conclusions expressed are those of the author and
not necessarily those of the Environmental Protection Agency. Mention of
company or product names is not to be considered as an endorsement by the
Environmental Protection Agency.
Publication No. EPA-450/3-76-020
11
-------
TABLE OF CONTENTS
Page
ABSTRACT 11
1. EXECUTIVE SUMMARY 11
2. INTRODUCTION 15
3. PRIORITIES FOR NEW SOURCE PERFORMANCE STANDARDS 19
3.1 PRIORITY REQUIREMENTS 19
3.2 SOURCE RANKING METHODOLOGY 20
3.2.1 Model IV Calculations 20
3.2.2 Source Screening. 26
3.2.3 Emission Projections and Standard-Setting Schedules . . 34
3.2.4 Efficiency Ratio 37
3.3 SPECIAL PRIORITIES FOR NSPS 41
3.3.1 Pollutant Priorities 41
3.3.2 Strategy Priorities 43
4. STANDARD SETTING PROGRAM ALTERNATIVES 47
4.1 EVALUATION PROCEDURE 47
4.2 POLLUTANT PRIORITY ANALYSIS - PARTICULATES 49
4.3 POLLUTANT PRIORITY ANALYSIS - SULFUR DIOXIDE 65
4.4 POLLUTANT PRIORITY ANALYSIS - NITROGEN OXIDES 76
4.5 POLLUTANT PRIORITY ANALYSIS - HYDROCARBONS 88
4.6 POLLUTANT PRIORITY ANALYSIS - CARBON MONOXIDE 108
4.7 COMBINED POLLUTANT PRIORITY RANKING 117
4.8 SPECIAL PRIORITY AREAS 156
4.8.1 Nitrogen Oxide and Hydrocarbon Emphasis 158
4.8.2 Particulate and Sulfur Oxide Control 158
4.8.3 Nondegradation Source Control 159
4.8.4 Emerging Industry Control 161
4.8.5 Energy Conservation 161
4.8.6 Noncriteria Pollutant Control 163
5. EMISSION CONTROL TECHNOLOGY: LIKELY NEAR-TERM PROGRESS 165
5.1 EXPECTED DEVELOPMENTS IN EMISSION CONTROL TECHNOLOGY 165
-------
TABLE OF CONTENTS (Contd.)
5.1.1 Sulfur Oxides Emission Control Systems 165
5.1.2 Nitrogen Oxides Emission Control Systems . . 170
5.1.3 Particulate Emission Control Systems . . 173
5.1.4 Dual Emission Control Systems . 176
5.2 BASIC RESEARCH EFFORTS 178
5.3 SUMMARY AND CONCLUSIONS 180
6. PROCEDURES FOR DEVELOPMENT OF NEW SOURCE PERFORMANCE STANDARDS. . . 183
6.1 SOURCE PRIORITY DETERMINATION AND SCHEDULING STANDARD
DEVELOPMENT 185
6.2 PROCEDURES AND RATIONALE FOR DEVELOPMENT OF NSPS 189
6.3 REVIEW OF PROPOSED NSPS 193
6.4 INVOLVEMENT OF CONTRACTORS IN STANDARDS DEVELOPMENT 198
6.5 DEVELOPMENT AND REVIEW OF FORMAL NSPS ENVIRONMENTAL
IMPACT STATEMENTS 202
6.5.1 Environmental Impact Analysis Related to a
Specific NSPS 202
6.5.2 Environmental Impact Analysis with General
Applicability 204
6.5.3 Development and Review Procedures for EIS 206
APPENDIX A. Projected National Mobile Source Emissions 208
ACKNOWLEDGMENTS 211
REFERENCES 212
-------
LIST OF TABLES
No. Title Page
3-1 Parameters for Determining Ts-Tn by Model IV 23
3-2 Source Screening Factors 28
4-1 Comparative Emission Rates 48
4-2a Particulate Source Categories with Existing NSPS
(Group ES) 51
4-2b Particulate Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN) 52
4-2c Particulate Source Categories Requiring Control Systems
with Moderate Constraint Rating Due to Increased Energy
Consumption (Group MCR) 56
4-2d Particulate Source Categories for which an Equipment
Standard is Preferable (Group EQ) 57
4-2e Particulate Source Categories Requiring Fuel Switching
to Achieve NSPS (Group FS) 57
4-2f Particulate Source Categories Requiring Control Technology
Research and Development Prior to NSPS Promulgation (Group RD) 58
4-2g Particulate Source Categories for which There Is No
Control Technology Available (Group NC) 58
4-3 Particulates Priority Strategy Summary 63
4-4a Sulfur Dioxide Source Categories with Existing NSPS
(Group ES) 67
4-4b Sulfur Dioxide Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN) 68
4-4c Sulfur Dioxide Source Categories Requiring Control Systems
with Moderate Constraint Rating due to Energy Consumption
(Group MCR) 69
4-4d Sulfur Dioxide Source Categories Requiring Fuel Switching to
Achieve NSPS (Group FS) 70
4-4e Sulfur Dioxide Source Categories Requiring Control Technology
Research and Development Prior to NSPS Promulgation (Group RD) 70
4-4f Sulfur Dioxide Source Categories for Which There Is No Control
Technology Available (Group NC) 71
4-5 Sulfur Dioxide Priority Strategy Summary 75
-------
LIST OF TABLES (Contd.)
No. Title Page
4-6a Nitrogen Oxide Source Categories with Existing NSPS (Group
ES) 80
4-6b Nitrogen Oxide Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN) 80
4-6c Nitrogen Oxide Source Categories for Which an Equipment
Standard is Preferable (Group EQ) 81
4-6d Nitrogen Oxide Source Categories with Moderate Constraint
Rating Due to Increased Energy Consumption or Scarce Resource
Utilization (Group MCR) 81
4-6e Nitrogen Oxide Source Categories Requiring Control Technology
Research and Development Prior to NSPS Promulgation (Group RD) 82
4-6f Nitrogen Oxide Source Categories for Which There Is No
Control Technology Available (Group NC) 83
4-7 Nitrogen Oxide Priority Strategy Summary 87
4-8a Hydrocarbon Source Categories with Existing NSPS (Group ES). . 93
4-8b Hydrocarbon Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN) 94
4-8c Hydrocarbon Source Categories for Which an Equipment Standard
is Preferable (Group EQ) 95
4-8d Hydrocarbon Source Categories with Uncertain Energy Impact
due to Unknown Gas Flammability (Group UGF) 96
4-8e Hydrocarbon Source Categories with Moderate Constraint Rating
due to Increased Energy Consumption or Scarce Resource
Utilization (Group MCR) 98
4-8f Hydrocarbon Source Categories Requiring Control Technology
Research and Development Prior to NSPS Promulgation (Group RD) 99
4-8g Hydrocarbon Source Categories for Which There Is No Control
Technology Available (Group NC) 100
4-9 Hydrocarbon Priority Strategy Summary 105
4-10a Carbon Monoxide Source Categories with Existing NSPE (Group
ES) 112
4-10b Carbon Monoxide Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN) 112
-------
LIST OF TABLES (Contd.)
No. Title Page
4-10c Carbon Monoxide Source Categories for Which An Equipment
Standard is Preferable (Group EQ) .............. 113
4-10d Carbon Monoxide Source Categories with Uncertain Energy
Impact Due to Unknown Gas Flammability (Group ES) ...... H3
4-10e Carbon Monoxide Source Categories with Moderate Constraint
Rating Due to Increased Energy Consumption or Scarce Resource
Utilization (Group MCR) ...................
4-10f Carbon Monoxide Source Categories Requiring Control Technology
Research and Development Prior to NSPS Promulgation (Group
RD) ............................. 114
4-10g Carbon Monoxide Source Categories for Which There is No
Control Technology Available (Group NC) ............ 115
4-11 Carbon Monoxide Priority Strategy Summary .......... 118
4-12 Multiple Pollutant Standards ................. 120
4-13 Combined Pollutant Strategy Summary ............. 124
4-14 Combined Pollutant Standard Setting Schedule for Baseline
Strategy ........................... 130
4-15 Combined Pollutant Standard Setting Schedule for
Strategy with NOX Emphasis .................. L 142
4-16 Impact of Special Priorities on Stationary Source Emissions. . 157
4-17 Source Categories Considered for Nondegradation Controls of
TSP and S02 .......................... 160
4-18 Source Categories Considered for Emerging Industry Priorities. 162
5-1 Summary of Methods Currently Available for S02 Removal from
Stack Gases .......................... 167
5-2 Types of Processes Available for Removal of Sulfur Dioxide
from Stack Gases ....................... 169
5-3 Summary of Methods Currently Available for NOX Control
through Combustion Modification ............... 171
5-4 Summary of Commercial Methods for Particulate Removal
from Stationary Sources ................... 174
6-1 Current EPA Schedules for Review and Promulgation of NSPS . . 197
-------
LIST OF TABLES (Contd.)
No. Title Page
6-2 Accelerated EPA Schedules for Review and Promulgation
of NSPS 197
A-l 1972 NEDS Land Vehicle Emissions 208
-------
LIST OF FIGURES
No.
"3 1
•3 0
3-3
4-1
4-2
4-3
4-4
4-5
4-6
4-7
4-8
4-9
4-10
4-11
4-12
4-13
4-14
4-15
Title
Particulate Emission Projections for Stationary Sources . . .
Sulfur Dioxide Emission Projections for Stationary Sources . .
Nitrogen Oxide Emission Projections for Stationary Sources . .
Nitrogen Oxide Emission Projections for Stationary and
Hydrocarbon Emission Projections for Stationary Sources . . .
Hydrocarbon Emission Projections for Stationary and Mobile
Sources .....
Carbon Monoxide Emission Projections for Stationary
Carbon Monoxide Emission Projections for Stationary and
Mobile Sources
Emission Projections for All NSPS Set at Zero Emissions . . .
Combined Pollutant Emission Projections for Stationary
Sources Based on Single Pollutant Analysis (Strategy 2) . . . .
Combined Pollutant Emission Projections for Stationary
Sources Based on Setting All Feasible Standards Immediately
(Strategy 3)
Combined Pollutant Emission Projections for Stationary
Sources Using Baseline Strategy (Strategy 4)
Combined Pollutant Emission Projections for Stationary
Sources with NO Emphasis (Strategy 9)
Emission Projections as a Function of Standard-Setting Rate. .
Combined Pollutant Emission Projections for Stationary
Sources with Delay in NSPS Impact (Strategy 15)
Page
21
38
40
50
66
77
78
89
91
109
111
127
128
129
139
151
152
1S4
4-16 Combined Pollutant Emission Projections for Stationary
and Mobile Sources with Delay in NSPS Impact (Strategy 15) . . 155
-------
10
LIST OF FIGURES (Contd.)
No. Title Page
6-1 Procedures for Development: and Implementation of NSPS 184
A-l Emission Projections for Mobile Sources 209
-------
11
PRIORITIES AND PROCEDURES FOR THE DEVELOPMENT OF
STANDARDS OF PERFORMANCE FOR NEW STATIONARY
SOURCES OF ATMOSPHERIC EMISSIONS
Loren J. Habegger, Richard R. Cirillo, and Norman F. Sather
ABSTRACT
Because of the increasingly important role of New Source
Performance Standards in the national air quality program and
the large number of categories for which standards are being
developed, a clearly defined procedure for selecting category
priorities and establishing schedules for standard promulga-
tion is a necessity. This report describes a methodology that
has been developed for selecting priorities and schedules
based on projected reductions in emissions resulting from
the individual standards and other considerations related to
technological, legal, institutional, and conservation factors.
The methodology is used with available data to develop an
initial standard-setting program. The program variations
that result from alternate areas of emphasis are also pre-
sented. The expected future developments in emission control
technology and various aspects of the process for developing
standards are reviewed in terms of how they may affect the
long-term New Source Performance Standards program.
1. EXECUTIVE SUMMARY
The promulgation of Standards of Performance for New Stationary Sources
as mandated by Section 111 of the Clean Air Act is assuming an increasingly more
prominent role in the national air quality program. This body of standards,
commonly referred to as New Source Performance Standards (NSPS), reflect the
long-term maximum limitation in stationary source emissions, taking into account
cost, which is achievable without the imposition of restrictions on land use
or industrial development.
Because of limitations on resources for developing the standards and
other restrictions such as availability of emission testing and control tech-
nology, there is a constraint on the number of standards that can be developed
in a given period. This report addresses the question of the impact on future
-------
12
emissions of these constraints on standard-setting rate and establishes prior-
ities and schedules for future standard promulgation in view of alternate ob-
jectives or areas of emphasis. Over 300 potential and existing standards in
190 source categories were considered.
A methodology for prioritizing the potential standards is developed,
which considers first of all for each pollutant the potential emissions reduc-
tion computed from estimates of source category growth and emission factors with
and without NSPS. For the minimization of future emissions, priority factors
based on potential reduction should also be weighted with the inverse of the
time required to develop the standard.
The next step in the prioritization is a source-screening procedure
that identifies for each industry/pollutant category other constraining factors
that are not as easily quantifiable, but which may of necessity increase or
decrease the category priority ranking. The factors considered include the
status of emission measurement and control technology, legal and institutional
constraints, impact on energy and other scarce resources, individual source
impact, and others. The screening methodology relies on both a numerical rank-
ing of some factors and a qualitative ranking of others. Alternative strategies
wherein constraints are applied or relaxed are then evaluated for their impact
on emissions, first for the individual pollutants and then for all pollutants
simultaneously.
The objective of the methodology for prioritization is to provide a
framework in which all of the assumptions that go into setting the priorities
can be clearly defined and changes in areas of emphasis can be easily accommo-
dated to obtain new priorities that reflect those changes.
Using the methodology described, an initial source category prioriti-
zation and alternatives were developed from compiled information. This initial
prioritization is not intended to firmly establish the order in which NSPS
should be set. Rather, it is intended to identify those industries and pollu-
tants for which more intensive studies should be Initiated to confirm or revise
the priority finding. The priority evaluations should be a continuing process
that accounts for new information or changes in emphasis.
For particulates, the evaluations in this study show that existing
NSPS are insufficient to maintain future emission levels at 1975 levels. How-
ever, even with the delay of standards with constraining factors identified
-------
13
in the source screening process, the 1975 levels could be maintained with a
nominal standard-setting rate for particulate sources of 6 per year. The
largest uncertainty in this schedule is the need to promulgate particulate
standards in the near future for intermediate size boilers. Additional inform-
ation is also required to determine the desirability of augmented particulate
standards to control fine emissions and hazardous trace substances.
For sulfur dioxide, emissions can only be maintained at the 1975 level
by the NSPS mechanism if natural gas or other equivalent clean fuels become
more readily available. Without these fuels or the development of signifi-
cantly improved stack gas cleaning devices, S02 emissions are projected to
increase by 22% by 1990. The current potential for SOa emission reduction
has been largely exploited by existing regulations.
For nitrogen oxides, even with the application of maximum NSPS control
efforts, a significant emission increase of more than 40% occurs in the 1975-
1990 period. The maximum controls provide significant reductions through re-
vised standards for large boilers and nitric acid plants. Control of internal
combustion engines, through the resolution of problems of enforcement, should
be a matter of high priority.
Existing NSPS for hydrocarbons have achieved only a small portion of
the control potential and promulgation of additional standards can result in
a significant reduction in emissions in the 1975-1990 period. Resolution of
constraints on the industrial surface coating and ethylene oxide categories,
combined with controls on the unconstrained sources, appears to be the most
effective NSPS program.
Significant control of carbon monoxide emissions results from motor
vehicle controls and therefore this pollutant is not of high priority for NSPS.
Except for the iron and steel processes, adequate stationary source control can
be attained by linking the NSPS for CO to standards for NO or hydrocarbons.
X
For the combined pollutant standard-setting schedule, the initial
pollutant to be emphasized depends on the relative emissions limitation criteria.
In the baseline strategy, initial emphasis on hydrocarbon NSPS is required to
prevent the many uncontrolled categories from causing emission increases. A
special priority emphasis on energy conservation causes only minor variation
in projected emissions. Diversion of effort from development of NSPS for
-------
14
criteria pollutants (regulated by NAAQS) to those for noncriteria pollutants
is possible without significant penalties in increased criteria pollutant
emissions. An increased emphasis on emerging industries also results in slight
increases in projected national emissions for all pollutants. Emphasis on
sources that are covered under prevention of significant deterioration regu-
lations results in some emission penalties for NOX, hydrocarbons, and CO.
A consideration of the standard development procedure indicates that
the current practice of preparing rather detailed supporting documents cannot
be avoided without penalties of less stringent standards or increased involve-
ment in litigation. With current resources the standard-setting rate is approx-
imately 20 NSPS per year. This could be increased up to 80 per year through
extensive use of contractors and by streamlining of the review process. The
reduction in projected national emissions is, however, not in direct propor-
tion to the increased standard-setting rate because of prior regulations for
a majority of the major sources. As the number of promulgated standards in-
creases, additional effort will be required for monitoring their impact, pro-
viding guidelines for affected sources, and developing necessary revisions.
The recently implemented procedure for preparing Environmental Impact
Statements for NSPS will result in standards that are more easily defendable.
This procedure should include preparation of periodically updated statements
on the cumulative effects of all NSPS and comprehensive assessments of second-
ary impacts from frequently used control devices, such as wet scrubbers.
-------
15
2. INTRODUCTION
The Clean Air Act of 1970 has mandated the use of several complement-
ary approaches in a national program "to protect and enhance the quality of
the nation's air resources so as to promote the public health and welfare ..."
These approaches include:
a) National Ambient Air Quality Standards (NAAQS), which
are to be attained on a regional basis through State
Implementation Plans (SIP) (Sections 109 and 110);
b) Standards of Performance for New Stationary Sources,
which reflect the degree of emission limitation
achievable through the application of the best sys-
tem of emission reduction, which has been adequately
demonstrated, taking into account the cost of achiev-
ing such reduction (Section 111):
c) National Emissions Standards for Hazardous Air Pollutants
(NESHAP) for stationary source controls of pollutants,
which may cause serious health effects (Section 112);
d) Emission Standards for Moving Sources, which are required
by the Clean Air Act to reduce mobile source emissions
at least below a given level (Sections 202, 211, and 231);
and
e) Abatement by Means of Conference (Section 115) and
Emergency Powers (Section 303), which are lesser-used
options.
The purpose of this report is to present a systematic analysis of the
priorities and procedures relevant to long-range implementation of one of these
programs, the development of Standards of Performance for New Stationary Sources
(Section 111), commonly referred to as New Source Performance Standards (NSPS).
Development of NSPS, which reflect the best-demonstrated control tech-
nology (taking into account costs), is a complex and time-consuming process,
and because of a limitation in the resources of manpower and funding available
to the EPA, there is a restriction in the rate at which NSPS can be developed
and promulgated. As a result of this limitation, it is mandatory that a pro-
cedure be implemented for establishing priorities for developing NSPS categor-
ies of stationary sources that reflect the objectives of this set of standards.
The overriding purpose of these standards, as intended by Congress,
is to maintain existing air quality and to prevent new air pollution problems
-------
16
2
from developing in the future. The implementation of Section 111 serves an
additional role by contributing to the other air programs information related
to emission factors, capability of control systems, cost alternatives, stand-
ard sampling methods, malfunction regulations, inspection procedures, etc.
For noncriteria or "designated" pollutants (pollutants not listed under Sec-
tion 108 requiring promulgation of NAAQS, or listed as a hazardous pollutant
under Section 112) standards of performance apply to both new and existing
sources and become the complete control strategy (Section lll(d)).
In the following Section 3 of this report, a methodology is presented
for assigning priorities to the various categories of sources. This methodology
considers first of all the potential reduction in emissions, which results from
NSPS promulgation based on estimates of existing emission levels, available
control technology, and projected growth rates. To this is added information
related to other factors, such as expected developments in technology, avail-
ability of adequate emission testing methods, impact on fuel consumption or
other limited resources, legal constraints, etc. A prioritization is then
developed with this information in view of areas of emphasis based on an assess-
ment of the broad EPA strategy for implementing the Clean Air Act.
An application of the developed methodology for priority evaluation
is presented in Section 4 using data on potential emissions reduction, which
3 4
have been provided by The Research Corporation of New England ' and informa-
tion on areas of emphasis and other additional factors that were compiled in
this study. The result of this evaluation is an initial prioritization using
a baseline set of data and assumptions on the relative importance of areas of
emphasis. Also included are alternative priorities that would result from
changes in areas of emphasis or changes in other factors, such as availability
of alternative fuels or new technology.
Because of the importance to the prioritization of available emissions
control technology, Section 5 is devoted to a discussion of the current status
of these technologies and expected developments as a result of ongoing research.
In Section 6, the procedures and requirements of the standard develop-
ment process are considered. Topics that are discussed include the need for
more detailed and on-going category prioritization and scheduling, the standard
-------
17
rationale, review of the proposed standard, use of contractors in standard
development, enforcement and revision of standards, and preparation of Envir-
onmental Impact Statements.
The basis for emission projections for mobile sources used in estima-
tions of total national emissions is presented in Appendix A.
-------
19
3. PRIORITIES FOR NEW SOURCE PERFORMANCE STANDARDS
3.1 PRIORITY REQUIREMENTS
In carrying out the mandate of Section 111 of the Clean Air Act, the
EPA is faced with the Herculean task of setting New Source Performance Stand-
ards for over 200 source categories and at least 5 pollutants. Each industry
represents a unique system of emission sources, control options, and qualify-
ing constraints that makes the standard-setting process a complex and involved
procedure if it is to be done in a technically and economically sound fashion.
Given a limited amount of resources available to carry out the process, it is
necessary to establish a system of priorities to concentrate efforts on the
most important areas first, while postponing less important areas for later
consideration. In terms of the NSPS process, this means setting standards for
some industries and pollutants while leaving others controlled at existing
state standard levels until sufficient resources are available to carry out the
necessary studies for a standard to be set.
To date, standards have been set for 12 industry categories and 6
pollutants. As would be expected, the question has often been raised as to
why these specific industries and pollutants were chosen over all others.
Similar questions will, no doubt, be raised every time a new standard is pro-
posed. A rational system of setting priorities is necessary to define the
reasons for choosing one category over another and to make the NSPS process
a more efficient means of air quality management. At the same time, a well-
designed prioritization methodology can be used as an air quality planning
tool to determine where technological, legal, and institutional improvements
are necessary to realize emission reductions.
No prioritization procedure, the one to be presented here included,
can expect to engender universal agreement on the factors that are most important
and the resulting priority listing. The most that can be hoped for is that
all of the assumptions that go into setting the priorities will be clearly
defined and that challenges to the prioritization can be made on the basis of
an agreed-upon set of ground rules. The methodology to be described here does
not rely on the use of a single numerical ranking of industry/pollutant cate-
gories since such a process would tend to obscure the assumptions and decisions
that go into the method and the loss of this information can result in controversy
-------
20
and confusion. Instead, the methodology relies on both a numerical ranking
of some factors and a qualitative ranking of others. The technical judgment
of the one establishing the priorities will, of necessity, play a key role in
the relative importance of each factor, but if the rationale behind each deci-
sion is clearly outlined and documented, there can be little cause for confusion.
One additional point needs to be made about the prioritization meth-
odology presented here. This is not intended to establish the order in which
NSPS should be set. Rather, it is intended to identify those industries and
pollutants on which intensive studies should be initiated in preparation for
the setting of a standard. These more detailed studies may confirm or dispute
the findings of this priority scheme, but the procedures presented here will,
nevertheless, provide a starting point from which to determine resource allo-
cations .
The methodology consists of three major parts: 1) Model IV calcula-
tions, 2) source screening, and 3) emission projections.
3.2 SOURCE RANKING METHODOLOGY
Figure 3-1 is a sample form used to evaluate each industry category
and pollutant. It provides a uniform method of tabulating the various consid-
erations that go into the source prioritization. In many cases, it was not
possible to fill in the form completely due to a lack of information. Never-
theless, the evaluations that could be made from the available data provide a
useful framework for the source ranking. To simplify the discussion of these
evaluations, the 10 factors on Fig. 3-1 will be referred to by their number on
the form. The first factor, Special Priority, is discussed in Section 3.3.
Factor 2, the Model IV Data, is discussed in Section 3.2.1, and Factors 3-10
in Section 3.2.2.
3.2.1 Model IV ColGulations
The use of the emission computation procedure referred to as "Model
briefly.
3
IV" has been described in detail elsewhere and will be summarized here only
Model IV was developed by George Walsh of the EPA's Emission Standards
and Engineering Division and is the latest methodology in an evolving emission
-------
21
INDUSTRY
POLLUTANT
Source Evaluations Special Considerations
1. Special Priority
2. Model IV Data
En
Ts-Tn
Rank
3. Control Technology Evaluation
a. Type
b. Status
c. Cost
d. Availability
e. Other
4. Emission Measurement Evaluation
a. Method
b. Feasibility
c. Applicability
d. Other
5. Enforceability Evaluation
a. Technical
b. Legal
c. Equipment Standard
d. Other
6. Individual Source Impact Evaluation
a. Typical Source Size
b. Source Location
c. Other
7. Energy Impact Constraint Rating
8. Scarce Resource Constraint Rating
9. Other Environmental Media Constraint Rating
10. Other Considerations
Overall Rank
Fig. 3--1. Standard Industrial Evaluation Form
-------
22
source priority rating system that is based on determining the relative impact
of NSPS on industrial emissions. The fundamental prioritization parameter gen-
erated by the model is the "additional control potential" of new or revised
NSPS relative to baseline year control regulations. This parameter is denoted
as (Ts-Tn) where
Ts = total emissions under control regulations existing iri
the baseline year and
Tn = total emissions under new or revised NSPS.
By computing this parameter for a given year -for each individual source cate-
gory, it is possible to determine what emission reductions could be achieved
by NSPS above and beyond current state regulations. Promulgation of standards
for sources with the largest Ts-Tn values would result in the greatest emis-
sion reductions while control of sources with small Ts-Tn values would have
little impact on national emission rates. This rating can be used as one means
of establishing a hierarchy for the setting of standards within the confines
of limited resource availability.
Table 3-1 lists the parameters considered in the Model IV calculations.
The industrial capacity parameters are a measure of the level of emission-
producing activity of the source category. New Source Performance Standards,
when promulgated, are applicable to the capacities B and C that represent the
replacement of obsolete facilities and the construction of additional capacity,
respectively. The baseline year capacity A is subject to state regulations
only. The fractional utilization K accounts for unused capacity.
The industrial growth parameters are used to measure the rate of ex-
pansion of an industry both in the replacement of obsolete facilities and in
the construction of new facilities. The growth rates P_ and P may be simple
o (_.
or compound. It is intuitively obvious that industries with large growth rates
should have standards promulgated as soon as possible to bring the large number
of new plants and facilities under best available control. The production
capacities B and C are related to the growth rates by Eq. (3-1) and (3-2):
B = A [(1 + Pg)1 - 1] (3-1)
C = A [(1 + P^1 - 1]
for compound growth;
-------
23
Table 3-1. Parameters for Determining Ts-Tn by Model IV
Parameter
Symbol
Factor
Units
Industrial
Capacity
K
Fractional utilization of
existing industry capacity
Baseline year production
capacity
Production capacity from
construction and modifi-
cation to replace obsolete
facilities
Production capacity from
construction and modifi-
cation to increase output
above baseline year
capacity
Production units/year
Production units/year
Production units/year
Industrial
Growth
Construction and modifica-
tion rate to replace obso-
lete capacity
Construction and modifica-
tion rate to increase
industry capacity
Decimal fraction of
baseline capacity/year
Decimal fraction of
baseline capacity/year
Emissions
n
E
lll(d)
Emissions with no controls
Allowable emissions under
existing regulations
Allowable emissions under
new or revised NSPS
Allowable emissions for
existing sources as re-
quired by Section lll(d)
of the Clean Air Act
Mass/unit capacity
Mass/unit capacity
Mass/unit capacity
Mass/unit capacity
-------
24
B = A i PB (3-2)
C = A i Pc
for simple growth,
where i is the elapsed time in years.
The emission rates are used to determine the magnitude of the emis-
sion impact of each source category. In addition to the uncontrolled, state-
regulation-controlled, and NSPS-controlled emission rates, there is an emission
rate to reflect the promulgation of an NSPS for a noncriteria pollutant. Under
Section lll(d) of the Clean Air Act, such a promulgation mandates the states
to implement control strategies for that pollutant for both new and existing
facilities. The emission rate E,,..,,, reflects the emission regulation for
existing facilities.
All of the Model IV parameters are incorporated into the Ts-Tn value
of additional control potential by Eqns. (3-3) through (3-5):
Ts = E K(A-B) + E K(B+C) (3-3)
s s
Tn = E K(A-B) + E K(B+C) (3-4)
S Li
Ts-Tn = K(B+C) (E -E ) (3-5)
s n
For noncriteria pollutants, Tn is redefined by Eq. (3-6):
Tn = £„,,,,. K(A-B) + E K(B+C) (3-6)
For cases where the state standards differentiate between new and existing
sources, Ts and Ts-Tn are redefined by Eq. (3-7) and (3-8):
Ts = E . K(A-B) + (E ) K(B+C) (3-7)
s exist s new
Ts-Tn = K(B+C) (E - E ) (3-8)
s new n
The Ts and Tn values may be computed for any year of interest. In
both cases, the year in which the NSPS is promulgated determines whether the
-------
25
industrial growth is controlled under state regulations (i.e., E ) or NSPS
3 S
(i.e., E ). For the Ts-Tn calculations made by TRC, it was assumed that the
standard was set in 1975 and the impact on 1985 emission rates was determined.
Factor 2 on the standard industrial evaluation form of Fig. 3-1 is
the Model IV data. The items of special interest are the values of En, Ts-Tn,
and the Ts-Tn rank. The Ts-Tn rank is the numerical order of the source cat-
egory relative to the Ts-Tn values of all other sources. The source with the
largest value of Ts-Tn for a given pollutant is first with other sources
following in sequence. As indicated before, this rank established a prioriti-
zation that can be used to set standards. In the following methodology, this
rank is used to order the sources within the various groupings and represents
the fundamental hierarchy. This order is superceded by consideration of the
constraints and restrictions on the setting of standards for the source.
The prioritization using Model IV parameters can be extended to in-
clude the effect of the differing amount of time required to develop each of
the standards. The importance of this additional parameter becomes obvious by
considering the simple case of two separate categories with identical Model IV
values; intuitively, priority should be given to the category for which stand-
ard development is nearest completion. This concept can be generalized by the
following analysis of two source categories X and Y, which are to be priori-
tized. Let E and E be the allowable emissions under existing regulations
S,X S , I
for categories X and Y, respectively, and E and E be the corresponding
n, A n, Y
emissions under NSPS. The annual growth rates in new and modified capacity
for categories X and Y is, respectively,
and
PX - PB,X + PC,X
PY = PB,Y + PC,Y
The time required to develop the respective standards is t and t .
X Y
With the above assumption, by developing the standard for category X
followed by development of the standard for Y, the combined emissions from new
or modified sources initiating construction during the standard development
period for both standards is:*
*For the relatively short time periods covering standard development, simple
growth rates can be assumed. However, for compound growth, the annual growth
rate as used in this development is dependent on the year of analysis.
-------
26
ATXY = ^X'X+VX^ I
where Ky^. and K^A^. are initial production rates. On the other hand, develop-
ing the standards in reverse order results in new emissions:
A <-p fi7 t- i_ T? 4- "I'D
VY ~ >• c Y Y n Y YJ "S
XA Sjl I ft , X A }
The new emissions growth after both standards are set is independent of the
order in which the standards are set and therefore the priority depends on
the relative magnitudes of Eqs. (3-11) and (3-12). Taking the difference of
these equations gives:
(AT - AT ) = [(E -E )PI
Al XA Sn I.A. Jan A JL
which can be positive or negative depending on the values of the parameters.
By considering the implications of this relation, it can be easily shown that
minimum emissions will occur if highest priority is given to the category with
largest value for the
Priority Factor = " " — (3 14)
SD
where t is the time required for standard development. The appearance of the
oD
development time in the denominator tends to increase the priority of standards
that are nearer to promulgation because of, for example, having received prior
partial development or being revisions to existing standards.
For fixed development time t , the prioritization based on Eq. (3-14)
would be in most cases equal to that based on Ts-Tn given above. For the quan-
titative study described in Section 4, the Ts-Tn prioritization was used because
of lack of sufficient information to determine t _ values.
Further details on the development of the Model IV data base are given
in References 3 and 4.
3.2.2 Source Screening
The Model IV calculations provide an insight into the relative import-
ance of the various sources based on the parameters listed in Table 3-1. There
-------
27
are, however, other factors that are not as easily quantifiable, but that also
influence the priority ranking of the industry/pollutant categories. It is
the purpose of the source-screening procedure to provide a mechanism whereby
these factors may be incorporated into the overall" .prioritization.
Table 3-2 lists the screening factors used in this methodology, the
items considered for each factor, and the possible "flags" that will influence
the priority ranking of the source category under consideration. The factor
numbers refer to the position of each on the standard form of Fig. 3-1.
Factors 3 through 6 involve an evaluation of the items listed and a
judgment as to whether there are any major obstacles to the setting of a stand-
ard. The flags are those obstacles that have appeared most frequently in the
application of this methodology in this study. Factors 7 through 9 are an
evaluation of constraints that may not pose an obstacle to the setting of a
standard, but may result in a shifting of the order in which the standards are
set. In general, a ranking of 1 indicates little or no constraint on the set-
ting of a standard as imposed by the factor. A ranking of 2 indicates a mod-
erate constraint, and a ranking of 3 indicates a severe constraint, which may
hamper the promulgation of a standard. A ranking of 0 is included to indicate
that the setting of an NSPS may have a positive effect on the factor considered.
It should be emphasized that the numbers used to indicate constraint ranking
are not intended to indicate relative magnitudes of the constraints. A rank-
ing of 2 does not necessarily mean a constraint twice as heavy as a ranking of
1. Factor 10 is for any other consideration, the most frequently occurring of
which is an already-promulgated NSPS.
Control Technology Evaluation (Factor 3)
This review is designed to determine, in a qualitative way, the con-
trol options that are available for the industry/pollutant under consideration.
The first item considered is the type of control system available. These may
include stack gas cleaning equipment, process modifications, or design changes.
Where several options are available, all are included in the evaluation. A
significant finding to come from this review is an identification of those
sources for which there is no control technology available apart from the
cessation of operation. These sources are flagged with a NC and must, of
necessity, be moved to the end of the priority list, since there is no manner
-------
28
CO
o
4-1
O
CO
PM
00
.^
G
CU
0)
a
en
0)
a
3
O
en
.
CM
I
cn
0)
rH
,£]
CO
H
43
to
60
CO
pr.
CU
rH
43
•H
to
to
O
T)
0)
CU
•H
CO
G
0
O
to
4-1
H
l-t
O
4-1
O
cd
P-H
cd
!-4 rl
O 0)
4-J 43
a 0
cd 3
MH
0
Cfl
G
O CO
•H 4J
4J rj
cd cu
CO CO
CO CU
tU M
O rH ft
O
g TJ V-l 4-1
0 Q) 4-1 G
rl TJ GO)
M-l CU 0 g
0) 0 ft
4-1 G -H
l-i 43 3
Cd 4-1 4-1 tr
ft G -HO)
cd CU |3
0 rH
CU ft TJ O
rH O 0) I-l
43 rH 4-1 4-1 g
cd 0) cfl G 0)
H > -H O rH
•H 0) O O 43
cd TJ O O
> to MH (-1
CO TJ CO O ft
G cfl
rH Cd t*i 0)
O C 4-1 rH CJ
}H O 43 co ft G
4-1 -H CJ O ft cd
G 4-i (-1 o 3 -H
O Cfl Cd CO rH
o s-i cu 42 ft
0) Cfl 00 0) g
O ft 0) -H 45 O
G 0 (-1 43 4J 0
1 1 II
cj q o >
rH 4-1
O G
rH )-l MH CU
O 4-1 O 0
H G ft
4-1 O >> -rl
GO 4J 3
O t>* "H CT
CJ M-l 00 rH 01
O O -H
o co o cd o
3 G H IH
0) 4J 43 4-1 -r) 4-1
ft cfl o co cd C
>-, 4-1 0) O > O
H en 4-1 cj -i
0
q_l _u _[_j
o o
co G G
4-1
CO CO CO
•H -rl -H
X CU
o) 4-1 4-1 a
C C G
TJ 4J CU CU Cd
0 G g B rH
43 CO CU CU rH
4J 4J !-l Vl -H
0) 3 3 30)
0 H CO CO >
— t cd cfl M
0 O 0) CU 3
G ft 0 0 W
1 1 1
g PM en
§ K 2
>•>
4-1
4-1 -H
G rH
0) -H
0 43
CU -H
M CO
3 co
CO 0)
cd MH >-,
Q) 4-1
g 4-1 4-1 -H
C G rH
m cu cu -H
0 g g 43
cu o) cd
TJ (-1 J-l O
0 3 3 vH
43 CO CD rH
4-1 cd cd ft
0) 0) 0) ft
g g g cd
• • •
cfl 43 O
4-1
a)
G B
O 0)
•H SH
co 3
CO CO
•H cd
g CU
W g
> 43
4-) cd
•H (-1
rH 0)
•H >-, MH CU
43 4-1 0) rH
cfl -H J-i 43
0) rH ft CO
a -H M
j-i 43 cu o)
O Cfl 43 MH
MH 0) 0)
C 0 >, )H
0) J-i CO ft
0 0
M MH CU
O G TJ 43
M-l 0) t-l
cfl >s
CO i-l TJ CO
S o C B
0) MH nj
rH 4-J TJ
£> CO CO 4-1 rl
0 g -rl CO
M Q) 4J g TJ
ft H G -H C
43 0) rH Cfl
H 0 0 4-1
cd n ft G to
CJ ft -H O
•H 3 -H rH
G H cr co o)
43 cd CU CO 3
a oo -H MH
0) 0) G B
4-1 rH Cfl 0) Cfl
III 1
W W O* en
H 1-3; w PLI
CO T3
0 V"l
CU cfl
r—\ "CD
43 CO G
0 0 cfl
I-l 0) 4-1
ft rH CO
r\
rH O 4-1
CO M G
CJ ft 01
•H 0
G rH ft
43 cd 'H
cj 00 3
cu cu cr
H J W
cd 43 O
1
cu >,
CJ 4-1
I-l -rl
0 H
MH -rl
pj f^
w cd
LO
a)
^
•H
4-1
CO -rl
cu to
0 C
i-t cu
3 to
o
W G
CO O
CU rH -H
O rH 4-1
IH cfl cfl
300
o co o
CO rH
TJ
cu crj co
00 0) vH
IH }-i
cfl ft CU
rH CO CJ
0) I-l
!S TJ 3
CU -H O
MH |S CO
1 1 1
r4 en O
PR IS r3
0)
N
•H
CO
G
0) 0
a -H
I-l 4-J
3 co
o o
CO O
rH
rH
CO CU
0 0
•H J-i
ft 3
?•< o
H en
cfl 43
rH
%
TJ
•H 0) 4J
> 0 cj
•H H cfl
TJ 3 ft
cog
M en i-i
V«O
-------
29
/— x
•
13
4J
C
O
U
>^_/
•
CM
1
CO
0)
r-l
rQ
CtJ
H
43
CO
00
cd
I-l
fe
0)
r-H
43
•H
CO
CO
O
P4
13
0)
I-l
01
13
•H
CO
C
O
U
CO
0
cu
4-J
I-H
M
O
4-J
o
cd
fn
cd
M H
o cu
4-J ,0
0 0
cd 3
fn 3
C
O
•H
4J a
cd o
> -H C
M 4J O
cu a- 1-1 c
CO 0 4-1 O
C 3 P. -H
O CD 0 4-1
o c 3 a<
o co g
>, o a 3
oo o co
i-i >* a c
0) 00 O
G ri >> a
CD CU 00
C rl >,
C CU 0) 00
•H CM
C 0) 0)
4-1 0 C
rH C CU
3 4-1 -H
CO 0 C
(U 0) 01 *H
i-i 4H CO
4H cfl 01
^3 o) cu co
rH M Cfl
3 O
4-J -H o cu
CO rH 0 CO
1 1 1 1
O rH CSJ CO
C
o
CO
13 C
r4 O
cd -H
13 4-1
c ex
cd S
4-1 3
CO CO
C
4H O
o o
4-1 >,
a oo
CU !-i
4H CU
MH c
w cu
4-1
C
•H
cd
£*> 4J M
00 O 4J
I-i cd co
cu a c
ceo
W H U
r^
cu
CO
CU 30)
O CO
I-l 0) 3 CU
3 o co
O I-l 0) 3
CO 3 O
cu o v-4 cu
M co 3 cJ
0) O M
cu >-i co 3
a cu o
)-l CU I-l CO
cd o cu
O M CU >-i
co cd o
a )-i cu
C co cd o
•H OH
C co cd
4-1 O CJ
rH C CO
3 4J vH
w o a
0) 0) 0) %H
!-! MH CO
<4-l Cd 0)
T3 0) CU CD
rH M Cd
3 C 0 0 CU
O O C C M
S «rl -H CJ
4-1 >-l C
T3 cd O CU -H
!-i > 4J
cd M o) cd CD
13 0) rH M !-l
C co 4-> cu a)
cd C 4-J 13 >
4-1 O -H O 0)
CO O rH 0 CO
1 III
O i— i CN ro
CU
&
4-J
CO
C 0)
0 0
!-i
co 3
T3 O
M CO
cd cu
T3 J-l
c
cd cu
4-1 a
CO W
cd
<4H O
O CO
4-1 M-l
CJ 0
CU
M-l CU
MH CO
W 3
4-1
C
CU -rl
a cd
cu n M
CJ 3 4-1
!-4 O CO
cd co C
CJ 0) O
C/3 Pi U
OO
rH
M cd
0) 4-1 rH
42 C cd
4-1 0) 4-1 rH
o e c cd
C 0) 4-1
>4H O 0 C
o M c o;
•H 0 S
rH > H C
O C -H 0
M cu > i-i
4J C -H
C M 0) >
O 0) C
CJ ,£ M CU
4-1 0)
C co o fi M
•H 4-1 4-1 CU
C C O 43
4-J Cd O 4-1
rH 4-1 CO
3 3 4J -H
CO rH CJ C
CU rH CU CU -H
I-l O 4-1 CO
& M-4 Cd 0)
rrj CU 0) CO
rH rH |-l Cd
3 cd o o cu
0 4-1 C C M
£ C CO -H CO O CO
CU )-l 4J 4-J C 4J
T3g OC CUC'HC
SH C cd 4J cd cd
CdO 0)4-1 Cd4-l 0)4-1
T3l-lrH3 rl 3 rl 3
C'H 4-lrH 0)rH OlrH
Cd> 4JrH T3rH > i-H
4-IC'HO 00 CUO
COO) rHft 0 ft CO&,
1 1 1 1
O r-i CN ro
0)
00
C T3 M
O » -H cd
CO rH f
CO 4-> O CJ
T3 C CO CO
5-1 cd -H
Cd 4-1 "13
T3 3 C
C rH 0 rH
Cd rH -H Cd
4-1 o 4-i e
co a. 3 M
rH 0)
MH P rH £}
0 -H 0 4J
cd ex
4J
O I-l 1-4 0)
CU 0) 0) 4J
m 43 4-> co
LH 4-i cd cd
W O S 15
4-1
c
1 iH
C cd
O rH 5-1
!^ i-i cd cd 4J
CU -H 4-1 -H CO
rC > C T3 C
4j C o) cu o
0 W B S u
CT\
C/2
PM
00
'z
00
c
•H
4-J
CO
•H
:*!
0)
1
CO
w
c
0 ^
•H 4-J
4J -H
cd i-i
1-4 O
CU vH
TJ M
•H a.
CO
C 0)
o 4:
CJ 4-1
I-i 00
cu c
43 -H 00
4-J 4-> C
O CJ iH
0) ^
>sUH C
C M-l cd
42 0
« S rl
0) 3 3
rH C 0
ex co
6 1-4
cd o I-i
X 4J cd
CU CJ r-H
cd 3
1-4 UH CJ
O ^~- -H
Pn 4J
4-1 I-l
C cd
• cu ex
>> 0
4-J CO CU
C CO 43
•H CU 4-1
cd co
4J CO C
1-4 Cd O
cu
0 >, 4-1
C 00 C
3 O 0)
rH 6
4-1 o ex
C C -H
cd 43 3
0 o a*
•H 0) 0)
M— 4 4— t
•H r-l
C rH 0
00 O rl
,-< -H I-i 4-J
1 co 4-i C
ro CO
CO O CJ
. -r-l O
00 43
•H CU CU 4J
fn M 43 i-l
0) 4J J5
C 43
•H 4-1 C 0)
•H 0
6 43 C
M o >> a)
O -H 4-J -H
4-4 43 C U
13 -H CU
T3 cd pu
I-l C 4J X
cd -H I-i 0)
T3 0)
C M CJ S-i
cd O C O
4J 4-1 3 i-l
CO CJ |4
cd o) ex
CU <4-l rH
43 43 4-1
4J cd cd o
I-l
<4H CO CU ^
O CU 13 O
u -H cd
I-i cd co ^H
0) cJ C
Td -H o cd
Vi 13 O
O C3 "
•H CO CO
o) o) ex
43 p 4-1 cd
4-1 cd 43
4-4 CJ M
C O i-l 0)
o *d ex
00 C
13 nj -H "
CU rH 6
co 4-1 £D o
cd i i-i
PQ
-------
30
in which compliance with a regulation may be achieved. In some instances, the
promulgation of a standard that effectively prohibits the operation of the
source may be desired if the emissions are such that there is a significant
health and welfare penalty to be paLd by allowing the emissions to go uncon-
trolled. Open-burning is an example of this type of source category. It will
be discussed in more detail later.
The second item considered is the status of the control technology.
Where there is a demonstrated control technique that is in use, then no flag
is necessary. Likewise, when a control option is available, but has not been
widely used in the industry, no flag is used. If, on the other hand, the con-
trol system (including process and design modifications) is under development
or requires a technology transfer from another similar industry and is not in
widespread use, then the source category is flagged with an RD indicating that
additional research and development is necessary before an NSPS can be set.
These industry/pollutant categories are also shifted further back in the pri-
ority ranking to allow time for the control technology to be developed.
The third considered item is the cost of control. In some cases,
there is a demonstrated control technology, but the cost of applying it is
prohibitively high. In this case, the industry category is given an HC (high
cost) flag. Given the manner in which the screening system is set up, there
might be some argument to include cost as a constraint evaluation and rank it
as a 0, 1, 2, or 3. There is some validity to this approach, but the purpose
of the evaluation is to identify sources for which cost is an overwhelming
obstacle. It does not seem reasonable to develop a priority standard setting
procedure based on relative costs of control, since this is probably better
handled by adjusting the magnitude of the standard rather than the order of
standard setting. It should be emphasized that no attempt was made to do a
comprehensive cost analysis. Instead, the intent was to identify special
industry categories where the cost of control would be unusually high.
The fourth item is the availability of control systems. If an indus-
try can be expected to encounter severe problems in obtaining the necessary
equipment or materials for control, it is given an AV flag.
-------
31
Emission Measurement Evaluation (Factor 4)
This review considers the measurement of emissions from the source.
The first item considered is the determination of whether a method exists to
measure the pollutant of concern from the source. For the criteria pollutants
the published reference methods are available. For some noncriteria pollutants
there may not be a recognized method for determining the emission rate as
would be required for compliance testing, and such categories would be given
an NM flag.
The second item is the feasibility of making an emission measurement
from the source. In general, if the emissions are released through a stack,
it is feasible to conduct some tests for compliance. If the emissions are
from nonpoint sources, it is difficult (if not impossible) to measure emission
rates and the industry is given an NF flag.
The third item is the applicability of the emission measurement for
routine surveillance. As before, this would apply primarily to noncriteria
pollutants and is designed to identify situations where the analysis of samples
is too extensive and complex to be used routinely. This might occur, for exam-
ple, in analysis for certain trace metals. An NS flag is given to indicate
this condition.
Enforceability Evaluation (Factor 5)
This review considers whether or not an enforceable NSPS can be de-
signed within the requirements of the Clean Air Act and subsequent judicial
rulings. Technical problems are the first item considered. These would in-
clude uncertainties in the definition of a source category and the need to
subdivide a category to develop realistic standards, difficulties in determining
compliance with a standard, and the lack of information on source emissions
(applicable especially with regard to new technologies). Industry/pollutant
categories experiencing these types of obstacles would be given a flag desig-
nation TE.
Legal problems are the second item considered, and these include the
authority to promulgate an NSPS for a category, overlapping regulations, pub-
lic demand for control based on the nature of the emissions (e.g., pathological
incinerators), and the lack of sufficient EPA manpower resources to ensure
source compliance. Categories with these problems are flagged with an LE.
-------
32
The third Item considered is the possible use of an equipment stand-
ard in preference to an emission limit. This consideration also includes a
fuel standard where control is achieved by specifying the fuel used. The
flags used are EQ (equipment standard) and FS (fuel standard). The need for
this type of NSPS can be dictated by two different conditions. In one case,
it may not be feasible to design an emission standard due to measurement prob-
lems. In this situation, the industry category would also have flag notations
in the emission measurement evaluation. In the other case, there may be such
a large number of sources that it would not be feasible to enforce a standard
that would require individual source testing. The direct firing of meat cate-
gory presents such a problem. Under these circumstances, an equipment or fuel
standard is the only reasonable way to control the source. There is, however,
some question as to whether this type of standard meets the requirements of
Section 111 of the Clean Air Act. The standards for petroleum storage vessels
have been promulgated in this form primarily for the first reason (i.e., emis-
sion measurement is not feasible). It is not clear what the legal interpreta-
tion might be for an equipment standard set for the. second reason. In any
case, EPA policy must be established for these sources prior to the promulga-
tion of an NSPS.
Individual Source Impact (Factor 6)
This review of typical source size and location is designed to iden-
tify special characteristics of individual sources. Sources that are wide-
spread throughout the country are flagged with WS, sources that are few in
number and tend to be large installation are flagged with FL, and sources that
have especially sensitive locations (e.g., in urban areas) are flagged LO.
Energy Impact Constraint (Factor 7)
The application of air pollution control systems can result in an
increase in energy consumption due to the power requirements of the equipment,
a decreased efficiency of the process, or the requirement for a clean burning
fuel to minimize emissions. The ratings of 1, 2, 3 are designed to give a
perspective on the energy impacts of NSPS on each industry. The numerical
rankings are not designed to indicate relative magnitudes of the impacts but
only qualitative judgments. The ranking of 0 is included for source categories
where NSPS promulgation can result in energy savings.
-------
33
Scarce Resource Constraint (Factor 8)
In some instances, air pollution control requires extensive use of
scarce resources, such as rare metals. Systems that require the use of a
catalytic control device fall into this category most frequently. Although
not representing an insurmountable obstacle, this consideration may dictate
a postponement of standards in the interest of conserving these materials, or
alternatively, influence the level of control to be achieved under the assump-
tion that a less-stringent standard may be met with a different control tech-
nique. If another control option was available besides one that required
scarce resource utilization, then the source category was given a rating of 1.
Ratings of 2 or 3 were given to those categories for which there was no cost-
effective alternative.
Other Environmental Media Constraint (Factor 9)
Air pollution control cannot be considered separately from other en-
vironmental media. When an air pollutant is controlled at the expense of water
quality or through the creation of a solid-waste problem, little has been gained
in compliance with the national policy of environmental protection. Similarly,
control of one air pollutant that results in the increase in emissions of
another may be of questionable desirability. This evaluation is designed to
flag industries with these problems in the interest of identifying the need
for cross-media studies prior to NSPS promulgation. On the other hand, those
industries for which an NSPS can have a synergistic effect in controlling other
emissions and effluents are identified as having increased desirability for
standard development.
Other Considerations (Factor 10)
This consideration is for any item that cannot be classed elsewhere
and might influence the priority ranking. The most frequently used flag is
ES, indicating the existence of an already promulgated NSPS. While this does
not preclude the development of a revised standard it might indicate a lower
priority concern until standards have been set for all industries.
-------
34
3.2.3 Emission Projections and Standard-setting Schedules
Using the Model IV data and the source-screening methodology, it is
possible to develop an ordered list of source categories for the setting of
NSPS. Sources with no major constraint are considered first, while others
with increasingly more severe constraints are postponed. The next questions
that must be answered are how the order of the sources will affect the emission
rates at various points in time and what tradeoffs are possible to maximize
the emission reductions while making allowance for the individual source con-
straints. To obtain these answers, a computation scheme was developed that
used the Model IV data to calculate total emissions from all sources as a
function of time and of the NSPS standard-setting strategy.
The general algorithm constructed for developing the prioritization
and computing the resultant impact on emissions can be used for single or
multipollutant analyses. It proceeds by evaluating at discrete points in time
the need for standards and their ::uture impact. Beginning in 1975 (or any
other initial time), the evaluation is repeated at each time increment (6-month
increments were used in this study) and continues sequentially until the final
time is reached (1990 in this study). At each time t the following analysis
procedure is used:
Step 1. Set standards for all categories that have been
explicitly scheduled for promulgation at time t.
Step 2. If the number of standards set is greater than or
equal to an established maximum, the analysis proceeds to
time t + At.
Step 3. Compute the projected emissions based on standards
already set at time t or earlier, making use of Model IV
Eqs. (3-3), (3-4), and (3-7). Based on these calculations,
determine the pollutant with highest priority because of
projected emissions exceeding goals or criteria.
Step 4. If no goals or criteria are exceeded and the number
of standards set at time t is greater than an established
minimum, return to Step 1 for the analysis at time t + At.
Step 5. For the priority pollutant, select for standard
promulgation the highest ranking source category as deter-
mined by the screening methodology. Skip those categories
that have been explicitly scheduled for standard promulga-
tion at a time t1 not equal to t, or alternatively are
constrained to having standards set after time t', which
is greater than t.
-------
35
Step 6. If the number of standards set at time t is less
than an established maximum, return to Step 3 to determine
the next standard to be set at time t. If the number is
greater than or equal to the maximum return to Step 1 for
the analysis at time t + At.
Because of the well-defined structure for the prioritization algorithm,
a computer program can be easily written to carry out the analysis. In fact,
this becomes a necessity when the number of categories is large and if numer-
ous reevaluations are necessary to determine the effect of alternate criteria
or assumptions.
The option for specifying explicit overriding dates at which a stand-
ard will be promulgated (Step 1 above) is useful for including, for example,
categories for which standards currently existing are proposed, under develop-
ment or scheduled for development. Preventing a standard from being set prior
to a given date (Step 5) simulates categories such as those that require an
intervening period for further development of control technology.
The specification of the maximum number of standards that can be
promulgated at any time (Steps 1 and 6) can be interpreted as units of resources
(manpower, funding, etc.) available for standard promulgation. Associated then
with each standard to be set is a number indicating the units of resources
required to develop that standard. For example, for categories that require
twice the normal resource for standard development (such as for a large, di-
verse category) only one-half as many standards can be set at any one time.
If a standard is being set for a pollutant within a category (Step 1
or 5), the standard for one or more additional pollutants from that category
can also be set if appropriate. Examples of the application of this option
occur when a single control system reduces emissions of more than one pollu-
tant. The resources required to develop standards for additional pollutants
simultaneously is generally less than that required for the first pollutant.
In many instances, emissions can be reduced by future revision of
NSPS as control technology develops and experience in its application is
accumulated. The above algorithm is easily expanded to include the possibility
of revised standards. This expansion includes a checking procedure for pre-
venting a revised standard from being promulgated before a minimum delay time
has passed, since the passage of the initial NSPS. This minimum delay time
is not required if the initial new source standard is a state standard.
-------
36
When applying this algorithm to the analysis of a single pollutant,
the concept of a "priority pollutant" is not used. Instead, the order in
which the standards are set is determined by the source screening methodology
subject to the imposition of limits on standard-setting rate and specifications
of time periods in which a standard can or cannot be set.
The standard-setting priorities to be described in this study were
based primarily on achieving and maintaining as nearly as possible predeter-
mined levels of national emissions for each pollutant. These emission goals
were determined first of all on the basis of absolute levels, relative to 1975
emission rates, needed to satisfy national ambient air quality goals, and se-
condly on the basis of reductions that are technically feasible, as indicated
by the separate evaluation of NSPS priorities for each pollutant. The national
emission levels, which would result in the attainment and maintenance of the
National Ambient Air Quality Standards (NAAQS), cannot be precisely defined
without the spatial disaggregatioii of emissions to at least an Air Quality
Control Region (AQCR) level, since offsetting emision increases and decreases
in separate areas can result in new or continued violations of NAA.QS, while
total emissions are decreasing. Without going to a disaggregated analysis,
specification of national emission goals is restricted to more qualitative
judgments based on considerations such as the number and severity of NAAQS
violations and their potential impact.
The difficulty in establishing precise national emission goals is not
as constraining a problem in establishing NSPS priorities as might be initially
supposed because of the importance of the second consideration, the potential
for control via NSPS with application of "best available control technology."
This potential for control determines the maximum reduction achievable under
Section 111 of the Clean Air Act as opposed to that reduction that is required
for the attainment of the NAAQS. This maximum reduction, however, cannot be
achieved because of constraints to NSPS promulgation, and it is only in the
determination of how this deviation from maximum reduction will be apportioned
among the pollutants considered that national emission goals have a role. The
importance of additional Clean Air Act mechanisms in meeting the NAAQS, such
as State Implementation Plans and mobile source controls, is clearly evident.
-------
37
Having defined the maximum emission level goal, the priority pollu-
tant at time t was determined (Step 3) by computing the minimum emissions that
will occur at each point in time in the future (at.times greater than t) if no
standards are set for that pollutant at time t. This minimum occurs under the
assumption that all remaining standards are set at time t + At. The priority
pollutant is that with largest value of projected minimum emissions relative
to the established emissions goals for that pollutant, and is illustrated by
the ratio A/B in Fig. 3-2.
The rationale for using the minimum projected emissions for evaluat-
ing priorities is that the growth in new source emissions that occurs during
the period between times t and t + At is the only penalty that can be directly
related to not setting standards at time t, since any additional loss in con-
trol of new source emissions can be prevented by standards set at time t + At.
Although assuming that all standards can be set at the following time t + At
is not completely correct, the alternative of determining the priority pollu-
tant on the assumption that no standards will exist in the future other than
those promulgated previous to time t gives an even less realistic projection.
An optimal analysis in the strict sense would simultaneously consider all pos-
sible standards in all time periods, but this becomes extremely complex because
of the nearly infinite number of combinations possible.
A possible variation to the above procedure for determination of
priorities is based on the total integrated emissions over the period under
consideration as opposed to selecting for evaluation the maximum emission rate
at any one point. Also considered was the possibility of basing the prioriti-
13
zation on projections of growth (using, for example, the OBERS projections)
in regions that are expected to have difficulty meeting NAAQS. In addition to
the enormous amounts of data that must be managed, the problem of the question-
able validity of projections of growth for a particular industry category in a
small geographic area prompted the rejection of this approach.
3.2.4 Efficiency Ratio
With the large volume of data that can be generated from the emission
projection routines, it is desirable to have one single measure of how each
prioritization strategy compares to others for use as an initial evaluation.
The measure chosen for use here is the effectiveness of a particular strategy
-------
38
W/0 NSPS
MAX. EMISSIONS WITH
At STANDARD DELAY
CRITERIA
EMISSIONS
LEVEL
NSPS AT t
HAt
1975
1990
TIME
Fig. 3-2 . Emission Projections with and without NSPS
-------
39
in reducing emissions relative to the maximum achievable reduction. This
effectiveness is termed the "efficiency ratio" and is given by:
E - E
Efficiency Ratio, % = Emax _ gP— x 100 (3-15)
max min
where E is the maximum emissions that would result from no further promul-
max
gation of NSPS (i.e., the implementation of existing standards only), E is
the emissions resulting from the standard-setting prioritization under study,
and E . is the minimum possible emissions that would result from the setting
mm
of all NSPS immediately, excluding those where cessation of operation is the
only feasible control option.
All quantities on the right-hand side of Eq. (3-15) are computed for
a given point in time. It is evident that the efficiency ratio changes with
time, depending on the prioritization strategy. From the nature of the Model
IV procedures, it is also evident that the efficiency ratio will tend to level
off at some value less than 100%. This is a result of the fact that the Model
IV calculations assume that individual facilities that are built prior to NSPS
promulgation continue at their uncontrolled emission rate indefinitely. The
time scale considered is not long enough to have all these sources become ob-
solete. Because of the asymptotic approach of the efficiency ratio to a con-
stant value, it becomes a useful measure of the prioritization strategy's
effectiveness; this is especially true when it is computed for the last time
period (i.e., 1990). Figure 3-3 gives an example of the computed efficiency
ratio as a function of time for several hydrocarbon prioritization procedures.
The asymptotic approach to a constant value is evident for all cases except
when the standard-setting pace is too slow for all the standards to be set in
the time frame considered. Even in this case, however, the value of the effi-
ciency ratio computed in 1990 provides a first-order rating of the prioritiza-
tion strategy relative to other procedures. In the following analyses, there-
fore, the 1990 efficiency ratio is used as a measure of priority effectiveness.
(The unusual slope of the curves in the late 1970's is the result of the particu-
lar hydrocarbon standard-setting strategy used in this example. Standards for
some large sources have been delayed due to some constraints and the slope of the
curve changes sharply when they are finally set. This will become evident in
the discussions in Section 4.)
-------
40
UJ
g
•H
4-J
Oj
•H
^
OS
a
CD
•H
O
o
CD
w
bO
•H
%'OllVd AON3I3IJJ3
-------
41
3.3 SPECIAL PRIORITIES FOR NSPS
Using the previously described prioritization methodology, a ranking
of source categories can be developed subject to the 9 factors outlined: Model
IV projections, control technology, emission measurement technology, enforceability,
individual source impact, energy impact, scarce resource impact, other envir-
onmental media impact, and other considerations. The promulgation of New Source
Performance Standards, however, is only one of a number of management mecha-
nisms, and as such is subject to other demands and requirements that do not
fit into the classification schemes outlined in the methodology. Considerations
may arise that dictate the promulgation of a standard for a specific source
category irrespective of its position in the ranking. As a flexible control
program, NSPS promulgation must be able to respond to these considerations and
adjust the allocation of resources accordingly. The emission projection pro-
cedure will provide an assessment of what emission penalties must be paid to
change the priority schedule.
The identification of special priorities for NSPS is an exercise in
planning and resource allocation that should be carried out at a level where
total environmental control perspectives can be maintained.
The purpose of this section is to review those priority "areas of
emphasis" that will influence the NSPS ranking process independently of any
screening technique that can be applied. The first factor on the standard
industrial evaluation form (Fig. 3-1), "Special Priority," is used to identify
sources that fall into one of these areas.
Selection of special priority issues was made upon review of EPA
internal memoranda and published work, which were designed to identify prob-
lem areas. A recent study completed by Argonne into forecasting new air
pollution problem areas was used to expand the list. Issues were classified
as pollutant priorities or strategy priorities.
3.3.1 Pollutant Pm-orit-ies
Nitrogen Oxides and Hydrocarbons
The control of nitrogen oxides and hydrocarbons has been identified
as one of the principle objectives of NSPS. Both pollutants participate in
photochemical oxidant formation and the state of the art of source-receptor
-------
42
dispersion modeling is crude in this case. Lacking an analytical tool that
can be used to develop alternative control strategies, the application of
best available control technology through NSPS ma}' be the most viable way to
proceed.
The additional complication of mobile source emission contributions
puts further emphasis on the NSPS control program. Proposed amendments to
the Clean Air Act suggest relaxation of the stringent NOX exhaust emission
regulations for automobiles with added emphasis to be placed on stationary
source controls. Although the following analysis will show that NO emission
reduction over the 1975-1990 time period is not possible with even maximum
application of NSPS, a vigorous program of stationary source controls is
necessary to minimize the emission increases.
Sulfates
54
Recent studies have indicated that sulfates are a potentially hazard-
ous component of atmospheric pollution. As with HC and NOX, the state of the
art of dispersion modeling for this pollutant is undeveloped. Likewise, the
body of knowledge on the dose-response of various susceptible portions of the
'population is limited. A significant research effort is currently under way
under EPA sponsorship to identify the potential problems more definitely.
Control of sulfates through NSPS regulation of sulfur compound emis-
sions appears to be the most efficient way to proceed, given the current state
of knowledge. This will, nevertheless, be an exceedingly complex task due to
the national energy situation. Control of sulfur compound emissions has a
marked effect on fuel requirements, since fuel switching is one of the most
effective methods of control. The same difficulties as have been encountered
with the control of SOg can be expected in an attempt to control total sulfur
compounds.
Fine Particulates
Submicron-size particulates are potentially the most hazardous because
of their deep penetration into the respiratory system. The development of an
ambient air quality standard for fine particulates is difficult because of the
uncertainties of atmospheric reaction processes (such as aerosol formation)
and the relationship of ambient concentrations to source emission character-
istics.
-------
43
Trace Metals
As with sulfates and fine particulates, the effects of trace metals
(e.g., lead, manganese, chromium, vanadium, etc.) as atmospheric pollutants
are receiving ever increasing attention. Interest in them is heightened by
recent findings that some species tend to have a strong affinity for fine
particulates and, therefore, are transported into the respiratory system where
their potential health effects are maximized. The setting of an ambient air
quality standard for all trace metals would be a monumental task and would
consume an extremely large resource of money and manpower to enforce. NSPS
appear to be the logical alternative, although the hazardous pollutant regula-
tions (Section 112 of the Clean Air Act) may prove preferable for certain
species.
Other Noncriteria Pollutants
Several other noncriteria pollutants have been evaluated as being
candidates for an NSPS control program. Included are fluorides, acid mist,
benzo (a) pyrene, and odors. Control of these pollutants under Section lll(d)
of the Clean Air Act would mean that NSPS and the application of some existing
source retrofit standard would comprise the entire control program. There are
obvious advantages in simplicity and resource conservation in this approach
21
and its use was studied in another program at Argonne under EPA sponsorship.
Fluoride and acid mist control has already been initiated under the NSPS program.
3.3.2 Strategy Priorities
Nondegradation Source Control
Q
Recently promulgated regulations for the prevention of significant
air quality deterioration in areas currently below secondary NAAQS are aimed
at providing controls on sources of SOa and particulates that, by the location
of a single facility, are capable of presenting substantial problems in stand-
ard attainment. Since the facilities considered for control are exclusively
new plants, the NSPS program is a vital portion of the regulatory effort.
By ensuring application of best-available control technology, the source im-
pacts can be minimized.
-------
44
Air Quality Maintenance Planning (AQMP)
Substantial planning efforts are underway for the development of pro-
grams designed to demonstrate maintenance of the NAAQS over the ten-year period
of 1975-1985. The development of control strategies is heavily dependent on
NSPS as an indication of what level of emission control can be expected in
newly developed industrial areas. Since the AQMP process relies on NSPS
controls, the promulgation of standards for pollutants that are involved is
a special need. Air quality maintenance area designations number 159 for
particulates, 61 for S02> and 49 tor oxidants. For CO, 24 have been proposed
9 10
and for NOa , 5. ' Control of the oxidant problem depends on HC and NOV con-
X
trols; therefore, the AQMP process creates demand for NSPS for all criteria
pollutants.
Augmentation of NAAQS Attainment Strategies
Many areas of the country are experiencing considerable difficulty
in attaining the primary NAAQS. Particulates appear to be a widespread prob-
lem because of the complicating features of high-background levels, fugitive
dust sources, and a large number of difficult-to-control sources. Oxidants
and sulfur oxides are also presenting problems, but not as widespread. The
use of NSPS to augment the air quality management, strategies is a necessary
feature of the overall control program.
Air Quality and Energy Relationships
The current national energy situation may result in some reorientation
of the NSPS program in the interest of energy conservation. An initial consid-
eration might be the postponement of NSPS that require significant increases
in energy consumption (e.g., the use of an afterburner requiring natural gas as
additional fuel). Another possibility is the acceleration of standard promul-
gation for sources that would experience energy conservation as a result of
NSPS (e.g., petroleum handling loss reduction, use of self-sustaining after-
burners for heat recovery).
Emerging Industries
The development of new industrial processes presents a unique oppor-
tunity to integrate air pollution control into the early stages of system
-------
45
design rather than including it as an afterthought. Industries such as coal
gasification, refuse boilers for heat recovery, gas turbines used for electric-
ity generation, and others are in the high-growth-rate stages and substantial
benefits are to be had by developing uniform emission control requirements in
these initial periods.
Integration of Environmental Control Programs
One criticism often leveled at the national environmental control
program is that it is fragmented to the point of one effort contradicting or
conflicting with another. This is a special problem when different environ-
mental media (i.e., air, water, solid waste) are concerned. There is a need
to coordinate the regulatory efforts of all programs into a unified, consist-
ent process. For the NSPS effort, this means conducting standard development
studies in parallel with efforts in water pollution control, solid-waste
management, and/or hazardous material handling.
-------
47
4. STANDARD SETTING PROGRAM ALTERNATIVES
4.1 EVALUATION PROCEDURE
The combination of the Model IV data, the source-screening method-
ology, the emission projections, and the priority areas of emphasis can be
used to evaluate alternative NSPS programs. The method used here proceeds
by reviewing alternative standard-setting programs for each pollutant, eval-
uating the impact of a combined pollutant control program, and determining
the effects of special priorities.
In the individual pollutant analyses, the limits of NSPS control
potential are determined from the emission projection model. Emission esti-
mates under four conditions serve as bounds to the problem. First, it is
assumed that no NSPS are set and the projected growth in each industrial cat-
egory is controlled by State Implementation Plan regulations only. The anal-
ysis shows that emissions of every pollutant will increase markedly over the
1975-1990 time period. Second, only existing NSPS are assumed to be in effect
and the emission projections are recomputed. This gives an indication of what
portion of the control potential has been realized by previous work. Third,
the maximum control potential is determined by assuming all standards, with
the exception of those for source categories that lack a control technology,
are set immediately. Although this is not realizable in practice, at does
serve as a lower bound on emissions. Fourth, a nominal standard-setting pace
is assumed, and the order in which the standards are set is assumed to be de-
termined strictly by the Ts-Tn ranking. Given the limits established by these
four conditions, it is possible to evaluate the effectiveness of program alter-
natives .
The next step in the individual pollutant analysis is to conduct the
source-screening review to identify factors that would alter the source cate-
gory ranking from that dictated by Ts-Tn order. Alternative strategies, wherein
constraints are applied or ralaxed in turn, can be evaluated for their impact
on emissions. The selection of the most desirable strategy is based on maxi-
mizing emission reductions within the limits of the constraining conditions.
The combined pollutant analysis uses the results of the individual
pollutant reviews to fix the order in which standards are set for any one
-------
48
pollutant. It then investigates the effects of emphasizing one pollutant
over another and evaluates the effects of programmatic decisions, such as
standard-setting rate, delays between new and revised NSPS, and others.
Finally, the special priority analysis determines the effects of
external factors, which change the previously determined order of source
categories, and which alter the control potential achievable.
The choice of a 1975-1990 planning horizon is, to some extent, an
4
arbitrary selection. The Model IV data developed by TRC was designed to
cover the period through 1985. This was extended to 1990 in this study to
allow sufficient time for all standards to be set. Extension beyond 1990 was
deemed unnecessary, since once all standards are set the relative differences
between priority strategies remains constant.
For convenience, the emissions in 1975 are given on Table 4-1. These
are constant and independent of the NSPS program alternative chosen. Emissions
12
from EPA's National Emission Data System (NEDS) 1972 file are also included
for reference. The apparent discrepancies between the Model IV data and the
NEDS data result from the different approaches. The NEDS file is based on an
actual emission inventory of existing sources. The Model IV data are general-
ized estimates based on nationally averaged information. Given these two widely
differing procedures, the comparisons are reasonably consistent.
Table 4-1. Comparative Emission Rates
Emissions, 106 tons/year
Pollutant
Particulates
S02
NOX
HC
CO
1975
Stationary
Sources
10.40
31.10
11.14
14.41
39.36
Model IV
Mobile
Sources
0.55
0.53
8.85
12.49
64.30
Data
Total
10.95
31.63
19.99
26.90
103.66
1972
Stationary
Sources
17.79
31.40
15.33
10.35
24.27
NEDS Data
Mobile
Sources
0.77
0.62
8.72
16.28
77.42
Total
18.56
32.02
24.05
26.63
101.69
Details of computation given in Appendix A.
-------
49
4.2 POLLUTANT PRIORITY ANALYSIS - PARTICULATES
The emission projections that form the basis for evaluating NSPS needs
and priorities for stationary sources of particulates are summarized in Fig.
4-1. Curve 1 shows the increase in emissions with no NSPS in effect and sources
controlled by state regulations only (including state standards for new sources,
E in Eqns. 3-7 and 3-8). The 1990 emissions are more than 59% higher
s new
than 1975 levels. Curve 2 illustrates that a substantial reduction in projec-
ted 1990 particulate emissions has already been achieved by the previously
promulgated NSPS (including state new source standards), but that the achieved
reduction is not sufficient to maintain future emissions below 1975 levels.
An increase of more than 18% is calculated. A reduction of 23% below 1975
levels could, however, be achieved by setting all possible standards in 1975,
as shown by C>-vve 3. The emissions projections from these two cases, i.e.,
existing NSPS only and all possible standards set in 1975, represent the bounds
within which future emissions will lie.
The first-order prioritization is that based strictly on Ts-Tn values
from Model IV calculations. Using this procedure (excluding categories for
which no control technology exists) and assuming a nominal standard-setting
rate of 6 particulate standards per year, emission projections below 1975
levels are achieved, as shown by Curve 4. Only a small change from the max-
imum control case is evident. The final particulate prioritization that con-
siders additional factors is shown by Curve 5. The basis for this final
prioritization is discussed later.
Using the source-screening methodology of Section 3, sources of partic-
ulate emissions were separated into seven groups with similar constraints or
restrictions to NSPS promulgation. These were moved to a lower priority and
the impact of the reordering on emission projections was evaluated. Follow-
ing the regrouping, perturbations and adjustments were made to the ranking to
obtain the final particulate priority ranking. Categories included in each
constraint group are listed in Tables 4-2a through 4-2g.
Existing NSPS (ES)
Particulate NSPS have been promulgated or proposed for the 11 cate-
gories or subcategories indicated by an ES flag in Table 4-2a. For most of
the categories given on the table, the primary restriction on setting a revised
NSPS is the need to analyze data from sources subject to the initial NSPS and
-------
50
20
cc
O
cc
10
0.
STATIONARY SOURCES
I. ONLY STATE STANDARDS
2. ONLY EXISTING NSPS AND STATE STANDARDS
3. ALL NSPS SET IN 1975
4. NSPS SET IN Ts-Tn ORDER, 6 PER YEAR
5. FINAL TSP PRIORITY, STRATEGY 10, 6 PER YEAR
1975
1980
1985
1990
YEAR
Fig. 4-1. Particulate Emission Projections for Stationary Sources
-------
51
Table 4-2a. Particulate Source Categories with
Existing NSPS (Group ES)
Category
Boilers
(>250xl06 Btu/hr)
Asphalt Batching
Iron and Steel Plants
(Electric Arc Furnaces)
Cement Plants
(Kolns, Clinker Coolers)
Petroleum Refinery
(FCCU)
Municipal Incinerators
Brass and Bronze
Smelters
Secondary Lead
(Reverberatory Furnaces)
Secondary Lead
(Blast Furnaces)
Sludge Incineration
Iron and Steel Plants
(BOF)
Ts-Tn, 1985
(tons/year)
490,000b
25,000b
8,700b
5,200b
3,800b
3,700b
50b
30b
6b
N/Ad
N/Ad
Ts-Tn Constraint arid
a
Rank Priority Flags
lb
17b
30b
42b 3-RDC
49b
50b 3-RDC
96b 3-RD°
97b 3-RD°
101b 7-2, 9-0
N/Ad
N/Ad
First number is the factor considered, second character is the flag.
Definition of flags is given in Section 3.2.2.
Based on the promulgation of a revised NSPS.
"These sources have additional major constraints on the promulgation of a
revised standard (i.e., additional research and development is required).
Not applicable since these sources are not candidates for a revised NSPS;
i.e., the present NSPS is felt to represent the best control technology.
-------
52
Table 4-2b. Particulate Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN)
Category
Boilers
(10-250xl06 Btu/hr)
Grain Handling
(Processing)
Stone Quarrying and Processing
Grain Handling
(Transfer)
Industrial/Commercial Incineration
Grain Handling
(Screening, Cleaning)
Boilers
(Wood Waste)
By-Product Coke Ovens
Lime Manufacture
Steel Foundries
(Secondary)
Cast Iron Foundry
(Electric Furnace)
Primary Copper
Wood Processing
(Plywood)
Sand and Gravel Processing
Primary Aluminum Smelters
Whiskey
Vegetable Oil Manufacture
Mixed Fuel Boilers
Ts-Tn, 1985
(tons/year)
420,581
111,000
91,100
90,700
88,450
80,800
80,800
59,600
42,500
27,900
27,500
26,400
22,600
21,700
15,700
14,600
13,200
10,500
Ts-Tn
Rank
3
4
5
6
7
8
9
12
13
14
15
16
18
19
22
23
24
26
Constraint and
Priority Flags3
3-HC,b 5-EQ,b
10-U
3-U, 5-EQb/U
3-HC,b 5-EQ,b
10-U
3-HC,b 5-EQb
3-HC,b 5-EQb,
10-U
3-U
6-FL
3-HC,b 10-0
3-HCb
3-HCb
3-U
3-U, 5-EQb/U
3-U
6-FL, 9-0
(Coal and Refuse)
Phosphate Rock
(Grinding)
10,500
27
3-HC
-------
53
Table 4-2b. (Contd.)
Category
Concrete Batching
Nitrate Fertilizer
Coal Cleaning
(Thermal Drying)
Grain Handling
(Drying)
Beer Processing
Feed Milling
Deep Fat Frying
Ferroalloy
Synthetic Resins
Charcoal
Polypropylene
Sodium Carbonate
(Natural)
Cotton Ginning
Ceramic Clay
Synthetic Fiber
(Dacron)
Polyvinyl Chloride
Gypsum
Iron and Steel Plants
(Scarfing)
Paint Manufacture
Secondary Aluminum
Ts-Tn, 1985
(tons/year)
9,680
7,900
7,500
7,400
7,300
7,300
6,000
5,600
5,540
5,300
5,100
4,950
4,800
4,100
3,850
3,600
2,700
2,400
2,000
1,900
Ts-Tn Constraint and
0
Rank Priority Flags
29 5-EQb
31
32
33 3-U, 5-EQb
34
35 3-HCb
38 3-RD,b 5-EQ,b
9-0
39
40
41
43 6-FL
44
45 9-0
46 3-U, 5-U
47 3-U, 9-0
51 9-0
53
57 3-U, 6-FL
60
61 9-0
(Reverberatory Furnace)
-------
54
Table 4-2b. (Contd.)
Category
Secondary Copper
(Smelting)
Secondary Copper
(Handling)
Synthetic Fiber
(Nylon)
Feed Mill - Alfalfa Dehydrating
Lead Acid Battery Assembly
Flyash Sintering
Frit
Phosphoric Acid
(Thermal Process)
Wood Processing
(Pulpboard)
Perlite
Carbon Black
(Furnace Process)
Secondary Aluminum
(Sweat Furnace)
Clay Sintering
Mining and Milling of Lead Ore
Explosives
(High)
Primary Lead Smelters
Primary Zinc Smelters
Secondary Zinc
(Sweating)
Meat Smokehouses
Animal Feed Defluorination
Ts-Tn, 1985
(tons/year)
1,900
1,400
1,320
1,300
1,000
990
940
721
700
610
500
460
420
297
290
250
240
196
170
160
Ts-Tn Constraint and
ft
Rank Priority Flags
62
63 3-U
64 3-U, 9-0
65 3-HCb
69 9-0
70
71 3-U, 9-0
72 9-0
73 3-U
76
78
81
82
83
84 3-U
86 9-0
87
88
89
90 3-U, 6-FL, 9-0
-------
55
Table 4-2b. (Contd.)
Ts-Tn, 1985 Ts-Tn Constraint and
Category (tons/year) Rank Priority Flags
Styrene Butadene Rubber 130 91 3-U
Secondary Zinc ,„„ „„
(Distillation)
Secondary Lead 2Q gg
(Pot Furnace)
Secondary Magnesium Smelting 20 100 3-U
Fish Meal Processing 4 102 3-HC
Definition of flags is given in Section 3.2.2.
Constraint is removed by subcategorization of source.
-------
56
Table 4-2c. Particulate Source Categories Requiring Control Systems
with Moderate Constraint Rating due to Increased Energy
Consumption (Group MCR)
Category
Brick and Related Clay Products
Ammonium Sulfate Fertilizer
Iron and Steel Plants
(Sintering)
Phosphate Rock
(Drying)
Diammonium Phosphate Fertilizer
Sugar Cane
(Bagasse Burning)
Asphalt Roofing
(Saturator)
Starch Manufacturing
Petroleum Refinery
(Process Gas Combustion)
Asphalt Roofing
(Blowing)
Mineral Wool
Phosphate Rock
(Calcining)
Auto Body Incineration
Detergent
Granulated Triple Super -Phosphate
Fertilizer (Storage)
Coffee Roasting
Castable Refractory
Soap Manufacturing
Ts-Tn, 1985
(tons /year)
12,400
9,900
6,200
3,800
2,600
2,600
2,400
2,300
1,300
1,100
1,100
630
600
490
470
90
90
80
Ts-Tn
Rank
25
28
37
48
54
55
56
58
66
67
68
75
77
79
80
93
94
95
Constraint and
Priority Flags
7-2,
7-2
7-2
7-2
7-2
7-2
7-2,
7-2
3-U,
7-2,
7-2
7-2
7-2,
3-U,
7-2
7-2,
3-U,
7-2
8-0
9-0
7-2
9-0
9-0
7-2
9-0
7-2
o
Definition of flags is given in Section 3.2.2.
-------
57
Table 4-2d. Particulate Source Categories for Which an
Equipment Standard is Preferable (Group EQ)
Category
Ts-Tn, 1985
(tons/year)
Ts-Tn Constraint andr
Rank Priority Flags'
Direct Firing of Meats
Pathological Incinerators
19,500
29
20 6-WS, 9-0, 10-U
98 5-LE, 9-0
Definition of flags is given in Section 3.2.2.
Table 4-2e. Particulate Source Categories Requiring Fuel
Switching to Achieve NSPS (Group FS)
Category
Ts-Tn, 1985 Ts-Tn Constraint
(tons/year) Rank Priority Flags'1
Boilers
(0.3-10xl06 Btu/hr)
Boilers
(<0.3xl06 Btu/hr)
Stationary Gas Turbines
Electric Utility
Pipeline
Internal Combustion Engines
(Diesel and Dual Fuel)
597,000 1 5-EQ, 7-3, 9-0
76,300 10 5-EQ, 7-3, 9-0
64,500 11 5-EQ, 7-3, 9-0
3,600 52 5-EQ, 7-3, 9-0
2,000 59 5-EQ/LE, 7-3
Definition of flags is given in Section 3.2.2.
These sources are treated together.
-------
58
Table 4-2f. Particulate Source Categories Requiring Control
Technology Research and Development Priof to
NSPS Promulgation (Group RD)
Category
Glass Production
(Soda Lime)
Mixed Fuel Boilers
(Oil and Refuse)
Fiberglass
(Textile Processing)
Glass Manufacturing
(Opal Glass)
Ts-Tn, 1985
(tons/year)
15,700
7,200
670
250
Ts-Tn Constraint and
Rank Priority Flags3
21
36 6-FL/LO
74
85 9-0
Definition of flags is given in Section 3.2.2.
Table 4-2g. Particulate Source Categories for Which There
Is No Control Technology Available (Group NC)
Category
Ts-Tn, 1985
(tons/year)
Ts-Tn
Rank
Constraint and
0
Priority Flags
Open Burning
(Agricultural)
Sugar Cane
(Field Burning)
2,603,100
84,000
N/A
N/A
5-LE
5-LE
Hydrofluoric Acid
Fiberglass Production
(Wool Processing)
Iron and Steel Plants
(Blast Furnace)
Wood Pulping
(Kraft)
Wood Pulping
(Sulfite)
Orchard Heaters
0
0
0
0
0
0
N/A 7-2
N/A
N/A
N/A
N/A
N/A
Definition of flags is given in Section 3.2.2.
Based on an assumed value of E =0.
n
-------
59
evaluate the practical feasibility of making the limits stricter. Given the
rate at which this information could be assembled and the rate at which the
mechanics of revising the standard could be completed, it appears that five
years is a reasonable estimate of the delay time between the promulgation of
the original NSPS and the promulgation of a revised standard. Therefore, in
this analysis, the setting of the revised NSPS for these sources is subject
to a five-year lag time. Other than this consideration, the sources are
included in their respective groups in Ts-Tn order. Should the standard-setting
strategy selected reach these sources prior to the elapse of the five-year
period, they will be passed over and standards will be set at the end of the
five years. Should the strategy reach these sources later than the five
years, the standards will be set in normal Ts-Tn ordei.
For the cement plants (kilns and clinker coolers), municipal incinera-
tors, and brass and bronze smelters, revised standards would require addi-
tional research and development. Since these constraints are more severe
than the procedural constraint of revising a standard, these categories were
also treated with the RD group discussed below.
The sludge incineration and basic oxygen furnaces at iron and steel
plants were not considered for revised NSPS since the current standard is
felt to reflect the best control technology for these sources. In addition
to the existing particulate NSPS shown here, standards for the primary zinc,
primary lead, ferroalloy, and coal cleaning categories have recently been
promulgated. At the time the TRC data were assembled it was decided to ignore
the proposed standards since the final disposition was uncertain. For con-
sistency's sake, these recent promulgations and proposals are also ignored
here. All of these categories fall in the Unconstrained Group described
below.
Unconstrained (UN)
The group without any major restrictions to the establishment of
NSPS contains 64 source categories (Table 4-2b) . The boiler (10-250xl06 Btu/
hr) category rated highest in Ts-Tn value for this group and would thus be
given the highest priority in the final prioritization of particulate sources.
Assuming an average size of lOOxlO6 Btu/hr, over 14,000 new sources in this
category will be constructed by 1990. A NSPS of 0.127 lb/106, compared to
-------
60
the existing state regulations, would result in an emission reduction of
635,000 tons/year in 1990. The enforcement effort for this number of sources
would be large, but not prohibitive, in view of the reduction possible. The
cost per pound of pollutant removed could be somewhat larger than for the units
>250xl06 Btu/hr, but again should not be prohibitive. The grain handling
(processing and handling) were the second and fourth categories in this
grouping; however, a high level of uncertainty (indicated by the "U" flag)
in the actual reduction achievable remains because of the diverse nature of
this industry and the level of emissions emanating from uncontrollable fugitive
sources. Similar comments relate to the sand, stone, and gravel industries
that ranked high in this group. In addition to this high ranking, there is
an incentive to promulgate NSPS for the lime category because of its similarity
to the portland cement category for which there is existing NSPS.
The recently promulgated standards for primary zinc, primary lead,
coal cleaning, and ferroalloy were not considered in these data.
Moderate Constraint Ratings (MCR)
The most viable method of attaining the indicated reduction in
emissions for this group (Table 4-2c) is through application of scrubbers
or afterburners. The energy consumption of these devices in comparison to
baghouse or ESP's was the basis for placement of the categories into a
separate group. The highest ranking category in this group, brick and
related clay products, was ranked only number 25, based on Ts-Tn value.
Equipment Standard Preferable (EQ)
The two categories, pathological incinerators and direct firing of
meats, in Table 4-2d consist primarily of numerous small units and the only
practical means of enforcing NSPS is to require an equipment standard.
Questions as to the validity of equipment standards under Section 111 places
a constraint on NSPS promulgation for these categories. Consideration of
public demand for control of pathological incinerators for esthetic reasons
may, however, indicate a higher priority for this category.
-------
61
Fuel Switching Required (FS)
With the exception of moderate size boilers (see UN group) further
reduction in particulate emissions for boilers and other fuel combustion
sources in Table 4-2e is only achievable in the 1975-1990 period through
fuel switching. The low availability of necessary fuels thus places a
severe constraint on further standard promulgation for these sources. Re-
moval of this group from the Ts-Tn ordering had the largest single impact
on projected emissions and should therefore be subject of continuing evalua-
tion to determine applicability of new technology or increased availability
of required fuels. The stationary gas turbines are treated together with
the following effort:
Category Normalized Standard Development Effort
Stationary Gas Turbines
Electric Utility 0.5
Pipeline 0.5
Research and Development Required (RD)
Categories in this group (Table 4-2f) cannot achieve the indicated
emissions reduction without applying advanced control technology or process
changes that have not been fully developed. For the mixed fuel boilers (oil
and refuse) category, it may be necessary to promulgate standards to provide
uniform control for the emerging industry; however, significant reduction
below current levels, which are equivalent to NSPS for utility boilers, is
not expected.
The availability of control technology was based in part on the first-
order approximation that emissions could be controlled to a level of 0.01
grains/standard cubic ft. exhaust gas concentration with current technology,
unless specific contrary information was available. This level approximates
that for existing NSPS.
No Demonstrated Control Technology Available (NC)
The open burning (agriculture and sugar cane) categories are the
largest emitters in this group in Table 4-2g; however, Section 111 of the
Clean Air Act in its present form would be difficult to apply to these categories,
-------
62
An evaluation of the effect of imposing the above constraints on the
priority ranking is summarized in Table 4-3. The first four strategies corres-
pond to Curves 1-4 in Fig. 4-1. In Strategy 5, the RD constraint group was
delayed with only minor impact on emission projections in comparison to
Strategy 4 with standards set in strict Ts-Tn order. On the other hand, delay
of the group requiring fuel switching (FS) in Strategy 6 had the largest single
impact on projected emissions of any constraint group, increasing the 1990
projected emissions from -17.3% to -6.7% below 1975 values and decreasing
the efficiency ratio to 60.5%.
Delaying the moderate constraint rating group (MCR) in Strategy 7
and the equipment standards (EQ) in Strategy 9 also had only a minor impact
on projected emissions.
Strategy 9 represents the case when all constraint groups are post-
poned. The emissions projections remain below 1975 levels except for a
small increase in 1976 before sufficient additional standards are promulgated.
In Strategy 8 the single category of moderate size steam generators
(10-250xl06 Btu/hr) was removed from the unconstrained (UN) to the fuel
switching (FS) groups. The result was a significant increase in projected
1990 emissions that exceeded 1975 levels, clearly illustrating the importance
of placing NSPS development for this category in high priority.
Because of the large number of sources in the unconstrained group
(64), setting all standards in this group as a first priority results in a
longer-than-warranted delay of standard setting for the subsequent group (MCR),
which requires energy consuming scrubbers or afterburners. As an alternative,
in Strategy 10 only the categories in the unconstrained group with 1985 Ts-Tn
values greater than 3000 tons/year were kept in the high priority ranking and
the remainder of the unconstrained group were combined with the subsequent
group in an order based on Ts-Tn values. This strategy was considered the
baseline prioritization for particulate categories for use in the simultaneous
consideration of all pollutants as discussed in Section 4.7. In Strategy 10,
the setting of standards for the group requiring fuel switching is not
initiated until 1990 at the standard setting rate of 6 per year.
The effect of alternate rates of 4 and 10 per year for particulate
standards is illustrated by Strategies 11 and 12. The large impact of
-------
63
n3
>
S-i
3
e
§
en
>
w
CD
4J
cti
J-i
j-J
w
>
w
*rH
S-i
o
tp-i
j_j
P-<
CD
0)
4-J
cfl
[ — J
3
U
•H
4J
M
CO
PH
m
1
-a-
OJ
iH
Oj
H
a ^-.
c s^s
CU x_>
a o
•H H
14-1 4-J
M-l CT3
w a;
m
O 00 O>
CT\ C iH
CTv Cfl
-* .£ 6
O O
V-i
frS H-<
en ^-.
C X
o a,
•H 4-1
to
W ^
-H 0
8 rH
w ^
in
(1) r-*
OC CT\
TO
-C B
U O
J-.
e-5 y-i
m
CO
-H
to ,--»
C >,
O CX
•H *-i
U)
CQ ,
CO
e a>
W 4J .— v
« >.
e cc: c^
3 4-1
e
X O
OJ rH
S ^
OJ
"U OJ ^-~-
SJ CSJ (-*
CO >-,
~o oc^-
c c •
nj -H o
4-1 -U C
W 4-1 ^^
0)
cr:
u
JD
>,
&C
or
n3
CO
>,
4-1
•H
!M
H
Jj
Cu
O
r-~
0^
1
ro
CT>
u-l
4-
^r>
un
^D
i— i
>
o
en
T3
)-t
n)
-o
C
CO
j_j
w
OJ
4-J
(fl
V)
•-H
0
o
\r>
CO
i-H
<-
m
fN
fNJ
0
+
UD
,
C
°
Cs|
O
0
o
^-4
Cst
m
CNJ
|
ON
cr.
r-
CNl
vO
1
CN
r~-
CO
m
r--
a%
0
CO
c^
1
O>
ro
CO
C*")
CsJ
1
^O
av
m
•<£>
r~^
o>
m
en
ex
D
O
00
Q
CO X-N
OS CO
CJ [14
s: -^
cd
QJ O
0 ^
D. ?:
4J ^3
CO ^
o
Cu
r~-
Csl
^o
-J-
r^-.
o
1
m
CO
0
m
o
1
m
0
1 '
0
CO
c^
fN
m
o
-JD
o
X
0
in
r\i
o
en
M
0) Q.
-H 3
•H O
O >-!
43 00
_C CO Q
4-1 [JH Cd
3 C CO
•H fe
X-v Cd
en ^ u
tu x: s:
OJ 3 SS
6 -u ^)
cfl cO • — '
to
CO
r^
ON
m
- T3 CO
QJ fi.
X >^-^
•H ^H [jj
3 OJ "^
"04-1
cr. oi
>i CJ
wax
rt 4j -^,
QJ
QJ O Z
E O £3
co
-------
64
increasing the rate to 10 per year is largely attributable to earlier initia-
tion of standard setting for the group requiring fuel switching because of
the large sources in this group. This is illustrated in Strategy 13 in which
the standard setting rate is set at. 10 per year but no standards for the fuel
switching or RD group are promulgated.
Strategy 14 shows the impact of postponing the revision of an existing
NSPS until all other standards have been set. This strategy results in the
poorest emission picture except for Strategy 8. This indicates the importance
of considering revisions for the large boiler category, which has the largest
Ts-Tn potential.
For the particulate priority analysis, the generalized procedure
that allows alternate relative manpower requirements for standard development
was implemented. The following categories were assumed to require the indi-
cated normalized standard development effort:
Category Normalized Standard Development Effort
Grain Handling (Processing) 2
Grain Handling (Transfer) 0.5
Grain Handling (Screening, Cleaning) 0.5
Grain Handling (Drying) 0.5
Industrial/Commercial Incinerators 1.5
Ferroalloy (Arc Furnace) 2
Secondary Copper (Handling) 1.5
All other categories were assigned a development effort of 1.0.
The categories with greater than unity effort required are large
and diverse and may necessitate multiple standards. On the other hand, the
subsequent Grain Handling subcategories would require reduced standard
development effort because of relevant background information compiled for the
initial processing subcategory. The above deviations from normal development
effort are not intended to be a precise or complete listing, but rather are
included to emphasize that differences in required effort do exist. If esti-
mates of the effort-required parameter were available for all source categories,
the Ts-Tn ordering could be weighed by the inverse of the effort as discussed
in Section 3.3.
The evaluation of achievement attributed to particulate NSPS can be
deceiving if based on total emission mass only as is done in this emalysis.
-------
65
A more precise evaluation would include weighting of the impact of emissions
based on size distribution of the particulates and their chemical composition.
Current control techniques are less efficient for fine particulates and thus
the percent reduction for these smaller particles may be significantly less
than the overall reduction. Differences in chemical composition and their
environmental impacts could be accounted for in a weighting scheme based on
Threshold Limit Values, as was done in a recent EPA Industrial Emissions Research
Laboratory Study.
Particulate emissions from mobile ground level sources, as illustrated
in Appendix A are not a major contributor and were thus not included in this
analysis .
4.3 POLLUTANT PRIORITY ANALYSIS - SULFUR DIOXIDE
The potential for control of SOa emissions through the promulgation of
NSPS is shown in Fig. 4-2. A substantial reduction of 26% in projected 1990
emissions is shown to have already been achieved by the NSPS for SOa currently
in effect (Curve 2); however, this reduction is not large enough to prevent
an increase over estimated 1975 emissions without development and promulgation
of additional standards.
The mobile source emissions of S02 , as computed in Appendix A, are
relatively insignificant and were thus not included in the priority analysis.
Assuming the nominal standard setting rate for SOa sources of 4 NSPS
per year (excluding sources with no demonstrated control technology) and pri-
orities I strictly on Ts-Tn values, the projected emissions would decrease
by over 40% from the 1975 levels (Curve 4), indicating that additional factors
can be included in the prioritization without permitting significant increases
in projected emissions. For the prioritization in view of additional factors,
the sources of SOa emissions were grouped into six categories as shown in Table
4-4a to 4-4f and discussed below.
Existing NSPS (ES)
Sulfur dioxide standards have been proposed or promulgated for three
categories: large steam generators, sulfuric acid plants, and petroleum
refineries (Table 4-4a) . For this analysis, all standards were assumed in
-------
66
60
cc
-
\
CO
o
CO
50
o 40
CO
CO
LU
X
o
0
cc
CO
30
20
STATIONARY SOURCES
I. ONLY STATE STANDARDS
2. ONLY EXISTING NSPS AND STATE STANDARDS
3. ALL NSPS SET IN 1975
4. NSPS SET IN Ts - Tn ORDER, 4 PER YEAR
5. BEGIN FUEL SWITCH IN 1979, STRATEGY 7, 4 PER YEAR
6 FINAL S02 STRATEGY, BEGIN FUEL SWITCH IN 1985,
STRATEGY 9, 4 PER YEAR
7. NO FUEL SWITCH BEFORE 1990, STRATEGY 10,
4 PER YEAR
1975
I960 1985
YEAR
1990
Fig. 4-2. Sulfur Dioxide Emission Projections for Stationary Sources
-------
67
Table 4-4a. Sulfur Dioxide Source Categories with
Existing NSPS (Group ES)
Category
Ts-Tn, 1985
(tons/year)
Ts-Tn Constraint and_
Rank Priority Flags'
Boilers
(>250xl06 Btu/hr)
Sulfuric Acid
Petroleum Refinery
(Process Gas Combustion)
8,351,900
23,100b 17b
N/Af N/Af
5-FS, 7-3, 9-0
3-RD, 7-2,
9-0/2e
First number is the factor considered, second character is the flag.
Definition of flags is given in Section 3.2.2.
Based on the promulgation of a revised NSPS.
"This source has an additional major constraint on the promulgation of a
revised standard (i.e., fuel switching required).
This source has an additional major constraint on the promulgation of a
revised standard (i.e., additional research needed).
a
"Scrubbers are used for control resulting in simultaneous reduction in
particulates (9-0) with an increase in solid waste generation (9-2).
Not applicable, since this source is not a candidate for a revised NSPS;
i.e., the present NSPS is felt to represent the best control technology.
-------
68
Table 4-4b. Sulfur Dioxide Source Categories with No Major
Constraints to Promulgation of NSPS (Group UN)
Category
Primary Copper Smelters
Primary Zinc Smelters
Portland Cement
(Kilns, Clinker Coolers)
Primary Lead Smelters
Wood Pulping
(NSSC)
Wood Pulping
(Sulfite)
Wood Pulping
(Kraft)
Lime
Fiberglass
(Textile Manufacturing)
Fiberglass
(Wool Processing)
Ts-Tn, 1985
(tons/year)
1,740,000
741,000
334,900
177,000
110,000
54,000
10,600
9,400
8,200
2,800
Ts-Tn
Rank
3
5
6
8
11
12
19
22
23
26
Constraint and
Priority Flagsa
6-FL, 7-2, 9-0/2
3-U, 7-0, 9-0
6-FL, 7-2, 9-0/2°
3-U
9-0
3-U, 9-0
Definition of flags is given in Section 3.2.2.
"'NSPS have now been promulgated for these sources.
cScrubbers are used for control resulting in simultaneous reduction in
particulates (9-0) with an increase in solid waste generation (9-2).
-------
69
Table 4-4c. Sulfur Dioxide Source Categories Requiring Control
Systems with Moderate Constraint Rating due to
Energy Consumption (Group MCR)
Category
Mixed Fuel Boilers
(Coal and Refuse)
Explosives
(High)
Secondary Lead
(Reverb Furnace)
Explosives
(Low)
Refinery Fuel Gas
(Sulfur Recovery)
Sulfur Recovery
(Crude Oil and Natural Gas
Production)
Ts-Tn, 1985
(tons/year)
119,000
41,400
29,600
24,500
17,500
9,900
Ts-Tn
Rank
10
13
15
16
18
21
Constraint and
o
Priority Flags
6-FL, 7-2, 9-0/2
3-U, 7-2, 9-0/2b
3-U/HC, 7-2,
9-0/2b
7-2, 9-0/2b
7-2, 9-0
3-U, 7-2, 9-0
Definition of flags is given in Section 3.2.2.
Scrubbers are used for control resulting in simultaneous reduction in
particulates (9-0) with an increase in solid waste generation (9-2).
-------
70
Table 4-4d.
Sulfur Dioxide Source Categories Requiring
Fuel Switching to Achieve NSPS (Group FS)
Category
Boilers
(10-250xl06 Btu/hr)
Boilers
(.3-10xl06 Btu/hr)
Boilers
Ts-Tn, 1985 Ts-Tn Constraint and
(tons/year) Rank Priority Flags
2,566,300 2 7-3, 9-0
1,670,000 4 5-EQ, 7-3,
209,000 7 5-EQ, 7-3,
9-0
9-0
(<.3xl06 Btu/hr)
Stationary Gas Turbines
Electric Utility
Pipeline
Coal Cleaning
(Thermal Drying)
Internal Combustion Engines
(Diesel and Dual Fuel)
Brick and Related Clay Products
Asphalt Batching
122,000
2,700
10,200
6,200
5,500
2,300
9
27
20
24
25
28
5-LE, 7-3
5-LE, 7-3
7-3, 9-0
5-LE/EQ, 7-3,
9-0
7-3, 9-0
7-3
Definition of flags is given in Section 3.2.2.
These sources are treated together.
Table 4-4e. Sulfur Dioxide Source Categories Requiring
Control Technology Research and Development
Prior to NSPS Promulgation (Group RD)
Category
Mixed Fuel Boilers
(Oil and Refuse)
Secondary Lead
(Blast Furnace)
Ts-Tn, 1985
(tons/year)
29,600
1,400
Ts-Tn
Rank
14
29
Constraint and
Priority Flags3
3-U, ,6-FL, 7-2,
9-0/2"
3-HC/U, 7-2,
9-0/2b
Definition of flags is given in Section 3.2.2.
Scrubbers are used for control resulting in simultaneous reduction in
particulates (9-0) with an increase in solid waste generation (9-2)-.
-------
71
Table 4-4f. Sulfur Dioxide Source Categories for Which There
Is No Control Technology Available (Group NC)
Category
Petroleum Refinery
(FCCU)
Primary Aluminum Smelter
Iron and Steel Plant
(Sintering)
Glass Production
(Soda Lime Glass)
Indus trial /Commercial Incinerators
Municipal Incinerators
Byproduct Coke Oven
Orchard Heaters
Glass Production
(Opal Glass)
Hydrofluoric Acid
Mineral Wool
Ts-Tn, 1985
(tons/year)a
259,000
218,000
53,600
35,600
32,870
30,200
900
680
510
432
30
Ts-Tn
Rank
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Constraint and.
Priority Flags
9-0
7-2
3-U, 6-FL, 7-2,
9-0
3-U
6-LO
7-2
5-EQ
3-U
o
Based on an assumed value of En = 0.
Definition of flags is given in Section 3.2.2.
-------
72
effect in 1975. Revised standards for each of these groups was determined to
be either not feasible, to require additional research and development, or to
require fuel switching. Since these constraints are more severe than the
procedural constraint of revising a standard, these categories were also
treated with the NC, RD, or FS groups discussed below.
In addition to these existing SOa NSPS, standards have recently been
promulgated for the primary copper, primary zinc and primary lead smelters.
In a manner similar to that for particulates, these proposed standards were
ignored in the TRC data collection because of the uncertainty of the final
standard level. They are likewise ignored here. All of these sources are
in the Unconstrained Group discussed below.
Unconstrained (UN)
Based on available information, categories in Table 4-4b have no
significant constraints that would inhibit application of control technology
required to meet NSPS. The indicated reduction in S02 emissions for the
Portland cement and lime categories can be achieved through design changes
curtailing fuel consumption in the drying process. The resultant energy
conservation is an added incentive for NSPS promulgation for these categories.
The wood pulping categories achieve reduction in emissions by conversion to
alternate chemical processes. Conversion to electric furnaces in fiberglass
manufacturing is a demonstrated technology and thus eliminates the need for
fossil-fueled furnaces, which are the primary source of SOa emissions in
this industry.
The recently promulgated standards for the primary copper zinc, and
lead smelters is not considered in these data.
Moderate Constraint Rating (MCR)
Categories in this group (Table 4-4c) generally require the use of
scrubbers that are moderate consumers of energy. Scrubbing also has the
disadvantage of producing solid/liquid wastes, although this environmental
impact is partially offset by the benefit from simultaneous removal of parti-
culates from the gas stream.
-------
73
Fuel Switching Required (FS)
Included in this group (Table 4-4d) are all S02 source categories
that could attain further SOa emission control primarily through switching
to natural gas or other fuels with low sulfur content. The availability of
these fuels presents a severe constraint on promulgation of NSPS. The four
classes of boilers in this group (including a revised standard for boilers
>250xl06 Btu/hr from the existing standards group on Table 4-4a) received the
highest ranking of all categories based on Ts-Tn alone, which points out the
importance of this group. For the smaller individual sources, cleaning of
the stack gas with scrubbers may be technologically feasible but would be
very costly without additional research and development. Further control
beyond existing NSPS may be possible for the largest class of boilers in the
near future without fuel switching as experience in scrubber operation is
accumulated. Appreciable control could be obtained by selective application
of fuel switching to certain facilities within a category in critical areas,
but this option is not provided by Section 111 of the Clean Air Act.
The stationary gas turbine engines are treated together with the
following normalized standard development effort:
Category Normalized Standard Development Effort
Stationary Gas Turbine
Electric Utility 0.5
Gas Pipeline 0.5
Research and Development Required (RD)
For this group of categories (Table 4-4e) stack gas scrubbing is the
most viable technique for obtaining additional emission control; however,
further improvements in technology are required in order for the reduction
below present levels to be significant without excessive cost to the industry.
No Demonstrated Control Technology Available (NC)
The categories in this group (Table 4-4f) are not expected to be
capable of achieving further emission control at a reasonable cost in the
1975-1990 time period. Included are categories for which there is no demon-
strated control technology and the Ts-Tn values that are given assume zero
-------
74
emissions on new sources in order to show the impact of this lack of tech-
nology; the cumulative effect is about 632,000 tons/year (Ts-Tn, 1985).
The impact of prioritization of S02 source categories on the basis
of the above groupings is summarized in Table 4-5. In all evaluations, NSPS
for the NC group were assumed not to be promulgated in the period 1975-1990.
Categories requiring additional control research (RD group) were
assumed to have lowest priority. Without changing other priorities, this
perturbation (Strategy 5) resulted in a 10.7% increase in 1985 SOa emissions
(compared to Strategy 4). (With the nominal standard setting rate of 4 S02
NSPS per year, standard setting for this low priority group is initiated in
1981.)
For the next perturbation from Ts-Tn ranking, the categories requiring
fuel switching were moved to lower priority (Strategy 6) with a resultant
major increase of 15% in 1990 emissions as compared to standard setting based
only on Ts-Tn rank. Furthermore, annual emissions increase to a maximum of
4% over 1975 emissions, the maximum occurring in 1979 just before standard
setting for the FS group is initiated.
Maintaining this prioritization in Strategy 7 with the exception
that the MCR group categories (requiring control systems with moderate
energy consumption) are ranked just below the unconstrained group results
in approximately 0.1% increase in 1985 SOa emissions over Strategy 6 levels.
Because of this small increase, the lowering of priority for this group can
be maintained.
The above preliminary analysis clearly demonstrates the dilemma of
the SOa standard setting prioritization. The setting of standards for boilers
and other large consumers of fossil fuels is a dominant factor in the mainte-
nance of 1975 emission levels using Section 111 mechanisms only, but the setting
of these standards requires use of low-sulfur fuel, which is in low supply or
alternatively requires the use of significantly advanced SOa stack gas scrubbers.
The effect of delaying the FS group standards is further illustrated by curves
5, 6, and 7 in Fig. 4-2. The curves in this figure are based on 4 standards
per year and ranking of groups as before, but with the addition of a further
delay in initiation of standard setting for the third and fourth groups. The
-------
75
3
I
0
>i
60
0)
tS
S-i
CO
4J
•H
0
•H
S-i
OJ
•H
^
0
*H
p
3
H
CO
L^
^
OJ
iH
H
o /-^
QJ ^-"
•H
0 0
•H -H
4-1 CO
W fi
Ol r-.
O 00 cr.
o> co
•-« X 0
CJ 0
S-i
B-i! "-W
CO x-s
0 O.
to
•H O
w ^
m
oo£
.c 0
U 0
V4
m
c?
^ CO ^
o ex
•H 4-1
•H O
0 -H
O ^
-H
8 cu
W 4-J /—*
nJ ?~i
0 Pi PH
3 4-J
0
•H
4J
cr\ o r^ ^ o
vo in CM ^r oo co
>, co m v* 3
i— ( r-^ o O
C tO O"\ M
O CX, — ( C CX 00
C/l H 3
CO 2 C 1 O Q ^^
*U >H CO U p£j Q
VJ 00 H 00 05
CO C 4-1 ^v ---,
id -H -, C/l 4J 4J
Cfl r-H M p-i CO CO
u c M tn o o
_: ^ ^ s; ^ *
\i> m
CN i— (
i I i
r- --a- oo
OO OO O
00 CO ON
i— < CN O
V i +
•—* oo oo
PH 0)
CO Xl
00 CO
C 0
-H
4-J 4-1
-------
76
peak emissions reach a maximum in 1990 or 122% of 1975 emissions (37.83
million tons/year) if the standards for these groups are not set at. all in
the 1975-1990 period (Strategy 10).
Strategy 9 is selected as the prioritization procedure for SOa (Curve
6 on Fig. 4-2). It is felt that 1985 is the earliest that clean fuels (e.g.,
low sulfur coal, gasified coal, etc.) or advanced flue gas desulfurization
technology will be in adequate supply to warrant consideration of the NSPS
that would require fuel switching or advanced technology. This may, in fact,
prove to be optimistic and delays in the NSPS for these sources may have to be
postponed until 1990 or later.
4.4 POLLUTANT PRIORITY ANALYSIS - NITROGEN OXIDES
Control of nitrogen oxide (NOX) emissions is affected by mobile and
stationary source influences. Figure 4-3 is the set of limit curves for sta-
tionary sources only. It is obvioxis that even under maximum NSPS control im-
pact through the setting of all possible standards immediately (Curve 3), emis-
sions still increase substantially over the 1975-1990 period. The 1990 emissions
are 44.4% higher than the 1975 emissions, which is an increase of 5.0 million
tons/year. This is a little less than half of the emission increase (Curve 1),
which would result from not setting any NSPS.
NOX standards have been promulgated for only two source categories to
date: large boilers (> 250 x 10 Btu/hr) and nitric acid plants. Curve 2 of
the figure shows that these standards represent only a small portion of the
NSPS control potential. In 1990, these two standards provide only a 4% reduc-
tion in emissions from the unregulated case.
Curve 4 shows the impact of setting the NSPS for NOV in strict Ts-Tn
A.
order at the rate of 4 standards per year. The source categories for which
there is no control technology available have been excluded. As with the other
pollutants, this does not result in a substantial change from the maximum im-
pact case of Curve 3, since the large sources are controlled very quickly.
Curve 5 gives the final prioritization and will be discussed later.
Figure 4-4 shows the combined emission rates of mobile and stationary
sources. The mobile source calculations assume the most stringent NOX emission
standards for automobiles to go into effect in 1978. Details of the
-------
77
40
o= 30
CO
I
o
CO
1
CO
g
o
cc
10
0,
STATIONARY SOURCES
I. ONLY STATE STANDARDS
2. ONLY EXISTING NSPS AND STATE STANDARDS
3. ALL NSPS SET IN 1975
4. NSPS SET IN Ts-Tn ORDER, 4 PER YEAR
5. FINAL NOX PRIORITY, STRATEGY 8, 4 PER YEAR
1975
1980
1985
1990
YEAR
Fig. 4-3. Nitrogen Oxide Emission Projections for Stationary Sources
-------
78
40
g 30
LU
CO
O
co
1 20
CO
x
O
o
cc.
10
0
STATIONARY AND MOBILE SOURCES
I. ONLY STATE STANDARDS
2. ONLY EXISTING NSPS AND STATE STANDARDS
3. ALL NSPS SET IN 1975
4. NSPS SET IN Ts-Tn ORDER, 4 PER YEAR
5. FINAL NOX PRIORITY, STRATEGY 8, 4 PER YEAR
1975
1980
1985
1990
YEAR
Fig. 4-4. Nitrogen Oxide Emission Projections for Stationary and Mobile Sources
-------
79
calculation are given in Appendix A. The results on the figure are especially
significant in light of the fact that one of the rationales used to argue for
relaxation of the stringent emission controls on motor vehicles was that the
same emission reductions could be achieved through the imposition of stricter
stationary source controls. These data show that the growth characteristics
of stationary sources and the availability of emission control technology
are such that total emission rates will increase through 1990 despite the
most rapid application of NSPS. Stated differently, stationary source NOX
emissions cannot be reduced in the 1975-1990 time frame even with the strictest
application of NSPS and therefore cannot compensate for mobile source emission
increases. Retrofit of existing sources has not been included in this considera-
tion.
While the indications are that the imposition of source constraints
on the standard setting procedure will compound an already difficult situa-
tion, some of the constraints are unavoidable and their effect will be
evaluated here. Using the source screening methodology, the nitrogen oxide
categories were separated into six groups as shown on Tables 4-6a to 4-6f.
Existing NSPS (ES)
As shown on Table 4-6a, this group contains the large boilers
(>250 x 106 Btu/hr) and nitric acid plants. As with the other pollutants,
the NSPS are assumed to be in effect in 1975. Based on the TRC review, these
sources are also candidates for revised NSPS. For both the large boilers
and the nitric acid plants, the setting of a revised NSPS is not constrained
by any of the factors considered here. The available information indicates
that the boilers could achieve additional NO emission reductions through
the application of a combination of design modifications (e.g., off-stoichio-
metric combustion, flue gas recirculation, tangential firing, etc.) instead
of a single modification that could be used to meet the current standard.
Some nitric acid plants have already demonstrated emission levels 33% below
the current standard and, therefore, a revised standard is not inconceivable.
The only restriction is the five-year time lag between original and revised
standards as discussed previously.
-------
80
Table 4-6a. Nitrogen Oxide Source Categories
with Existing NSPS (Group ES)
Category
Ts-Tn, 1985,
(tons/year)'
Ts-Tn Constraint and.
Rank Priority Flags
Boilers
(>250xl06 Btu/hr)
Nitric Acid
(Air Oxidation)
1,040,900
8,100
17
7-2, 8-2
Based on the promulgation of a revised NSPS.
First number is the factor considered, second character is the flag.
Definition of flags is given in Section 3.2.2.
Table 4-6b. Nitrogen Oxide Source Categories with No Major
Constraints tc Promulgation of NSPS (Group UN)
Category
Stationary Gas Turbines
Electric Utility
Gas Pipeline
Boilers
(10-250xl06 Btu/hr)
Explosives
(High)
Mixed Fuel Boilers
Coal and Refuse
Oil and Refuse
Cement Plants
(Kilns and Clinker Coolers)
Municipal Incinerators
Adipic Acid
DMT/TPA
(Nitric Acid Oxidation)
Fiberglass
(Wool Processing)
Ts-Tn, 1985
(tons/year)
1,060,000
158,000
553,884
229,000
156,000
2,200
25,100
14,700
3,900
2,790
880
Ts-Tn Constraint and
r\
Rank Priority Flags
1
6
4
5
7 5-LE, 6-FL/LO
22 5-LE, 6-FL/LO
11 7-0, 9-0
15 6-LO
20
21 5-LE, 6-FL
25
Definition of flags is given in Section 3.2.2.
These sources are treated together.
-------
81
Table 4-6c. Nitrogen Oxide Source Categories for Which an
Equipment Standard is Preferable (Group EQ)
Category
Internal Combustion Engines
(Spark Ignition)
Internal Combustion Engines
(Diesel and Dual Fuel)
Boilers
(0.3-10xl06 Btu/hr)
Ts-Tn, 1985
(tons/year)
882,000
140,000
56,200
Ts-Tn
Rank
3
8
10
Constraint and
Priority Flags
3-HC, 5-LE
3-HC, 5-LE
5-FS, 7-3
Definition of flags is given in Section 3.2.2.
Table 4-6d. Nitrogen Oxide Source Categories with Moderate
Constraint Rating Due to Increased Energy
Consumption or Scarce Resource Utilization
(Group MCR)
Category
Industrial/Commercial Incinerators
Explosives
(Low)
Auto Body Incinerators
Ts-Tn, 1985 Ts-Tn
(tons/year) Rank
16,850 13
15,800 14
30 31
Constraint and
o
Priority Flags
7-2, 10-OC
8-2
7-2, 8-0
Definition of flags is given in Section 3.2.2.
-------
82
Table 4-6e. Nitrogen Oxide Source Categories Requiring
Control Technology Research and Development
Prior to NSPS Promulgation (Group RD)
Category
Boilers
(<0.3xl06 Btu/hr)
Glass Manufacture
(Soda-Lime)
Petroleum Refinery
(Process Gas Combustion)
Fiberglass
(Textile Processing)
Lime Processing
Brick and Related Clay Products
Ceramic Clay
Nitrate Fertilizer
Byproduct Coke Ovens
Pathological Incinerators
Glass Manufacture
(Opal)
Mineral Wool
Coffee Roasting
Ts-Tn, 1985
(tons/year)
80,000
17,100
9,100
6,300
5,600
2,000
1,000
720
720
380
230
160
15
Ts-Tn Constraint and
ft
Rank Priority Flags
9 5-EQ
12
16 6-FL
18 9-0
19
23
24
26
27
28 5-EQ
29
30
32
Definition of flags is given in Section 3.2.2.
-------
83
Table 4-6f. Nitrogen Oxide Source Categories for Which There
Is No Control Technology Available (Group NC)
Category
Open Burning
Sugar Cane
(Field Burning)
Steel Foundries
Secondary Lead
(Reverberatory Furnace)
Secondary Zinc
(Distillation)
Secondary Lead
(Blast Furnace)
Secondary Zinc
(Sweating)
Magnesium Smelting
Ts-Tn, 1985
(tons /year)
306,200
11,200
2,700
140
9
5
5
1
Ts-Tn
Rank
N/A
N/A
N/A
N/A
N/A
N/A
N/A
N/A
Constraint and.
Priority Flags
4-NF, 5-LE, 9-0
4-NF, 5-LE, 9-0
Based on an assumed value of En = 0.
Definition of flags is given in Section 3.2.2.
-------
84
Unconstrained (UN)
The sources in this group on Table 4-6b have no major constraints
to hinder the application of NSPS. The electric utility and pipeline gas
turbines are treated together as are the mixed fuel (refuse/fossil fuel)
boilers. The normalized standard development effort is as follows:
Category Normalized Standard Development Effort
Stationary Gas Turbines
Electric Utility 0.5
Gas Pipeline 0.5
Mixed Fuel Boilers
Coal and Refuse 0.5
Oil and Refuse 0.5
The mixed fuel boilers and municipal incinerators are flagged as
being location sensitive because of their siting in or near urban areas.
Control of cement plant kilns and clinker coolers results from a process
redesign that reduces fuel consumption; hence, the energy conservation
and other pollutant control flags.
Some legal considerations arise for the mixed fuel boilers and
DMT/TPA plants. For the boilers, there is some overlap in the NSPS for
incinerators and boilers with this category. A precise definition of a
mixed fuel boiler as compared to the other sources is necessary. For DMT/
TPA plants, the TRC review indicated that the emission-producing processes
may be phased out by all but one corporation. The standard would then
result in the regulation of only one company.
Equipment Standard Preferrable (EQ)
Internal combustion engines, both spark ignition and diesel and
dual fuel, are included in this group because of the large number of indi-
vidual sources that would make compliance testing extremely difficult. An
alternative to field tests would be production line tests, either selective
sampling or 100% sampling, but this too would present enforceability complica-
tions. In addition, control of these sources through design modifications
is expected to result in substantial cost penalties, estimated as high as
20-30% increase in capital expenditures.
-------
85
The boilers in the 0.3-10 x 106 Btu/hr range are included in this
group because fuel switching is the most cost-effective control method. The
large number of sources may make a fuel standard more readily enforceable
than an emission limit. At the same time, a fuel standard would have signifi-
cant energy use implications as indicated by the rating of 3.
Moderate Constraint Rating (MCR)
Control of industrial/commercia,! incinerators is achieved with medium
energy wet scrubbers, hence the rating of 2 on factor 7. Another considera-
tion may come into play for these sources; the wide range in source size
(50-4000 Ib/hr charging rate) may make a subdivision of the category by unit
size desirable.
For low explosives, control is achieved through catalytic decomposi-
tion, which requires the use of rare metals. For auto body incinerators, an
afterburner is used for control of all pollutants; this is a high-energy-
consuming device but the effect is minimized since the gas flow volumes are
small.
From the above considerations it is evident that these constraints
are not very restrictive and could be relaxed with minimum impacts.
Research and Development Required (RD)
The sources in this category have no control technology currently in
widespread use although some system is either under development or is a
carryover from similar industries. In most cases, the required research
would have to be conducted in combustion and flame kinetics since the emis-
sions result primarily from fuel combustion. Combustor design to minimize
NOX emissions would likely be the most readily adaptable control technique.
For the small boilers (<.3 x 106 Btu/hr) and the pathological incinera-
tors, an equipment standard would be preferrable to an emission limit due to
the large number of sources. For fiberglass textile processing the control
technique is a switch to electric furnaces, which results in control of all
pollutants. Research is needed to determine the applicability of the
electric furnace to this process.
-------
86
No Demonstrated Control Technology Available (NC)
For open burning and sugar cane field burning, the only control
method is to prohibit the practice. The remaining source categories are
metallurgical processes. With the exception of steel foundries, the com-
bustion of fuel is carefully controlled as a part of process requirements.
Modification of flame temperatures to achieve NOX control would not. be possi-
ble without substantially affecting the quality of the final product. In
addition, the Ts-Tn values of these sources are too low to warrant extensive
control program development.
Table 4-7 shows the effect of imposing the source constraints on the
standard-setting priority. The first four strategies correspond to the curves
of Fig. 4-3 with Strategy 3 serving as the baseline for the efficiency ratio
calculation.
Strategy 5 sets the standards for the unconstrained group first
in Ts-Tn order. The equipment standard group is considered to have a lesser
constraint than the MCR group. This ordering is further reinforced by the
fact that the EQ group has a very large emission reduction potential while
the MCR group does not. The sources requiring research and development are
considered last, while those with no control technology available are not
regulated at all. At the rate of 4 NOX standards per year, the RD group is
reached in 1979. Revised standards for the large boilers and nitric acid
plants are set in 1980. The imposition of these constraints results in 1990
emissions increasing by 52.9% over 1975 values, and the efficiency ratio
dropping off to 86.4% as compared to 94.4% for the strict Ts-Tn order. Strategy
6 shows that the efficiency can be increased to 89.5% through an acceleration of
the standard setting pace to 10 per year, but the RD group is now reached in
1977, which may be too soon for the necessary research to be completed.
Strategy 7 shows that, by relaxing the EQ constraint, a significant
improvement in emission reduction can be realized. This is being primarily
influenced by the setting of standards for the internal combustion engines,
which have very high Ts-Tn potential. Strategy 8 shows that relaxing this
constraint on these sources only, while maintaining it on the small boilers
(0.3-10 x 106 Btu/hr), costs virtually nothing in emission reduction potential.
The clear indication is that the control of the internal combustion engines
should be made a matter of high priority for NOX control.
-------
87
T)
>-,
M
§
CO
t^
60
0)
4J
*$
to
4J
CO
>%
4J
•H
to
O
•H
S-i
f^
QJ
T3
•H
X
0
C
0)
60
O
to
H-J
•H
jg;
r^
1
vf
0)
, — I
rH
OJ
H
>i*0
U s-~*
QJ ^
•rH
0 0
•H -H
4H CO
W Pi
LO
QJ r^
o oo o>
CT> 0 — i
CTs CO
-t J= E
0 0
}-l
&*? 4H
CO x— ^
C t^
o a
•i
o a,
•H 4-1
CO
COtC
•gs
w ^
(D
4-1
J-i Pi )-«
CO >^
13 00 --~
C C •
co -H o
4-1 4-1 C
cn -w '*-'
QJ
UD
U
X)
>%
00
OJ
4-1
CO
!-l
4_)
w
X
4_l
•H
kJ
o
•H
S-i
P-I
1
r-
o
1
CO
>£>
+
o
vd~
CM
OO
r--.
+
CO
O
Qi
>>
C
O
to
-a
jj
co
T3
C
cO
4_J
CO
0)
4-1
CO
4-J
en
^
o
OO
U3
O
+
•>
rH
q
o
CM
O-3~^ in oo r~- O m
o--d- ro r-- oo -
^D^or--- vc vo ^D r^- r^-
^ i— i t— i r-4 \o ^o a> m
unCT\-••
, — i
C
o
cn
QJ
C
-H
00
C
01
c
o
•H
4-1
CO
d
J3
E
o
o
c -o
VJ C1J
QJ CO
4-1 rH
co cn c >
CX CX H QJ
d d ^
(-1 O O l-j — '
V ^ S-, O
TJ t>0 oo MH cn cn
m j-i AJ p, w
r~- O 4J^~v 4-i^-N 4-1 4-i^-N C tn ^-^
CT- CQCQC CQ-H 2:Q
— i C T-* pi -rH pi -H -H pi CO Pi
H tO^^ ro "^ cO •— v cO~~~- >-" "O^
C 1 Jjpi l-i Pi ^P kiQi 4-J x— v QJOi
H co 4JU 4-JU 4-i 2 -u U COQ cncj
H cos cnS cn~^ coS CPS ---i S
4-J C\ C "^ CPi C ^^ O\ > "^
QJ C OO1 OCT OU OCX UO1 OJO1
CO -r-l ObJ UW CJS UljJ UJ l-iW
oo 4-i
l-i O
o >
u^ C
CO
13 cn
cO
T3 J-J
C C
CO *H
4-J ro
W ^4
X 4-1
i— t QJ cn
C "O C
o do
•—• u
CO O
, D cn
14 4-J
03 1C n3
d rJ
o 4j cn
•H CO CO
-L-I QJ
cO — i <-<
cn < d
cO JD
CO C 4_J
-------
88
Strategy 9 shows the effect of relaxing the moderate constraint
rating considerations while maintaining the other constraints. The 1990
efficiency ratio drops to 85.0% or 1.4% lower than for the full constraint
approach of Strategy 5. This is a result of the delaying of standards for
the large sources in the EQ group to control the smaller sources in the MCR
group. Given the difficulties with controlling NOX emissions, this is an
unacceptable approach.
For all of the strategies thus far, the revised NSPS for the large
boilers and nitric acid plants are set in 1980. Strategy 10 shows the impact
of delaying the setting of a revised standard until all others have been
set, including the KD group. The standards are set in 1982 at the 4 per
year rate. It is evident that this results in the worst 1990 efficiency
ratio and the largest emission increases except for Strategies 1 and 2.
The implementation of such a strategy is clearly not advisable and the setting
of a revised standard should not be delayed indefinitely.
From the above analysis, Strategy 8 appears to be the most effective
in reducing emissions while considering the constraints affecting each
source. Its impact on emissions is shown by Curve 5 on Figs. 4-3 and 4.4
4.5 POLLUTANT PRIORITY ANALYSIS - HYDROCARBONS
The control of hydrocarbon emissions is a multifaceted problem
because of the combined influence of mobile and stationary sources. Figure
4-5 indicates the potential for controlling stationary sources via the NSPS
mechanism. Curve 1 indicates the increase in stationary source hydrocarbon
emissions without the application of any NSPS and with only SIP regulations.
Emissions in 1990 are double the 1975 values. To date, the only hydrocarbon
standards that have been promulgated are for petroleum storage vessels and
Curve 2 indicates their impact on emissions. It is evident that there is a
great deal of additional control potential since the storage vessel NSPS
results in only a 6% decrease in 1990 emissions.
The maximum control potential achieved by the setting of standards
for all industries immediately is shown by Curve 3. Excluded from the standard
setting procedure are source categories for which there is no control tech-
nology available. The 1990 emissions are reduced to 17% less than 1975 emis-
sions and to 58% less than the SIP--controlled case. The indication is that
-------
89
40
cc
LU
CO
Z
O
I—
sD
O
co~
30
2 20
CO
CO
o
GO
CC
-------
90
even the most drastic of stationary source controls will provide little
more than a holding action on hydrocarbon emissions relative to their current
levels but will provide substantial control over the unregulated case.
Curve 4 on the figure indicates the effect of a nominal standard-
setting rate (6 hydrocarbon standards per year) on emissions. The priority
is based strictly on the Ts-Tn rank and shows an 8% reduction in 1990
emissions over 1975 values, which is only slightly less than the maximum
impact case. The relatively small difference betxreen setting the standards
at 6 per year versus setting them all at once is a result of the dominance
of several large source categories at the top of the Ts-Tn list. The first
six sources plus the petroleum storage vessels account for more than half
of the Ts-Tn emission reductions based on the TRC calculations for 1985. Once
the standards are set for these industries, the remaining will have only a
small effect on emission rates. In terms of total emissions, the differences
between setting all the standards at once and setting 6 standards per year
is about 1.27 million tons/year in 1990.
Curve 5 of the figure represents the final priority strategy, which
will be discussed later.
Figure 4-6 shows the effect of the control of stationary sources
through NSPS and the control of motor vehicle emissions through the Mobile
Source Pollution Control Program (MSPCP). The first four curves are for the
same four standard-setting strategies as considered above for stationary
sources alone. The details of the motor vehicle emissior computations are
given in Appendix A. Curve 1 shows that even without any controls on sta-
tionary sources, hydrocarbon emissions will decrease as a result of the
MSPCP and reach a minimum in about. 1980. Beyond that time, the growth in
motor vehicle traffic volume plus the growth in stationary sources will over-
take the gains made by the motor vehicle controls and will result in a net
increase in emissions in 1990 of about 19%. As before, the existing NSPS
for petroleum storage vessels (Curve 2) do not alter the trend very much.
The effect of promulgating additional NSPS are shown on Curves 3 and
4. The NSPS program is capable of counteracting the growth trends and bringing
about an emission reduction in 1990 of 41% over 1975 levels (37% for the 6
standards per year pace) . This is equivalent to preventing over 16 million
tons/year in 1990 compared to the uncontrolled case. Even with this large
-------
91
40
cc
-
CO
o
30
CO
2 20
CO
CO
O
OQ
cc
O
oc.
O
10
0
STATIONARY AND MOBILE SOURCES
I. ONLY STATE STANDARDS
2. ONLY EXISTING NSPS AND STATE STANDARDS
3. ALL NSPS SET IN 1975
4. NSPS SET IN Ts - Tn ORDER, 6 PER YEAR
5. FINAL HC PRIORITY, STRATEGY II, 6 PER YEAR
I
1975
I960 1985
YEAR
1990
Fig. 4-6. Hydrocarbon Emission Projections for Stationary and Motile Sources
-------
92
impact, Curves 3 and 4 show a definite leveling off, indicating that, beyond
1990, emissions will again begin to increase if no further controls are
placed on motor vehicles. Curve 5 is again the final priority strategy.
Prior to beginning the analysis of the impact of alternative
standard-setting priorities based on individual source constraints,, it can
be noted that there is some potential for revising the prioritization and
still maintaining at least no increase in hydrocarbon emissions in the time
frame considered. This is only a Limited capability, however, since the
maximum impact(case yields only a L7% decrease from 1975 emissions in 1990.
Based on the source screening methodology described in Sec. 3.0,
the hydrocarbon sources were separated into seven groups. These are indi-
cated on Table 4-8a to 4-8g.
Existing NSPS (ES)
This group on Table 4-8a consists of all source categories for which
there is an existing standard. For hydrocarbons, this includes only petroleum
storage vessels and is limited to the storage of liquids with a vapor pressure
greater than 78 mm of Hg and less than 570 mm of Hg and to storage tanks of
greater than 40,000 gallon capacity. For source categories included in the
TRC data, it is assumed that the standard applies to the breathing and working
losses associated with the storage of crude oil, gasoline, jet fuel, naptha,
and aviation gas. It is not assumed to apply to kerosene and distillate oil
because of their low vapor pressure. (Actually, jet fuel and naptha are only
marginally included in the minimum requirement.) Emissions from petroleum
transfer are not included in this category since these most frequently
involve mobile tanks and stationary facilities that are smaller than the
40,000 gallon size cutoff. This source category is not considered for a
revised standard since the existing NSPS already specifies best available
control technology.
In addition to this category, regulation has been proposed for vehicle
refueling. This regulation was not treated as an existing NSPS here.
Unconstrained (UN)
This group on Table 4-8b includes all source categories for which
there are no constraints to the application of NSPS. In this group, the
-------
93
Table 4-8a. Hydrocarbon Source Categories with
Existing NSPS (Group ES)
Category
Ts-Tn, 1985
(tons/year)
Ts-Tn Constraint and
Rank Priority Flags
Petroleum Storage
Aviation Gas-Breathing
Aviation Gas-Working
Crude Oil-Breathing
Crude Oil-Working
Gasoline-Breathing
Gasoline-Working
Jet Fuel-Breathing
Jet Fuel-Working
Special Naphtha-Breathing
Special Naphtha-Working
N/AC
N/AC
Not applicable, since these sources are not candidates for revised NSPS;
i.e., the present NSPS is felt to represent the best control technology.
-------
94
Table 4-8b. Hydrocarbon Source Categories with No Major Constraints
to Promulgation of NSPS (Group UN)
Category
Ammonia
(Methanator Plant)
Ammonia
(Regenerator and CO Absorber)
Degreasing
Carbon Black
(Furnace Process)
Charcoal
Graphic Arts
(Gravure)
Beer
Vegetable Oil
Petroleum Storage
Distillate Oil-Breathing
Kerosene-Breathing
Synthetic Resin
(Acrylic)
Synthetic Fibers
(Nylon)
Whiskey
Synthetic Fibers
(Acetate)
Textile Processing
(Heat Setting/Finishing)
Textile Processing
(Carpet Manufacture)
Styrene-Butadene Rubber
Lead Acid Battery Plant
Synthetic Resin
(Alkyd)
T extile Processing
(Texturizing)
Ts-Tn, 1985
(tons/year)
750,000
750,000
527,000
318,000
143,000
128,000
43,000
37,400
31,700
1,600
31,000
11,300
1,540
1,000
850
590
240
210
187
170
Ts-Tn Constraint and
O
Rank Priority Flags
2 7-0
3 7-0
4
9 7_of 9-0
13 7-0
14
27 7-0
30
35 5-EQ,C 7-0
57
36
45
58
62
64
65
67
69
70
73
o
Definition of flags is given in Section 3.2.2.
These sources are treated together.
'Despite the fact that these sources carry an EQ flag, they are included in the
UN group, since an equipment NSPS already exists for storage of other liquids.
-------
95
Table 4-8c. Hydrocarbon Source Categories for Which an
Equipment Standard is Preferable (Group EQ)
Category
Industrial Surface Coating
Petroleum Refinery
(Miscellaneous Point Sources)
Petroleum Refueling
Drycleaning
Petroleum Service Stations
Petroleum Transfer
Gasoline
Crude Oil
Jet Fuel
Aviation Gas
Special Naphtha
Direct Firing of Meats
Internal Combustion Engines
(Diesel and Dual Fuel)
Pathological Incinerators
Ts-Tn, 1985
(tons/year)
2,560,000
505,000
384,000
204,000
175,000
32,400
11,300
4,200
990
130
30,300
2,500
60
Ts-Tn
Rank
1
5
8
10
12
34
46
51
63
74
39
52
75
Constraint and
0
Priority Flags
6-WS
4-NF, 6-FL, 7-0,
10-0
4-NF, 5-LE, 6-WS,
7-0
6-WS
4-NF, 6-WS, 7-0
4-NF, 6-WS, 7-0
6-WS, 9-0
5-LE, 6-WS
5-LE, 6-WS, 7-2d
Definition of flags is given in Section 3.2.2.
A regulation has been proposed for this source.
-»
"These sources are treated together.
Despite the fact that the afterburners require additional fuel consumption,
the nature of the waste may bring public demand for control; therefore,
these sources are included here instead of further down the priority list.
-------
96
Table 4-8d. Hydrocarbon Source Categories with
Uncertain Energy Impact due to Un-
known Gas Flammability (Group UGF)
Category
Graphic Arts
(Flexography)
Petroleum Refinery
(Vacuum Distillation)
Graphic Arts
(Letter Press)
Graphic Arts
(Lithography)
Graphic Arts
(Metal Decorating)
Cast Iron Foundry
(Core Oven)
Paint
Polyethylene
(Low Density)
Maleic Anhydride
(Benzene Oxidation)
Polyethylene
(High Density)
Varnish
Phthalic Anhydride
(0-xylene)
Polyvinyl Chloride
Printing Ink
Wood Processing
(Plywood)
Deep Fat Frying
Polystyrene
Ts-Tn, 1985
(tons/year)
115,000
83,800
77,500
73,900
69,100
63,700
60,000
30,900
30,700
26,300
18,100
17,900
12,000
6,900
6,200
5,300
4,700
Ts-Tn Constraint and
o
Rank Priority Flags
16
18 6-FL
20
21
22
24
26
37
38
40
42
43 6-FL
44
47
48
49 9-0
50
-------
97
Table 4-8d. (Contd.)
Category
Synthetic Resins
(Phenolic)
Asphalt Roofing
(Blowing)
Mineral Wool
Synthetic Resins
(Urea-Melamine)
Fiberglass
(Wool Processing)
Synthetic Resins
(ABS-SAN)
Polypropylene
Coffee Roasting
Auto Body Incinerators
Secondary Zinc
(Sweat Furnace)
Meat Smokehouses
Secondary Magnesium Smelting
Ts-Tn, 1985
(tons/year)
2,480
2,400
2,000
1,806
1,400
1,127
1,100
290
230
180
170
10
Ts-Tn Constraint and
a
Rank Priority Flags
53
54 6-WS
55
56
59
60
61 6-FL
66
68
71
72 9-0
76
Definition of flags is given in Section 3.2.2.
-------
98
Table 4-8e. Hydrocarbon Source Categories with Moderate
Constraint Rating due to Increased Energy
Consumption or Scarce Resource Utilization
(Group MCR)
Category
Ethylene Oxide
Acrylonitrile
Formaldehyde
Ethylene Bichloride
Ts-Tn, 1985
(tons/year)
434,000
65,400
63,300
36,200
Ts-Tn
Rank
7
23
25
32
Constraint and
o
Priority Flags
8-2
7-2
7-2
3-HC, 6-FL,
7-2, 8-2
Definition of flags is given in Section 3.2.2.
-------
99
Table 4-8f.
Hydrocarbon Source Categories Requiring
Control Technology Research and Develop'-
ment Prior to NSPS Promulgation (Group RD)
Category
Internal Combustion Engines
(Spark Ignition)
Boilers
(>250xl06 Btu/hr)
Boilers
(0.3-10xl06 Btu/hr)
Boilers
(10-250xl06 Btu/hr)
By-product Coke Ovens
Auto Assembly Plants
Indus trial /Commercial
Incinerators
Boilers
(<0.3xl05 Btu/hr)
Asphalt Batching
Municipal Incinerators
• Ts-Tn, 1985
(tons/year)
499,000
186,000
124,000
91,300
77,900
42,900
39,800
37,200
33,700
20,900
Ts-Tn
Rank
6
11
15
17
19
28
29
31
33
41
Constraint and
Priority Flags
5-LE/EQ, 6-WS
9-2
5-EQ, 6-WS, 9-2
9-2
10-OC
5-EQ, 6-WS, 9-2
6-WS
6-LO, 9-2
Definition of flags is given in Section 3.2.2.
-------
100
Table 4-8g. Hydrocarbon Source Categories for Which There
Is No Control Technology Available (Group NC)
Category
Open Burning
Orchard Heaters
Sugar Cane
(Field Burning)
Wood Pulping
(Kraft Process)
Petroleum Refinery
(Process Gas Combustion)
Brick and Related Clay Products
Ts-Tn, 1985,
(tons /year)
3,062,500
168,000
112,000
3,300
2,600
620
Ts-Tn
Rank
N/A
N/A
N/A
N/A
N/A
N/A
Constraint and.
Priority Flags
4-NF, 5-LE
5-LE/EQ
4-NF', 5-LE
6-WS
, 9-0
, 9-0
Based on an assumed value of E =0.
n
Definition of flags is given in Section 3.2.2.
-------
101
petroleum storage for categories for distillate oil and kerosene are grouped
together since a standard could be set for both of them in much the same way
as for the storage of other liquids. The normalized standard development
effort is :
Category Normalized Standard Development Effort
Petroleum Storage
Distillate Oil-Breathing 0.5
Kerosene-Breathing 0.5
Six of the source categories are rated as having an energy conserva-
tion effect (factor 7 related as 0) as a result of NSPS control. For ammonia
manufacture (both methanator and regenerator and CO absorber), carbon black
(furnace process), charcoal, and beer processing, the hydrocarbons are con-
trolled with an afterburner. The exhaust gases are combustable and require
no additional fuel input; thus, heat recovery is possible for use in other
portions of the manufacturing process. For petroleum storage, the energy
conservation results from minimizing the loss of material. Although the
petroleum storage category is flagged as having a need for an equipment
standard, it is included here since a similar standard exists for the storage
of other liquids; that is, no enforceability problems can be expected.
The carbon black (furnace process) category is also rated as having
additional pollutant control potential as a result of hydrocarbon control
(factor 9 rated as 0) since the afterburner is used for sulfide control.
Equipment Standard Preferable (EQ)
Sources in this group on Table 4-8c have one or more special problems
that would make the enforcement of a NSPS difficult. With the exception of
petroleum refineries, all of the categories have an exceptionally large number
of individual sources that would make compliance testing for each source
an impractical task. For the miscellaneous point sources at refineries (as
well as for petroleum refueling, petroleum service stations, and petroleum
transfer) it is not feasible to measure emissions since they are not released
through a single point such as a stack. These considerations tend to support
the use of an equipment standard, rather than an emission standard, as the
-------
102
preferred NSPS control option. The legal problems associated with the use
of this type of standard have already been discussed.
Some legal problems are associated with the control of the petroleum
refueling category. Coordination with the Mobile Source Pollution Control
Program would be necessary to define the method of control and the adminis-
tering EPA division. (The recently proposed regulation was not considered here.)
For the diesel and dual fuel internal combustion engines, the equipment stand-
ard might take the form of production line testing similar to the motor vehicle
program rather than field testing. This presents compliance problems in that
not all sources would be tested. A resolution of this situation relative to
the requirements of Section 111 would be necessary.
Control of petroleum refineries, petroleum refueling, petroleum trans-
fer, and petroleum service stations would result in fuel conservation (factor
7 rated as 0). Control of the direct firing of meats would control odors
as well (factor 9 rated as 0). Pathological incinerators require an after-
burner (factor 7 rated as 2) but the units are generally small and the nature
of the waste may bring public demand for control. Hence, this category is
included here rather than in one of the later groups.
The petroleum transfer sources are treated together with the following
effort:
Category Normalized Standard Development Effort
Petroleum Transfer
Gasoline 0.2
Crude Oil 0.2
Jet Fuel 0.2
Aviation Gas 0.2
Special Naphtha 0.2
Uncertain Energy Impact Due to Unknown
Gas Flammability (Factor 7 rated as 2) (UGF)
Sources in this group on Table 4-8d are rated as having a moderate
energy impact as a result of NSPS since the control system requires the use
of an afterburner. Insufficient information was available to determine if
the waste gas was flammable and hence would not require additional fuel
input or whether there was need for fuel to be added. It should be noted
-------
103
that for several source categories there was adequate information on the
waste gas flammability. If the gas could be incinerated without additional
fuel input, the source was included in the unconstrained (UN) group. If the
information showed that fuel was required, the source was included in the
moderate energy impact group discussed next.
Although there are a large number of source categories in this group,
the emission impact is small. No single source contributes more than 1% of
the total 1985 Ts-Tn reductions based on the TRC calculations and 2/3 of the
sources each contribute less than 0.1%.
Moderate Constraint Rating (MCR)
Only four categories are included in this group on Table 4-8e. For
the ethylene oxide industry, the control system for hydrocarbons is a catalytic
converter. Since this requires the use of rare metals (usually platinum) it is
given a moderate constraint rating for scarce resource utilization (factor 8
rated as 2). The acrylonitrile, formaldehyde, and ethylene dichloride cate-
gories require auxiliary fuel in the afterburner and heat recovery is not
attractive; hence, they are rated as having a moderate energy constraint
(factor 7 rated as 2). The ethylene dichloride category has additional
problems in that the corrosiveness of the waste requires special alloys and
substantially increases the cost of control.
Research and Development Required (RD)
Sources in this group on Table 4-8f require additional research and
development into control systems technology prior to the promulgation of
NSPS. In some cases, such as the boilers, the research is needed on the
process itself. In others, control systems are under development or are
available but have not been applied to the industry. The other flags
associated with each category are secondary to the RD consideration. The
10-OC flag for industrial/commercial incinerators indicates that other con-
siderations may play a role in the standard-setting for this category. In
this case, the wide range of incinerator size and design may require a sub-
division of the category prior to NSPS development.
-------
104
No Demonstrated Control Technology Available (NC)
There is no hydrocarbon control technology available for sources
in this category on Table 4-8g apart from the cessation of operation. In the
case of brick and related clay products, the only control is combustor main-
tenance, but this is done for other than air pollution control and no other
system is available.
An evaluation of the effect of imposing the source constraints on
the priority ranking is given on Table 4-9. The first four strategies are
the same as the four considered on Fig. 4-5. Strategy 3 represents the
maximum NSPS impact case and is tha baseline against which the 1990 efficiency
ratios are computed.
Strategy 5 sets priorities for the source categories at the rate
of 6 per year based on the six constraint groups previously discussed. (The
NC group is eliminated from the standard setting procedure.) Existing stan-
dards are assumed to be in effect in 1975 and the unconstrained group (UN)
is considered in Ts-Tn order. The equipment standard (EQ) is assumed to be
a less stringent constraint than the energy impacts indicated by the unknown
gas flammability (UGF) and moderate constraint rating (MCR). Sources in the
UFG group may or may not have an energy impact and so are considered before
those with definite energy impacts in the MCR group. The research and develop-
ment group (RD) is postponed to the end to allow time for the necessary research
to be completed. (At the rate of 6 standards per year, NSPS for the RD group
are set starting in 1985.) The use of this priority scheme results in a 1990
emission rate that is slightly higher (8.6%) than the 1975 rate, with peak
emissions occurring in 1985. The implication of this procedure is that total
hydrocarbon emissions will be allowed to increase through 1985 due to the
various source constraints after which the promulgated standards will arrest
the growth and, by 1990, bring the emission level almost back to the 1975
level. As measured by the 1990 efficiency ratio, this strategy yields about
76.6% of the maximum possible control.
If the standard-setting rate could be accelerated to 10 per year
as shown in Strategy 6, then the peak emissions would be reached in 1978, the
magnitude of the peak would be reduced by 0.81 million tons/year arid the
1990 efficiency ratio would be increased to 86.2%, which is a 1.6% reduction
-------
105
cfl
f-l
*w
g
3
CO
toO
0)
•U
t^
4J
CO
>-.
4-1
•H
O
•H
PM
C
O
S-i
o
o
T3
ffi
CTi
|
0)
0
c^
^H
GO
C
o
•H
cn
T-*
S,
S c
•H
1
C.
CJ ,—s
S tt
O O
•H -H
W Gi
00 ON
-C E
0 0
cn --v
O CX
-H 4-J
cou>
-H O
E rH
W "— • '
m
QJ r-
bO ON
ff -H
cO
x: E
O 0
cn *-N
C >->
O 0.
•H 4-1
cn ID
•H O
^_^
>N
H
£ CX
LD
O
QJ
4-J
"0 X
3 C •
"0 -H O
-J 4-J C
n -u ^-^
QJ
LO
a
00
QJ
4-J
M
4-J
•H
S-i
o
•H
P-.
ON co >-o CN in ^ r— -ON oo -J"
o ON r- co co co ^ r- oo co
i — i
p-itHinr--^^}-^-^ rHr--o CN m r- rH
cor—cNcoin-j'-J'in t — . LO <± •*3-
CN CN rH i — 1 i — IHiHrH i — 1 i — I i — I rH
^jr\jOinr--co co^D -3* ^o
inrHcNcocNcNinr-— CN ON in i — t
in in i — i i — i CN
+ +11+ + + + ++ + +
ro I— - \£> OO i — I T-- CN in ^OOO rH ^O
cN-HCNro\£}~3-inin p- in in %
cfl iH C -H O rH
J-J V4 X QJ i-t C Q
co c cn X co u
Cb DQ4-JX 3S0140
4-> TJ C 4J -o T3 CX
co coco c^-HQj C-O-HCU
4-J CXCX -T4VJCO HCXCJ
CO 33 OS-i!u cflOX
MOO J-4O04JO V-t H
C 13OOOO 14-i-tJ C >->i*HiHC CO
>,COmVJ s-\ s~^ CO^-sO 4JrHx-x C0)^-v40
CC/ION CCeCCeC CO5 -HOO5C >,o5-H
OQ-.rH C-H-—'H--.'H/-NiHbO'---05 CO — - -H 00 X! "^- fl
cn H cao5 copd cop cocoiu iu >, otj cocwoi >-i
cn "Z. C 1 MO MC_) MO5 M -H O S 4_t^.CJ M-HOJCJ 4_i
M 00 H co--- cn--. coo5 cocO--.t3 C60--- cocflj-i--- C
cO C 4-* Cfa Cfa CCJ COfa C -^ OOJfa COOfa O
T3 '-H 0) C OO OO OS QUO cQQ U4-JO OOM-tO O
C4-icn-Hcjr3O3u--.(j ^D od dso r3
u -H c/j 4J QJ O* OJ o* O* O CX O O* O O1 C_j cy C^ u C O" rH Q
CO X 0-. 0) Cfa CW W ^j Wcow ^3W SOJW WaJ-HW (flee
OJ 2 CXZ D- !S X Z XMK Xg X-HZ; XMMZ XZ
a-JCHc/JOOOJOJ QJQJ QJ U
LOO
rH
00
in
1-1
v
i
o
o ^
c
iH O
CO -H
C 4-1
QJ C
4-J 00
S-* t-i
O CO
cn /^.
4J *^-x Q
c 52
•H cn --.
cfl QJ pci
M C CJ
4J -H X
CO 00--.
C C fa
O OJ O
U S
e -—
§0 o-
•H Ed
X CO Z
cfl 3 &
QJ
05
rH
c
H
1
cn
C
•H
Cfl
OJ
o
3
o
cn
H
rH
CO
cn
0)
'O
iH
U
a
•H
CX
3
0
00
^
z
QJ
iH
CO
4-J
cn
C
0
CJ
c,
QJ
H
s-^
2
N— '
K^
00
0
o
c
u
OJ
4-1
o
4J
o
CJ
•a
Q)
4-1
cfl
4J
cn
0
QJ
"O
0
C
fj
•H
3
CX
o
rJ
00
V-i
o
cn
T3
in
-o
G
ca
4~l
co
E>.
C "O
0 3
iH
CO O
QJ X
U QJ
t-i
O QJ
CO -H
00
M 4J
cO CO
C rJ
•H CO
cO i-H
4J iH
Cfl JD
*0
a)
>
rH
O
>
c
•H
cn
•iH
4-1
-H
CO
4-1
tn
C
o
•H
00
01
4-1
CO
t-l
4-1
JH
Q
4-1
a,
01
CJ
w
in
ON
c
•H
4-1
a
0)
UH
MH
0)
C
OJ
rQ
O
4J
CO
(X,
CO
55
00
C
•H
4J
CO
T-t
X
QJ
S
3
CO
CO
cfl
CO
QJ
•H
00
OJ
4-1
CO
4_i
cn
rH
CO
^
00
QJ
4-1
CO
)-i
4-1
cn
M
O
tx
0*
O
X
Id
CJ
C
0
«
>
QJ
^
OJ
"5
c
•H
U
OJ
>
o
§
•H
QJ
^
cO
4-1
Cfl
x:
4J
cn
4J
-H
cfl
4-1
CO
C
o
a
QJ
x:
4-1
O
o
4-J
C
o
iH
4-1
•H
cO
C
QJ
CO
QJ
1
cti
4-1
cn
cO
QJ
rH
c
•H
E
fa
cn
•H
s~^
CO
00
QJ
4-1
CO
4-1
CO
^^
CO
fa
c
cfl
X
W
cn
CN
00
QJ
4-1
Cfl
4-1
CN
OJ
QJ
X!
m
iH
CO
c
fjj
"
01
•H
.-
O
0
rH
X
O
7*
td
i
CN
fa
~~-
00
OJ
4-J
CO
IH
4J
cn
Cd
1
CN
iH
3
E
M
o
UH
OJ
4J
U-/
QJ
3
CX
O
CJ
-------
106
in emissions from the 1975 levels. Acceleration of the rate would, of neces-
sity, have to be accompanied by an earlier relaxation of the various con-
straints.
Strategies 7-13 reflect the result of selectively relaxing each of
the constraints to determine emission impact. If the EQ constraint could
be relaxed through a resolution of the enforceability problems and the sources
could be included in the unconstrained group in Ts-Tn order as in Strategy 7,
then the efficiency ratio could be improved to 82.5% in 1990. Emissions would
still increase through 1985 but the magnitude of the peak would be reduced
to 15.24 million tons/year as compared to 16.15 million tons/year for Strategy
5.
Review of the EQ group on Table 4-8c shows that the industrial sur-
face coating category dominates the picture with more than 65% of the Ts-Tn
potential in 1985. In Strategy 8, the EQ constraint is relaxed for this
category only. The calculations show that the emission peak still occurs
in 1985 and that the peak is 15.53 million tons/year or about 0.3 million
tons higher than the peak resulting from the relaxation of all the EQ
constraints. The 1990 efficiency ratio is 80.6% of maximum control potential
and the emission rate is virtually unchanged compared to 1975 levels. This
is a clear indication that if the e-iforceability problems of this source
category could be resolved quickly, it would result in significant emission
control improvement. The control potential of the other source categories
in the EQ group is smaller in magnitude and the constraint need not be lifted
prematurely for them.
In Strategy 9, the moderate constraints resulting from energy con-
sumption and scarce resource utilization (groups UGF and MCR, factors 7 and/or
8 rated as 2) are relaxed. The result is a worsened emission picture with
the peak being pushed back to 1984 and the 1990 efficiency ratio dropping
to 66.7% of maximum control potential. The primary reason for this behavior
is the generally small size and large number of sources in these categories.
By relaxing these constraints while maintaining the EQ constraint, standards
for the large sources in the EQ group are delayed until 1984. In comparison
to the emission reductions achievable through the other strategies, this
appears to be an unacceptable alternative. The fact that the setting of NSPS
for these categories could increase national energy consumption further
argues against premature relaxation of this constraint.
-------
107
Review of the source categories in the UGF and MCR groups (on Tables
4-8d and 4-8e) shows the ethylene oxide industry to play the major role. Its
inclusion in the MCR group is predicated on the need for scarce metals in
the catalytic converter used for control. Strategy 10 shows the result of
relaxing this constraint. On the basis of the industry's Ts-Tn rank, the
standard is set in 1976. Peak emissions occur in 1980 and the 1990 efficiency
ratio is increased to 78.9% as compared to 76.6% for Strategy 5.
Strategy 11 is a combination of Strategies 8 and 10. The constraints
on the industrial surface coating and ethylene oxide industries are relaxed
while all others are maintained. The result is an efficiency ratio of 82.8%
of maximum control, which is higher than all others considered thus far except
for the strict Ts-Tn order (Strategy 4) or the 10 standards per year rate
(Strategy 6).
Strategy 12, shows the effect of relaxing all the constraints except
RD. It represents the maximum control achievable with state-of-the-art
technology. The 1990 efficiency ratio is 86.4% of maximum control and the
emission peak occurs in 1977.
It is evident that the difference between Strategies 11 and 12 could
be reduced by relaxing the EQ, UGF, and MCR constraints of an increasing
number of sources until the desired level is attained. The question of what
is the desirable level is a highly speculative issue. As an alternative to
determining a numerical value of efficiency ratio, which is desired, it is
possible to consider the implications of relaxing constraints on other
sources in the groups. For the EQ group on Table 4-8c, it is clear that the
industrial surface coating category has such a large Ts-Tn value that it must
be considered a prime candidate for constraint relaxation. The only source
category that has a larger Ts-Tn is open burning, which is in the NC group.
The next source in the EQ group, miscellaneous point sources at petroleum
refineries, presents numerous difficulties in identifying the actual source
of emissions and determining the best control alternative. It seems intuitively
apparent that control of these emissions has economic incentives as a result
of the increasing price of crude oil and it is not clear that the effort
required for the promulgation of a NSPS will be justified in the light of
other incentives for control.
-------
108
The third source on the list, petroleum refueling of cars, has compli-
cations resulting from the interface with the Mobile Source Pollut Lon Contro^.
Program and would probably require extra time to develop a standard. The next;
two sources, drycleaning and petroleum service stations, have extremely"large
numbers of small sources. An EPA policy decision is needed to resolve the
enforcement difficulties. The remaining sources have small Ts-Tn potential
and hence do not have a critical requirement for constraint relaxation.
For the UGF and MCR groups, ethylene oxide is the only large source.
Relaxation of constraints on other sources is of minimal effectiveness.
The conclusion to be drawn, from this subjective and qualitative
analysis is that relaxation of the constraints for industrial surface coating
and ethylene oxide appear to be the only necessary ones at this time. There-
fore, Strategy 11 is the most practical choice for hydrocarbon standard setting,
Curve 5 on Figs. 4-5 and 4-6 shows the impact on emissions.
One last possibility needs to be considered. Strategy 13 is designed
to investigate the impact of a research program to resolve the control problems
for internal combustion (spark ignition) engines, which have a large Ts-Tn
potential as shown on Table 4-8f. It is evident that this source category
is approximately equivalent to the ethylene oxide category in terms of its
emission impact. The 1990 efficiency ratio is improved to 79.3% (as compared
to 76.6% for Strategy 5) if the control constraints for this source alone
can be remedied. There is, therefore, a strong indication that a research
effort designed to eliminate these problems would make a significant impact
on hydrocarbon emissions.
4.6 POLLUTANT PRIORITY ANALYSIS' - CARBON MONOXIDE
As with the control of nitrogen oxides and hydrocarbons, the control
of carbon monoxide (CO) emissions is influenced by the interaction of mobile
and stationary source categories. The set of stationary source emission
curves is given on Fig. 4-7.
Only one CO NSPS has been set (the catalytic cracker units at petro-
leum refineries); one more has recently been promulgated (ferroalloy produc-
tion) but, as discussed previously, is not included in this study. A signifi-
cant amount of emission control has been achieved by the refinery standard as
evidenced by the differences between Curves 1 and 2. The uncontrolled case
-------
109
100
90
cc
-------
110
results in a 1990 emission rate from stationary sources of over 62 million
tons/year. The refinery NSPS reduces this to about 51 million tons, although
this level is still amost 30% higher than 1975 rates.
Curve 3 shows that the maximum impact that can be expected through
the setting of all standards immediately is a reduction of 24% over 1975
levels in 1990. By setting CO standards at the rate of 2 per year in strict
Ts-Tn order, a 16.4% reduction is possible in 1990 as shown from Curve 4.
Figure 4-8 shows the behavior of CO emissions from both mobile and
stationary sources. Motor vehicle emission controls result in a significant
decrease in CO emissions through 1985 independent of stationary source con-
trols. Beyond that time, the growth in vehicle miles traveled causes emissions
to increase if no further stationary source controls are imposed (Curves 1 and
2). By promulgating additional NSPS, it is possible to counteract this growth
and effect continuing emission reductions through 1990 (Curves 3 and 4).
The prioritization of CO sources was handled differently than for
other pollutant sources. First, CO emissions from stationary sources do not,
in most cases, represent a majority of the pollutant load in a region; nationally,
12
stationary point sources account for 19% of the total CO emissions. Second,
control of CO is closely related to the control of hydrocarbons and nitrogen
oxides. For fuel combustion sources, the steps used to reduce hydrocarbon
emissions, such as design and firing modifications, will also control CO.
Nitrogen oxide control also has impacts on CO emissions since flame tempera-
tures, gas recirculation, and other methods must be carefully controlled to
avoid increasing CO concentrations. For process sources where the hydrocarbon
control technique is the use of an afterburner or incinerator, CO emissions
are controlled at the same time. For these reasons, it was decided to priori-
tize the CO sources by linking them to the priorities that result from HC
and NOX control. For the source categories where there is no strong correlation
between CO and HC or CO and NOX, tte normal priority screening routine was
used.
Tables 4-10a to 4-10g give the constraint evaluations for all CO
sources. Those categories where the priority is determined by hydrocarbon
or nitrogen oxide considerations are appropriately noted.
-------
Ill
no
100
90
cc
-
CO
o
80
CO
CO
CO
70
60
X
o
o
GO
CC
-------
112
Table 4-10a.
Carbon Monoxide Source Categories
with Existing NSPS (Group ES)
Category
Ts-Tn, 1985
(tons/year)
Ts-Tn
Rank
Constraint and
0
Priority Flags
Petroleum Refinery
(FCCU)
N/AC
N/A°
Not applicable since this source is not a candidate for a revised NSPS;
i.e., the present NSPS is felt to represent the best control technology.
Table 4-10b. Carbon Monoxide Source Categories with No Major
Constraints to Promulgation of NSPS (Group UN)
Category
Iron and Steel Plants
(EOF)
Carbon Black
(Furnace Process)
Ammonia
(Regenerator and CO Absorber)
Wood Pulping
(Kraft Process)
Stationary Gas Turbines
Electric Utility
Gas Pipeline
Iron and Steel Plants
(Electric Arc)
Charcoal
Iron and Steel Plants
(Blast Furnace)
Ferroalloy
Ts-Tn, 1985
(tons/year)
4,130,000
2,510,000
1,670,000
471,000
446,000
60,600
225,000
104,000
53,280
41,600
Ts-Tn
Rank
1
2
3
5
6
21
13
19
22
24
Constraint and
o
Priority Flags
7-0
7-0, 9-0, with
hydrocarbons
with hydrocar-
bons
with hydrocar-
bons
with nitrogen
oxides
7-0, with hydro
carbons
7-0
First number is the factor considered, second character is the flag.
Definition of flags is given in Section 3.2.2.
A NSPS has recently been promulgated for this source.
-------
113
Table 4-10c.
Carbon Monoxide Source Categories for Which An
Equipment Standard is Preferable (Group EQ)
Category
Internal Combustion Engines
(Diesel and Dual Fuel)
Pathological Incinerators
Ts-Tn, 1985
(tons/year)
137,000
60
Ts-Tn
Rank
17
32
Constraint and
o
Priority Flags
5-LE, 6-WS, wit!
hydrocarbons
5-LE, with
hydrocarbons
0
Definition of flags is given in Section 3.2.2.
Table 4-10d. Carbon
Energy
(Group
Category
Maleic Anhydride
(Benzene Oxidation)
Mineral Wool
Phthalic Anhydride
(0-xylene Process)
Secondary Lead Smelter
(Blast Furnace)
Asphalt Roofing
(Blowing)
Auto Body Incinerators
Meat Smokehouses
Fiberglass
(Wool Processing)
Secondary Zinc
(Sweat Furnace)
Magnesium Smelting
(Secondary)
Monoxide Source Categories with Uncertain
Impact Due to Unknown Gas Flammability
UGF)
Ts-Tn, 1985
(Tons /year)
279,800
161,000
61,200
6,000
1,400
1,100
500
60
1
0.5
Ts-Tn
Rank
9
15
20
27
28
29
31
33
34
35
Constraint and
*3
Priority Flags
with hydro-
carbons
with hydro-
carbons
6-FL, with
hydrocarbons
with hydro-
carbons
with hydro-
carbons
with hydro-
carbons
9-0, with
hydrocarbons
with hydro-
carbons
with hydro-
carbons
with hydro-
carbons
Definition of flags is given in Sec. 3.2.2.
-------
114
Table 4-10e.
Carbon Monoxide Source Categories with
Moderate Constraint Rating Due to
Increased Energy Consumption or Scarce
Resource Utilization (Group MCR)
Category
Formaldehyde
Acrylonitrile
Ethylene Bichloride
o
Definition of flags is given
Ts-Tn, 1985
(tons/year)
386,000
259,000
29,700
in Section 3.2.2.
Ts-Tn
Rank
7
11
25
Constraint and
o
Priority Flags
7-2, with hydro-
carbons
7-2, with hydro-
carbons
3-HC, 6-FL, 7-2
8-2, with hydro-
carbons
Table 4-10f . Carbon Monoxide Source Categories Requiring
Control Technology Research and Development.
Prior to NSPS Promulgation (Group RD)
Category
Iron and Steel Plants
(Sintering)
Internal Combustion Engines
(Spark Ignition)
Municipal Incinerators
Boilers
(>250xl06 Btu/hr)
Boilers
(10-250xl06 Btu/hr)
Boilers
(0.3-10xl06 Btu/hr)
Industrial/Commercial
Incinerators
Boilers
(<0.3xl06 Btu/hr)
By Product Coke Ovens
Fiberglass
(Textile processing)
Ts-Tn, 1985
(tons/year)
786,000
381,000
269,000
236,000
223,000
151,000
123,900
50,900
22,700
990
Ts-Tn
Rank
4
8
10
12
14
16
18
23
26
30
Constraint and
Priority Flags&
5-LE/EQ, 6-WS,
with hydrocarbons
6-LO, 9-2 with
hydrocarbons
9-2, with hydro-
carbons
9-2, with hydro-
carbons
5-EQ, 6-WS, 9-2
with hydrocarbons
10-OC, with
hydrocarbons
5-EQ, 6-WS, 9-2
with hydrocarbons
with hydrocarbons
9-0, with nitro-
gen oxides
Definition of flags is given in Section 3.2.2,
-------
115
Table 4-10g. Carbon Monoxide Source Categories for Which There
is No Control Technology Available (Group NC)
Category
Open Burning
Sugar Cane
(Field Burning)
Brick and Related Clay Products
Chlor-Alkali
(Diaphragm)
Chlor-Alkali
(Mercury Cell)
Orchard Heaters
Ts-Tn, 1984a
(tons/year)
15,312,300
561,000
1,300
970
370
70
Ts-Tn
Rank
N/A
N/A
N/A
N/A
N/A
N/A
Constrainc and.
Priority Flags
4-NF, 5-LE, 9-0
4-NF, 5-LE, 9-0
5-LE, EQ
o
Based on an assumed value of E =0.
b n
Definition of flags is given in Section 3.2.2.
-------
116
Existing NSPS (ES)
For the catalytic cracking unit at refineries, the control tech-
nique is incineration that represents best available control, hence there is
no revised standard proposal. A CO NSPS has been proposed for the ferroalloy
industry but this has been ignored in this analysis as have the other pollutants.
Unconstrained (UN)
On this group shown on Table 4-10b, only the iron and steel sources
(basic oxygen furnace, electric arc furnace, and blast furnace) and ferroalloy
require a CO NSPS independent of hydrocarbon or nitrogen oxide controls. The
Ts-Tn value determined by TRC for the ferroalloy industry is based on best
available control, which is more stringent than the proposed standard.
The stationary gas turbine engines are treated together with the
following effort:
Category Normalized Standard Development Effort
Stationary Gas Turbines
Electric Utility 0.5
Gas Pipeline 0.5
Equipment Standard Preferrable (EQ)
Both sources on Table 4-10c involve combustion processes and hence
CO control can be linked to HC control.
Unknown Gas Flammability (UGF)
All sources in this group on Table 4-10d are controlled for hydro-
carbons by an afterburner and CO control follows.
Moderate Constraint Rating (MCR)
All sources in this group on Table 4-10e use afterburners for con-
trol of hydrocarbons and CO control follows.
-------
117
Research and Development Required (RD)
Only the iron and steel sintering operation of the sources on Table
4-10f requires separate CO control. All others are linked to HC or NOX.
The 10-OC flag for industrial/commercial incinerators indicates that source
category subdivision (based on incinerator size or design) may be desirable
prior to NSPS development.
No Demonstrated Control Technology Available (NC)
There is no control available for sources in this group (Table 4-10g).
Table 4-11 shows the effect of the standard-setting strategies for CO.
The first four are the same as the four curves of Fig. 4-7. Strategy 5 con-
siders the imposition of the various constraints on the setting of CO standards
only. It does not include the effect of the linkage between CO and HC or
CO and NOX, which will be discussed in the next section on multipollutant analyses,
The table shows that the constraints reduce the 1990 efficiency ratio to
75.0%, but the emission rates are still 10.6% below 1975 levels. Strategy
6 shows the effect of accelerating the pace to ten CO standards per year.
This brings the efficiency ratio up to better than that of the strict Ts-Tn
order of Strategy 4.
4. 7 COMBINED POLLUTANT PRIORITY RANKING
The previous Sections 4.2-4.6 have evaluated alternate priority
strategies separately for each criteria pollutant within the constraints
of specified standard-setting rates using nominal values of 6 per year for
TSP, 4 for S02, 4 for NOX, 6 for HC, and 2 for CO, or a total of 22 per year.
For a combined pollutant priority ranking, time variations in the standard-
setting rate can be allowed for each pollutant to give a higher rate initially
to priority pollutants, and vice versa, while still maintaining a constant
total standard-setting rate over the period considered. This section discusses
the results of such a combined pollutant analysis using as the tool a com-
puterized version of the evaluation procedure described in Section 3.2.3.
A critical feature of the multipollutant evaluation procedure is
the specification of criteria used in the selection of the high priority
pollutant at each step of the standard-setting algorithm. Of the several
-------
118
rt
5-1
g
3
CO
^1
?\fi
0)
4J
U)
4-J
CO
1 i
•H
5-1
0
•H
PM
QJ
•H
0
c
fi
O
,£2
cfl
U
i— 1
1 1
1
OJ
, — 1
H
o
i-H
CO
O"i
1— 1
C
o
•H
CO
•H
W C
j
e <•
3 Q
•H
*,
cd
T
s.
r
T
C
c
4.
C/
a ^
e 8*e
•r-l
CJ O
•H -H
W C4
m
QJ r-.
C rH
ca
.C 6
O 0
M
fe-5
>iH O
B «H
w ^
m
oo a\
C rH
CJ 0
V-
CO s-^
0 CX
•H 4J
cn
•H O
w d-
,^
i_i
x
L) /~v
3 £•
O
rH
CU
4J /— N
CO V-l
3 a! X
0 00 •
3 C 0
: -H c
IJ 4-1 ^
J 4-1
} CU
U
-0
00
^ 01 0
- ro
c*i ^o co in r^
in -J" co o~i ro
o o m ^ ix>
O> c?\ r~* r~~ r-«
CJ\ O\ O\ ON C3>
5 £ $ Id 1C
2 ° ^ * *
CN CM
cn
M
nJ
cO
4-J
cn
a)
CTJ CO
4J CX
CO 3
i-i O
T3 QJ M /--^
C T3 bC Q
>-. cd un (_i pi
i-H f^ O 4J "-^
C CO ON C Cd
O CU rH C -H CJ
cn 25 c i I-* -^
u 00 H cn o
CO CJ 4J CD
•a 'H cu c o -*•*
C 4-J cn -H o cy
4-1 -H cn 4-1 cu -^
CO X CU QJ C ^
a) cn cn o ^D
cu 2 ex •^-'
4J >. Cn 4-1
CO r-H rH p_i CO
4J C rH C/l O
cn O < 'z cu
rH CM ro --.
bO
O
O
C
rC
U
w
o
L-i
4_l
C
o
U
T3
0)
CO
CO
o
g
cu
•o
o
c
& •
•iH QJ
S >
i-H
CX O
3 >
O C
!-( -rH
00
in IH
0
CO -H
TJ CO
CO 4-J
C C
CO O
4J a
cn
>> a
rH OJ -H
C: T3 U-i
C) 3 -H
i-H (J
U) O CU
QJ X CX
a QJ cn
3 co cO
o cu
CO «iH CO
oo cn
?>-. OJ QJ
cO cO C
C M 3
O 4J
r-* cn i-i
4-J 0)
C3 rH -rj
4-J rH l_l
c/: < o
4J
CO
o
4-1
4-J
o
CU
3
CO
aj
CO
cn
cn
TJ
QJ
cn
-H
a)
i-H
cO
_
1
i-H
cn
QJ
•H
bO
OJ
cO
i-J
cn
1-4
O
M-4
4-J •
CX C
u o
X CO
W -J
CU
in
r-. QJ
a\ ,n
rH 4-)
C C
iH -H
4-1 13
O QJ
QJ >
14-1 O
QJ >
C
iH
QJ
OJ JD
•° ^
O C0
4J g
c/: 4-»
P-i co
cn _C
bO co
C 4-J
•H C
4-1 -H
CO CO
">< 4J
CU CO
c
QJ O
g 'J
3
CO 1-J
cn cu
4-J
CO O
-. ct]
00 rH
QJ QJ
4-J T3
4J CO
cn
-------
119
possible criteria that could be used, the selection of the high priority
pollutant for this study is based on a determination of the maximum of the
lowest possible future emissions for each pollutant. That maximum value
relative to the criteria emission level specified for the pollutant is the
basis for selecting the priority pollutant.
When devising a combined strategy for all pollutants, the possibility
of simultaneously setting standards for more than one pollutant for a given
source category must be considered. In this study, it was assumed that if a
control device or process change required to control the priority pollutant
for a category resulted in the control of additional pollutants, standards
for the additional pollutants were set simultaneously. Categories and pollu-
tants with potential for multiple standards on the basis of the above assumption
are identified in Table 4-12. These multiple pollutant standards resulted
primarily from (a) use of scrubbers to control gaseous pollutants resulting
in particulate control, (b) use of afterburners to control both HC and CO,
and (c) process changes controlling various combinations of pollutants. It
was assumed that the priority pollutant required the normal resources (man-
power, money, etc.) for standard development, but the additional pollutants
required only 25% of the normal resources for a separate standard.
In the analysis of alternate coiffbined pollutant strategies, except
as noted, any standard requiring additional control technique research and
development (RD) or fuel switching to natural gas, or other fuels with limited
availability (FS) , was restricted from promulgation before 1985. Similarly,
any revisions of existing NSPS were not permitted prior to 1980. In the
single pollutant analysis these categories were generally constrained to these
limitations as an automatic result of their low priority with a fixed standard
setting rate. However, in the combined analysis, the rate for any pollutant
is variable and the above constraints must be explicitly included. From the
discussions in Chapters 5 and 6, these constraints are reasonable; however,
a more detailed future analysis should consider more exact constraint dates
for the individual categories.
Within these constraints, the sequence of standard setting for each
pollutant remains the same as that for the final strategy in the single pollu-
tant evaluation, with the exception of deviations resulting from multipollutant
standards for a category.
-------
120
Table 4-12. Multiple Pollutant Standards
Category Other
Controlled Priority Pollutant: TSP
Boilers: <0.3xl06 Btu/hr
Boilers: 0.3-10xl06 Btu/hr
Boilers: 10-250xl06 Btu/hr
Boilers: >250xl06 Btu/hr
Mixed Fuel Boilers
(Coal and Refuse)
Mixed Fuel Boilers
(Oil and Refuse)
Auto Body Incineration
Pathological Incineration
Municipal Incineration
Industrial/Commercial Incineration
Internal Combustion Engines
Pollutants Controlled
HC S02
CO
CO
CO
CO
TSP
TSP
CO
CO
CO
CO
CO
Simultaneously
NOX CO
HC
HC
HC
HC
HC
HC
HC
HC
HC
(Spark Ignition)
Internal Combustion Engines
(Diesel and Dual Fuel)
Stationary Gas Turbines
(Electric Utility)
Stationary Gas Turbines
(Pipe Line)
Open Burning (Agricultural)
Orchard Heaters
Phthalic Anhydride
(Oxylene Process)
Carbon Black (Furnace Process)
Acrylonitrile
Ethylene Dichloride
(Oxychlorination)
CO
CO
CO
CO
CO
CO
CO
CO
CO
HC
NO
x
HC
HC
HC
HC
HC
HC
-------
121
Table 4-12 (Contd.)
Category
Other Pollutants Controlled Simultaneously
Controlled Priority Pollutant:
TSP
HC
S02
NO,
CO
Formaldehyde
Ammonia (Regenerator and
CO Absorber)
Charcoal
Explosives (High)
Explosives (Low)
Maleic Anhydride
(Benzene Oxidation)
Meat Smokehouses
Coffee Roasting
Sugar Cane (Field Burning)
Deep Fat Frying
Asphalt Roofing (Blowing)
Cement Plants (Kilns and Clinker
Coolers)
Fiberglass (Textile Processing)
Brick and Related Clay Products
Mineral Wool
Fiberglass Production
(Wool Processing)
Primary Aluminum Smelters
Iron and Steel Plants (Sintering)
By-Product Coke Ovens
Secondary Lead (Blast Furnace)
Secondary Lead (Reverb Furnace)
Secondary Zinc (Sweating)
CO
CO
CO
a
a
CO
CO
CO
CO
CO
TSP
TSP
CO
TSP
TSP
TSP
TSP
HC
HC
HC
HC
NO
HC
HC
HC
x
HC
CO
HC
-------
122
Table 4-12. (Contd.)
Category
Other Pollutants Controlled Simultaneously
Controlled Priority Pollutant:
TSP
HC
S02
NO
x
CO
Secondary Magnesium Smelting
Refinery Fuel Gas (Sulfur
Recovery)
Crude Oil and Natural Gas
Production (Sulfur Recovery)
Wood Pulping (Kraft)
CO
HC
TSP
TSP
CO
HC
All criteria pollutants emitted (TSP, HC, S02, NOX, CO) are controlled
simultaneously.
-------
123
Except where noted, the time increment between the setting of standards
was one-half year with 11 standards (with normal development resource require-
ments) set at each time, or 22 per year.
The alternative combined pollutant strategies considered are summarized
in Table 4-13. For comparison, the first strategy assumes all NSPS are set in
1975 and that the emission level prescribed by the standard is zero (i.e.,
En=0). This is the maximum control case where all new sources have perfect
controls. The emission pattern for this strategy, plotted on Fig. 4-9,
represents the' existing sources. Obsolescence diminishes the emissions at a
steady rate for all pollutants. Over the 1975-1990 time period, S02 emissions
decrease the most (67%) while CO emissions decrease the least (31%).
Also for comparison purposes, the second strategy is a composite of
the final strategies from the single pollutant evaluations with a fixed standard
setting rate for each. The projected emissions, relative to 1375, are plotted
for each pollutant on Fig. 4-10.
In Strategy 3, Table 4-13, all projected NSPS are set in 1975, with
the exception of FS or RD categories for which the standards are set in
1985. This strategy, which represents the maximum standard-setting rate,
and thus the lowest possible emissions with non-zero standards, is not
realistic but was included for comparative purposes. The projected relative
emissions for this strategy are shown in Fig. 4-11. This optimal strategy
shows that it is feasible to keep the point source emissions of TSP, HC, and
CO from rising- very far above their 1975 levels even at the maximum point.
The S02 emissions, however, increase significantly (10.6%) but can be reduced
below 1975 levels if fuel switching and improved technology can be introduced
in 1985. For NOX, emissions will increase significantly (47.4%) even with the
1985 introduction of new technology.
Strategy 4 was used as the baseline case for the combined pollutant
evaluation. The emissions level criteria used for selecting the priority
pollutant was no increase above 1975 levels, except for NOX, which had a
criteria level of 44.4% above 1975 levels, which is the minimum level for
NOX even with advanced technology (see Sec. 4.4). The result of this strategy
is the standard-setting schedule given in Table 4-14 and the projected emis-
sions shown in Fig. 4-12. In the initial period, standard setting for HC is
emphasized to counteract the initial rapid increase in this pollutant without
-------
124
rrt
<^>
cd
g
03
M
01
CO
•J-*
oo
g
3
t3
0)
•H
o
^
.
CO
1
OJ
^
cd
H
XJ
CJ s-^
QJ ~— '
•H
U O
•H -H
14-. JJ
14- eg
O [JJ (X
ON
in
QJ r^-
be o>
C ' — '
r^ 6
U 0
QJ 1C
m M en
CO C i— *
CJ O
£
3J
QJ >-i
E Pi
3
E C
-HO u~i
X -H cur--.
^ en oc CTN
e ,c E
k..
(K "4-,
4J1
nj nj ^-.
i-i Dd i-.
CT3 >-,
C C •
rt -H o
en jj ^^
QJ
1/1
C 0] ,-j LD
en QJ ^ r— i
•H -H ^ £
E V-< o
W CJ ^ U
c
JJ
-^
o
CU
4J
'ti
Ui
en
>•,
•H
J_,
o
O>cnr-coo rHr^onLnON >X)oncM^a>
c^ooexJCMin Oo~iino^ ocor--\Di — i
in-^-oocor^ CO^-ONONOO ^Dr--onco'n ^-como^ COO-J-CNO r^co-^-MO
in >X) ^c on T— i CM O r- OOMCMCNON
Ilill II++I ii + il li + il
\jOininmcr- cncn^ Oi-nonrH^-i
Illll I+++I I++I1 I+ + +I
LninLnmin ^mOo-£ mmowo^ a^Lnooocn
cD>c^c^c^cn cncnc^c^CT, cncTsONCT>cr ONcnoNa^cn
ooooo mo^coo 1
QJ en c£
c o en jj a. at
•H r-MONOOrH D- 3 JJ
QJ • i — i in cc cj o ro
JJOJJ^ >-, >• >i "OUS-t S-J
Ol^nJO OOCiObC>-,X )-( X 00 4J
cc CD ^ ti ajQJQjoctiC COQJ en
en e u: c^ranjjjjj C"S QJ
O-iJJO i_.i-i)-jcCcfl ajin in c
2 en* cne/^enjjjj en^Cc7\ rH
inencu enc/: > — 'aji"1 QJ
T— ir^-H- IXHLi_'H cc
m i— i rH ^o '^ roincoom cor--v£)oooo CM rH CM CN •— i
cO^rHrot^- r-NinoQr"-cn r~-OicN-
1 i + + l li + ll l ii + i 1 ll + li
cNr--one^cncnc^ CTscncncnCT! cnc^cncr.cn cncnc^cr>CT>
i— t r- r-. ON o~-^c*~>''v'if^- m-^r^cncM
Oon\o^Dn i — iu~i i — iin
+ + + + + + + + + + + + + 4-+ + + + + +
CN CM CM CN
CM CM CN CN
OO-*OO OO -T O O O in
-------
125
^
*
4-1
O
U
'
01
i — 1
1
•>
C G •
0) *H O
£ ij s5
OJ
d> x~v
pj rO 60 in
O -H C r^
•H to (0 O>
CO QJ ,C rH
CO 4-> O
*H *H S
E w e^s o
^
C
+J
,3
o
00
01
4->
CO
^
en
^j
•H
O
'£
PH
-d-inosmr^ r^mvoosco
r^vooomos THOOOSVOCO
m^ooooso vc*^r^cor^
J
a o z 0
QJ C OJ C
CO O CO O
(0 *H CO 'H
01 m OJ w
^ CO V4 CO
U *H O -H
01 e c s
O 01 M 01
o
OS rH
os r^ oo os o
in vo co <± ^
tH co in co co
rH CO
+ + + + 1
o m o oo m
os a* os os os
CN rH^O OS 0
.rco.^0
+ + + +
CM
CM
o o
D CO
CM
CO CO 00 rH
r-. CM CM CM o
m rH
il + il
il + il
CM VD rH m
o -3- m CO C^ O CT»
CTN m o o> vc
CO 00 C^ 00 00
O CO rH
o~\ r^« oo
I + + + I
oo m o r** o*\
r^- co o> r- r-
> O CN CN
' CO O rH
r~-~ oo r
CM CO "
r^ CN vo O CM
CO CM CM - O
c/5 g: s o
CM isl X
c/2 O O O O
H c/5 Z 5C O
cn O O U O
H cn 2 32 U
ft. fJ X
cn o O
H W Z
00-
C •
-------
126
^_^
.
TJ
4-)
C
0
U
s — /
CO
rH
|
^j-
0)
rH
rO
cd
H
o
OS
OS
rH
m
00
OS
rH
CD
4-J
CO
E c«
3
E C
•H O
X -H
co en
S co
•H
g
w
n
i
4
C,
d
o -
•H
to
CO
•H •
e
w c.
!>0
O -^
C ^
0) s-~'
•H
O O
•H -H
4-1 4-J
W M
m
0) r-^
60 ON
C ' — '
Cd
^ e
o o
(-1
t>? 4~l
U~|
(U f""1-
OJ3 Oi
C iH
fQ
,£ e
U O
j-<
c^2 4-*
(-J
0)
CU
r-1"1
m
cu r~-
oo cr>
a ^H
cd
,£ e
U 0
V4
£^ UH
0)
4J
3 CO ^
H p^ tj
13 X
3 00-^
3 C •
•a 'H o
-1 4J C
o 4-> ^
CU
to
•a cu in
H 60 r^
H c as
11 CO rH
H CJ E
H O
J B-5 rJ
v~^ IH
4-1
C
CO
4-1
3
rH
rH
0
d<
_a
>s
60
CD
4-J
CO
r-l
4J
cn
>,
4-1
•H
n
o
-H
l-i
PJ
rH
CO
m
in
CO
i
as
o
i
as
r^
o
Os
CN
!
+
CN
CN
O
O
P-i
tn
H
O
Pt
•a
c
CO
to
Cu
>-,
CO
rH
CD
Q
CO
rH
rH
00
rH
so
CN
CN
+
00
rH
rH
+
0
OS
as
so
CN
CN
+
O
O
0
c/3
rH
•H
4-1
C
3
en
cx
3
0
r-l
60
CO CO 1^-
so co r~-
00 OO sO
O m r~-
CO rH SO
m
+ + I
in CN as
CO rH rH
CO
+ + 1
o oo as
as r- r~-
O O Os
O CM so
CO CO CN
m
+ 1 1
T -r
-& o o
~f O O
~3
+
X
QUO
Z X U
0
as
OS
rH
>-
CD
4-1
UH
CO
inooi — ^CNOS r-iascNr^in
r^vocNinoo cNoocosoco
m^oocoso -vrcNsor^m
ii + ii -J- + + + i
aoocosoco ij^osoinso
ocosocNO ^rminosco
rH CO rH vf
+ + + +I + + + + +
Oinor^rH cMr-^ooocM
ooooasr^co cocoosr^oo
asOOsOSOs CTsOSOSOOs
CNOsOt^OO rHr^COrHO
^ in CN
CD C & ~~~~
en -H CD rH
C 2 1
C en o o> CN
01 T3 C
01 r-l O "O
S CO 4-1 IH 01
4-J TJ O >s
CU C T3 CO
,0. CO D 4-1 rH
4-i en o cu en
CD en co 01 T3 r-i
e W
03 -H -U C
bo C rd
t-. OJ -U
O Oj-O & 3
U-l >, CU rH
^ ^ ^ rH
CO O O O O
T3 iw 00 C C^
^ QJ 'H , T3
cd CO -U >-( J-i
T3 4J cd 4-J OJ cd
ecu ^ aT3
ca cd O C
4-1 4-J CU '-W IO 0)
W 3 CJ (4-( CN 4-t
rH J-l i] • W
4-> M ^3
CU O O
c/i a co cd
•
^o
I— 1
i— i r^. r^. vo r-..
CN r-- ^o i-o o
^D -3- cx) oo r-
co co r~- I-H c^i
h- CN C^J rH CX)
U"l
1 I + I 1
r-- a)
O> CT> O"\ O>
^H
c
•H
4-J
CJ
0)
LH
M-i
OJ
C
• H
CU
^
0
4-J
C/3
O-i
C/D
^
&D
C
•H
4_J
CO
•H
X
CD
0)
E
3
en
en
a!
•a
c
CO
cx
3
o
rJ
60
CJ
• 2
>,
rH CD
n -a
O 3
rH
CO CJ
CU X
O 0)
IH
3 CO
O 0)
01 -H
60
>! CU
V-l 4J
CO CO
C r-l
O 4-1
•H en
4-1
CO rH
4-1 rH
CO <£
CO J3
,J
, — i
1
•H
60
0)
(-1
«
en
4J
c
CO
4J
3
rH
rH
O
cx
CU
4-1
CO
H
CO
CX
CD
cn
M
o
U-4
en
C
o
•H
4-1
•H
c
-H
UH
CU
Q
CJ
cn
4-1
C
•H
CO
H
4J
en
d
o
CJ
4J
C
CD
E
rx
o
, — i
CD
>
0)
13
13
C
CO
J3
a
CO
CD
en
CD
^
-d
C
co
60
c
•H
,c
CJ
4J
•H
3
en
rH
CD
3
UH
t-l
O
14H
4J
CX
CD
CJ
X
W
T3
-------
127
CC
-
\
CO
o
o ?n —
CO
CO
CO
STATIONARY SOURCES
EN = 0
1975
1980
1985
1990
YEAR
Fig. 4-9. Emission Projections for All NSPS Set at Zero Emissions
-------
CO
z
o
CO
CO
<£
^c.
o
60
50
40
30
20
10
0
-10
-20
-30
-40
128
-50
1975
I960
1985
1990
YEAR
Fig. 4-10. Combined Pollutant Emission Projections for Stationary
Sources Based on Single Pollutant Analysis (Strategy 2).
-------
129
o
60
50
40
30
20
10
0
-10
-20
-30
-40
-50
CO
1975
Fig. 4-11.
1980
1985
1990
YEAR
Combined Pollutant Emission Projections for Stationary
Sources Based on Setting All Feasible Standards
-------
130
60
0)
ca
S-j
QJ
a
ra
ct)
JH
o
•S
4-1
H
. _ tn
o-V
in i
u
<
CC
o
b
U
cc
w
en
w
u u
(E G"CO
^ UU
w
u
z
05
c
05
O
0= O
oa
05 EH
w oo
> < ^ K
05 tO 03 O oT X
*~ 05 >— m rn B
O ^Xt< I
o
o
z
o
o
u
Z 03
•"OB5WE-tP5E-i E-*P3vCJt-— —- "^ *^ EH EH
1/5 c/1 I/I ««
•O^-^— O*— T— t— OT— ^-o»~
'*— OOOO»~OO'
OOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOOO
OOOOOoOOOOOOOOOOOOOCOOOOOOOcOOOOOC'OOOo
ojcs)rsjr\j
-------
131
13
o
u
1
OJ
r 1
"<6
jurce
X
II
c e
3 5
+-> z
C/3
-M
i — <
O
PH
0)
•H -fJ
-t-* ^-<
rt o
3 W
u
cfl
W
fci
Z* •*
o a
M Q
H
H "3
O <
!»5 W Z
05 I/) M
OH H IO
X to Q M _
I-l M Z
CC M U W pi
03 WUtOWO.—- **U
01M MWfeCJWZ OfciH
CCi K t-1 WCL.H ZDZ
CJfO WO O3OEH fH«3t-J
S" U KJ W OMt-iC-jZOFHtltD (a EH"
MZQ •"•' o H "^ o \ «ctmH^» EM^J
OH rt Z ct 03 CQ CD tJ CC **^ P" O EH 0 1 HH CO
^tx as w w"u=s U uouuw>-i rccjHco
ClQiO H O CCiocc «i o >-J »— 3 "* O "*^ "SO O O
U»<25 bn OOE WOCD^-tC1-'^ O2S V) W COt/)WW
t-i [x-t W CJ M^ tOC/)M O Mt'^'WWH'OOEiJOCJH CJCJtX"*
-tCQ
Ull z^ nj H wW o
^JMM «! O ccz O MCU-I: o Occtrjo^cttOi-J^wtntiq^ ,-J^ffi<
Ds"*^ WE-H H •< EC CttWW H ^OxOOf-tMW^M^M &JWOW
uuuouooooouscouuu oo ooooooouooo^ uuuo
ggsss^ss^-^^ssss ?s^ss^^s;^ss^ss ss^;^
T-^jrorr, a^ra-Ln^r-oDCOcccro^- r- »- rMna-^-Ln^^^coc^c^ --r^ma-
uo o
LD ^O •
,- r- OV
(/T
U t/)
03 03
O iJ
tr* O
^ O
MM «
f J 1
Si ^— ' ^^ EH tO O
i-l HH" Z EH
r« O X W i-J «£
Z V> Z ^" z
W U W PJ EH Z
CC O 03 CU Z H Q
U tti E U 1-4 ij (J
EH W W X Oi
^t CLJ w cc w t~> o
C/3 E~* ti< QJ O E *^
uuuooooo
ssssssss
tn^r-cocrc^o.--
-------
132
(J
J^
3
^ £
*
^_
4-J
d
o
~— '
•
^•d"
rH
1
nj o
1 w
u
(H
03
CO
05
O
6*
D5
— - W ,— .
*-^ CC Z to
H E M CO
Q X O W
M p ^ oo (j
X H M tu O
i—l O-i V) O tO f*J CU
Q ^D*S O 05 M O5 EH
H MM EH bl EC U — M E-i
CJ O U <;EHWtnOtu [LI
«£ >-». ^- U5 05 t— l t> t-J to H-l <4
HJXW^WW wtnca w
H 0 ^ E 0 H 00 0 tO S-2, S-z
^^r^^jd-a^QQu^ u^
M -X MZE«SZZ ZOO
ZUOO»-JCO M bJMM MM
^ tn s— ' *33W>^MC5i-JQjC^ cxu
«3 M>Q 55 i-Ji-1 i-lO
<:t_jcnc^MO>-iM>Hr3iD sffi
CUO^fHCOCOCKk-JOjQ^Clj CLjO*
6HO3WOOO «SW<
X Wt-]O»-^OEEZ'EQO Q[£!
^CQMOO^FHMCLiMOO O*-
EMOZxDceOJOSOO OM
O6-CQMW o
W K
U Cu
•£
z m
05 ic^
b-,
>-3
^H rtl
sr o »-. »
in E^ tn t<
CD «; «s «c
r» , 05 ^ z
w w
K fc; z
Q W O "9j
Z I> Ctj
**• W iJ
05 >-i M
i-J — ' 05 O
-=C H
U W M Q
*~- "**" E~* b- ^>
W M W Qj
i-l i-J W 05 U
Hi ,_. W ^^ £ ^"" *— '
H i-J 0 iC W ^
WO M Q O O5 Q5
t!iw ^, 2-^>>
X ^00
to to M tn (/) tj u
tOtOE W >H&3Ci)[JJ
<<<<| s» Ojt»050j
t-J i-J CO M «! M
tjoos to o^noscc
CC05CL] O 5KO^)CD
UP^i-^ i-J Oi-^bbj
CDCQn CXi (jCU^fj
HMO X KIXOtD
(t. fc. oa w mwtoto
C'OOEOfOOOO
a" totodjtoctjtototocn
C-OOLOLTCOOOO
iriLTurr-r-ooooo
m ^untn^i-co^o-
o
;D
0^
hJ
w
^
o
Q
Q
z
«a
J_J
u
to
w
(_)
o
to
w
M
o
z
w
o
M
EH
CO
& 00
f£j fQ p^
W E O
05 £ EH 0 S
pq Z >< 05
PM *C W iJ ^1
O5 tO 05 3C *U y.
05 [u 05 Z E-H z M
tOWPKWrt; It,C5 U
Otozu>£nn°H H
U6H«t05< U
Z tO ,J Z M 05 M
rGZ WMl-^Z ClH'flJ O
wuzowok-; z o
t-JOM r3M*a39HO *-5
OMiJlWI^EHMUM O
C>QQ (O3(_JfjJEH [J^
>HQ5tOr56HMW05'«s3 fH
O5EL]*C05C^1>^MEH ><
otnc5(_)'^«ctooin a.
UCJUUCjUUUUOi-
nnxrcEEKXKEUs:
OOOOOOOOOLfllTl
00(Nl3-^OODOOor-!CM
^(NCNfSfN.Nnna^ir,^
z
o
M
•<
t-^
iJ
M
EH ^^
M y
0 M
*-^ E-*
__ J^J y^ __ f£
SM & 00 >4 K
1C f^ W EC Q
O-t O (±< PM O
« > °" « 0
O ^^ 05 U
O [230^1
X >^ EH bC *<
W 05 EH E-* EH
,J w w H W
~H i~-S-
to w to to in
EH 05 EH EH EH
05 05 05 OS
«* S <
0 CJ 0 CJ U U
;j rr sn 33 sc sc
o- cr o o o o
Lo u-> IP in LO LD
t— t—
-------
133
z
z
w
U
Q
z
w
U
O -^!
03 Z
CJ O
u~i i~
ce z
o w
H W
«e CK
w
U
«:
CU S5 H
c
o
U
W 1/1
o
in z
i z o
r- _1
H O
03 M
W Z
03
•Q
Z
>-i
03
O
t/5 03 N
W E- W
o a,
M Z Q
z
Q
H
z
w
fH !/)
W H
W
U W
Z CB
M «S
P3
*C EH (/>
M C/l Z
O3 C3 EH >
U
O
U I/) H
W O3 t/1
03
EH
P5
W
EH
O M _
03 03 U
— c z
EH H
H *C Z
03 H
Q (J
•e
•-5 03
E EH
as 1/1
O o
U Z
1-5.-5
Se W
i<3
Q O
O
I U
03 Q
85 W Z 03 O3 W z
r-l H P W W > H
(O 03 O (X W «£ E
W Z O W (£ |J
O O O Q
Cu M 03 O «S Q3
W
O
<
i
Q
Z C>
WWl-lUtJrHUejH M
WUHOEHtHZZinOS-'
VI CC COWZi-5HMb-i
a)
rH
s,
) o
( 4-1
U
in
oo
-------
134
o
>H
3
T 5
T3
••
4-1
£j
O
O
.
,-J.
I
1
_l_
0)
rH
J3
cd
H
?i !H
Cfl 0)
•o .g
+-> Z
t-H
r-i
O
•H -M
OJ O
'j ^
U
ni
CL>
£T
—-, 25
£T O 0? iJ U) , —
3U M EC >H Z o
X E-< \ X H Z O
6-< Q EH O t/J a H W
CG M CQ *-' W O CO Z
X U h-1 10 M
^OO^cWWO CQ W E
W W Q O Cfi ^», "*^ O **•' *-*.
OKOHHA-U O >JiJ
T-HT-C2O3 MO W WO
O •— O >H ^ W O H 1 Ct
LTi ipE X^tiJ ZC^i »_5 «; ^-*
MQCNZ (JZZWWO O W
AMArt Mf^ZXO O Q3t/l
•^^ t_) **•* !_•) ^WCXicC ^ QC/J
"^ U Sn C? "-^ ^"* ^"^ **
t/OV)HZZC3>HtH ^J t-3
CGCJKhJ MHOFHCOKJ "^ t/lC5
HJCBJK >-Z|3!SHH3: W HW
MEHHfn .JH^I-JWCI* z tnoa
OMOU o « »J o w w M WH
CGZCQCU CuCliCuC^CCxa; E OH&H
oooo^ir-u-iunLninunoLnino oo
OOOO-3 PJ ^^. to *£
Z W ^^ W W K
CC IH t/1 ^5 "S ft H
O •< EH Z O •*
EHW TC WZC&O.Z
•S* D Q «t C3 — ^
f& (n H H KJ [v,
^^ [t! — 'l/^ t/1 CGOCXit/lW
ZUZ W W OZ'SZEH
C/^WM O Z C3 C5 W ffi ffiWWtoWZ
iZJn SS M O < i-) W U UW'-'WZO
WWIO H Ni !C z: M « M EHEH ffiWCQ
CQ>-4<< [x4 0^>HQ4^'3H
^j^o^ixtc » Ha: coouiw'*
^-* Cud* Q (^* O W M W W QhJMC^O
O O^E "* ZCHZEHZhJEnO
v)cc;w CQ o w o o i-3 w >-3>«:i XZtCEH!>HM
tn^Pu EH u
-------
135
o
o
U
I
0)
cfl
H
&
•H 4-1
^ SH
CO O
CJ
B5
O
O
t_)
w
u
«c
Z
en u
O ««
EH Z
03 EH U KM
w i/) tr> w t-i
> •< Q CC EH O
ftj W w «; EH Z
'•-' EH En i-J 03 EH H
Z Obni-)<H
03
O
EH
-=C
03
Q W
03 O
i-A «| ,— o;
03 OJ EH tn
W Z H EH IE
EH M «* Z Z
O O EH n
O E W O IO Z
OS O Z 03 «!
Z U H Z
co ^ < a=
*C O
03 H
Q EH
SH IO
M CQ
Q JB
O
«C «C
In O
03 03 «
t-Hl^tJMJV^' Wi — p-1
y. ZCCWZOQW (o
S" PL, EHBiHUOUW
t-3 z rri O ® B1^ to fX PS O
Z^CSQHUMCaWCU
HWi-JU C6O«I««H
>
-------
136
^
""U
*•
-IJ
C
o
v-'
B
^j-
iH
1
v^"
0)
rH
H
d)
fj
J_,
3
£
T3.Q
1.2
II
C/3
•p
l—t
r- *
£
•H P
•*-> JH
rt O
|«
SH
1
O
CO a. Z K ^~ IJH O
CO Cu o O ^ 52:; O U
W CO H WC f-t f
tJ OH O Z ZM OHiJ
O X O *^ **^ O W H Cu E-t «t
Or; Cut W UH H-) WE
coawo H«r<,-J Kr:co
OUHJofij OCGOS|lt^H II^E-^ H COrf
H«SKCO WWWor; CQCO>- t-^IEMW
*4«;cc
cozoi-)Qcoc3cecen_5 ccoco QQCUH
O O3 J~i z Z rt3 "^ Z *fl3 W Z *ttl Z Z U
onwzoixHEjnojn TOOHCUOOXW
33Sg"u£SS"S SKSS""2S
EEI-^EEE^FIE Jri-E-TEEEE
OOOOOOOCOOO OOOOOOOO
OOOOOOOOOOO OOOOOC'OO
r— T—
o in
m ro
00 CD
^^
w
t_)
^
z
ce
tj __
I«j ~ M
W U
U U •<
Cf, m
CJ C^ P^H
H f^
K f-t
~~ H H CO
CO U CO «*
en w «: ^j
CO W K^ i-J CQ
K U W ffl „ ^
CO— — W
03 H H Z H
W H Z z c hJ
Z W «c -) i_i (t< E
cj QJ Cu CM co
z K «;
w w w «
t-J O W W — " W
< Z H H iJ
U H CO CO >c
w ,j a a 3 ce
O B Z ^ i 1 *•*
^ CL, «: < «: Q
o o z
E O Z Z CC O
22£ SSS
E O O OOO
Cu U O O O tJ
OOO O O C
000 OOO
i — r-
o m
rr 3
CD CO
T — *~
W
a
z
—l CO
M W
H ^
WO S?
H M W r>
£t, i-J Ul Dtn
E-i *-~ ^ t~* W
o w o o u w
^^ ^^^ EC DJ ^ M D
D^pc; hJMME-^Q O
f~ ^ JE E -_ CJ DJ ^ 0*5 O 25
CC \. \. &j" *~* *•** fTi t~> W <^
x c> s rc Q cc ex*
^S E"1 ^ \ (/} l/i 5S t-J
j^i CD CQ ^5 W l^J ^J O ^ ^H
fn E^ 5s 23 *i,' U sO v£) CQ M H E hJ *~^
W W CQ OQ CG nJ U
\OOO\D(rc;P5W'< »— 1
CH^*'~WCDDHZQ W
OXXOEHfHHCdWOC)
«~00r- ^WHS=&.
Of^Tm<'Su^*JffiO Q
IT) I f*") "CSCJISHWOW I-H
rMO«O H CCfHX (J
^ 3, ° V^ >"• >H S; >.
-------
137
/ N
*"O
"•
-U
fi
o
o
s- — '
•
•H +->
•P S
rt p
i-H <4H
§ W
!H
1
^
O
H
H
H
O
H
!*2
O5
i H Z O
W H pu «< < H U
t < CQ ^^ rf-^ i—l to 05 t/j
i-J (jul O Z W to i-^
WvX^^H-l OjWZ Wi«;
EW^^OSM Q W>H U Z
tOOWWH ftj NIOO O O5
<-EZX C5H H Z O5UW
QXHHW 2;*^ ^jWH diZH
H H O i— 1 ,— ~ iJ BH H
iJo«sp5 toccH
x ^^ OEto OQO^EHM cur*Oo5
05 tOB-«Jj OZ OCJ O Ct5-<;
rt!O)>-'(tJhJ Q5«CUWDO — 'hJ Z
OCB Jrj) Oj HEHQi-3 rttao
Oi-JtOKW WU-«05u5E tOWftiH
MOiJWH HcaWH!"^) to "^
W W Z SM H
vO O O W ! i r_i
W <- r- > CQ 05
O X X O C W
<- O O W JE
X *— LD W tO E
0 1 CM *6 tO O
LD n i o «s U
04 . O U X
A 0 «- W »J
-" >— -* H ^ «C
U H H
1/1 10 to B CQ 05
05 05 05 O O H
_3 ,_) ,J 05 O B
0 0 0 >- B Z
03 CQ CQ CQ •* H
uoucuocjouoo
IE O 3H U *C ^ E O tE iE O
mooLT.uriooLnLrtno
p~ c CNLrLnr"r~~( o
in^oi-r-cooooM^o^^
ui
•
oo
r-
W
o
< O
H
1-5 CO
H W
H Sf.
O — H
W (J
(J Z Z
H H (U
ffi t-3
H Z
U W O
^ W Cu H
05 ^ M EH
„ rc ^~ co_ o^to
X D E 03
X En X to CO E3
B to CQ B W W O
H 05 H Z Z U
CQ O vO CQ H H
H EEJ CQ CQ t«J
v£> <; o ^ 05 p^ «s
W 05 r- CL] B B Z
O OW XOH6-*05
«- Z Z o r- W
ro x tj i m «; «c z
. U Z ro • C> O H
O H H .O
V i°3 O V S*H 5M >H
— ' mj ^'^'050505
•< <3 c c r;
D-< DJ Cu
0 0 O
LO u) ul
CT, 0 ^
-------
138
•^
| 1
fi
O
u
^
1
"*
CU
rH
cd
H
.
o
o
B
T3.Q
ni a>
11
co^
•p
5
j _j
3
i— I
Q
PL,
>
•H +->
4-J (H
Oj O
3 m
M w
u
r<
Oj
cS
•*"
^_
15
Z
M
cc
EH
Z
O H
55 (/>
M •-'
H
<-l IT)
— W EH
W JC Z
M hJ
X tsl
H O W
^^" fv, TT 1
^5 « EH
in •*. 10
t/l tlj Q
rf O Z 0
»-J N^ >< Z
tp <•
oa to t/>
W (0 10 Z
03 •* < O
M f-4 CB CC
Ci-t t5 CQ H
«— T- 01 a- cr C" CT>
T) •
S-4 CO
cd CM
*~cJ c/^
d ^
ca
•U rH
co ca
0) 0)
4-J T3
cd CD
CO
T3
Cfl CD
en
en *H
QJ >
•H 0)
ft
6 cd
•H
CO
O 0)
•H
• rH
0 ft
& e
•H
M CM
cd
TJ •
C 0
cd ^
CO •>
en
• CO
iA !3
'*^x
rH Cfl
}-<
C 0)
•H T3
0)
4-1 MH
CJ
0) 4-1
MH en
OJ -H
C
•H 0)
0) 4-)
en
O 01
4-> -H
rH
T3 ft
cii S,
6 -H
• §
n en rH
rH en
1 cd •
-------
139
CO
CO
CO
60
50
40
30
20
10
UJ 0
-10
O
-20
-30
-40
-50
1975
1980
1985
1990
YEAR
Fig. 4-12. Combined Pollutant Emission Projections for Stationary
Sources Using Baseline Strategy (Strategy 4).
-------
140
additional NSPS as shown in the Strategy 2 curve of Fig. 4-5. The second
pollutant emphasized is NOX. Although NOX emissions have the most rapid
increase initially, their increase relative to the criteria of 44.4% above
1975 emissions is not greater than the relative HC emission increase. The
growth in SOa emissions cause this to be the priority pollutant by 1977 after
the major unconstrained NO sources have been regulated. All unconstrained
SOa source standards precede the particulate standards. In summary, the
sequential emphasis on pollutant standards for Strategy 4 is HC, NOX, SOa,
TSP, and CO, although other pollutant standards were set during the emphasis
of each pollutant. The standards for CO result in large part through simul-
taneous promulgation with HC or NOX.
The baseline Strategy 4, in comparison to Strategy 2 using individual
pollutant evaluations, produces a more nearly equivalent, relative maximum
emission for TSP, HC, and CO, of about 3% increase over 1975 emissions. The
maximum emissions for SOa, NOX, and CO increase slightly.
The baseline Strategy 4 results in a standard-setting schedule and
emissions reductions that is nearly optimal given the pollutant criteria,
total standard-setting rate, and other constraints. However, as the goals
and objectives of NSPS change as the result of, for example, new information
on the health effects of certain pollutants, new technology, increased avail-
ability of "clean fuels," and changes in impact of complementary SIP or mobile
source strategies, alternative standard-setting schedules for NSPS may be
preferable. In fact, the real value of the methodology developed in this
study is not only the ability to specify a future NSPS schedule, but to give
alternate schedules on the basis o:: a variety of conditions or goals.
Strategies 5-11 in Table 4-13 summarize a sensitivity analysis on the effects
of individually increasing or decreasing the criteria or goal for each of the
pollutants, and Strategies 12-15 show the effect of changes in other constraints.
Decreasing or increasing che emission criteria separately for each
pollutant did have the expected effect of a corresponding increase or
decrease in the maximum and final emission level for that pollutant. There
is, however, a limit to the change in projected emission level that is achievable
as indicated by Strategy 3 in which all standards are set in 1975, or 1985 if
constrained. An attempt to obtain increased reductions by lowering the criteria
can result in overemphasis of that pollutant with minor benefits at. the expense
-------
141
of increased emissions for other pollutants. For example, a criteria of
5% reduction from 1975 emissions for S02 (Strategy 7) resulted in only a
1.2% reduction in S02 maximum emissions (compared to Strategy 4) while
increasing the relative NOX emissions by almost 3 percentage points and HC
by more than 2 percentage points.
Although the change in emissions due to change in criteria may be
small, the change is usually obtained as a result of major changes in NSPS
development schedules. For each of the decreases in emission criteria shown
on the table, that pollutant became the initial priority pollutant in 1975.
Similarly, relaxing of the SOa criteria (Strategy 8) resulted in delay of
the emphasis on SOg control until after a significant number of HC, NOX, and
TSP standards had been set, and relaxing the NOX criteria (Strategy 10) delayed
the majority of NOX standards until near the completion of HC and SC>2 standard-
setting.
The most likely alternative to the baseline Strategy 4 is Strategy 9,
which has a lower criteria for NC> . The standard-setting schedule that resulted
.K.
from this change are given in Table 4-15 and the projected emissions are
illustrated in Fig. 4-13.
Strategy 12 was developed using the Strategy 4 baseline emissions
criteria but with standard-setting rates of 4, 10, 18 and 26 per year. The
1990 emissions are plotted as a function of standard-setting rate on Fig.
4-14. It is evident that the rate at which standards are set has only minimal
impact on the end period emissions beyond a pace of about 10 per year. This
indicates that the order of standard-setting is much more significant than the
rate. Once the large sources are controlled, standards for the many smaller
sources will provide relatively small reductions. However, while the change
in projected national emissions is not large, the impact on selected geographic
areas may be significant.
The possibility of no new technology or of no increase in availability
of clean fuels before 1990 is simulated in Strategy 13. There is a major
impact on 1990 emissions of SOa with this assumption with the increase from
1975 levels going from -2.8% for the baseline Strategy 4 to +22.6% with this
assumption.
-------
to
•H
en
cfl
js
ft
a
w
142
u
ft.
z
K
W
U
Z
(K
B
Z
O
B
W)
0)
4-1
cfl
4-J
CO
0)
,-d
o
CO
oo
4-1
CO
a>
u
tH
fe 10
U W
CO iJ
o
u u
ce S" 03
H z w
ED W O >-4 »
\ H -" U U
D Da i-) u
6-1 !/) Mi » Pn
ca
O
EH
CG
w
CQ
CB
W
>
«c
z
H
to
fS
• ca
o
^ VH
in H
•< «-O
t/5
03
W
O
O
W
bd
U
CQ
•K.
O
u
C! H
UOCB
a,
O Hi
m i uws=6-iwzu«Wijwzwin i cnUHHZUWm i
W >HV^)OO'*'«'' 1~'—"— '~'EHtH>-l
E-IOWOX03OOOC5WWWW W
MHXinȣ[/ltOCCCt;'C<'<<
-------
143
^v
13
JJ
&
O
U
V^X
•
in
i — i
I
0)
rH
cd
H
0
a
3
£
*Tj rO
00
•M
S
V
P
i— 1
i— t
£
D
>
H V
4-> !i
ni o
U
^
1
W
z o
o =
M Q
EH
H O
Z Z
M
i-3
^ W
05 10
rf M
x~ QJ M
>• in Q
EH *-• — •
hH
f4 W' tn -~
M W W in
D »— M IB — H W
W U to W O >J
u z z n tn z o
M M W £j Cn W O
CX, iJ W &_, u
EH z 03 W Z
U W O 03 O B
g. K || -i
tntoEHLDM EH WHO
Mi i*^ ZCNfZ^OOZcy^ CJ O5QC
O O hH 1 *"^ W W ( i EH Z EH %w'
O XX Z H Q H
>< >H X^tOMM>Hi44 MZt/]
03 05 05*-'WSCE05i-} JU"^to
Z Z atOHWl/lS'1' S^rtS
O O O05tOQ5Q5OEH HUO-H'h-3EHEi3 Mdi X f*1
f£ *£ ^ HH & fH W >4 E Z IH FH (Q
EH FH HO^OOEHW SQJCH
in in toaswoqmtou E«sciftj
oooooooooooooooo
zozozzzzzzztozzzz
Of^n^l^tnLDU^LOUOLD i/1 O O O O O
Ln^i-fNc-icNCsir-cNCNCNu-iinunLnu-i
T— t—
LD O
in v£
r~- r-
OS
w
pa
tn 03
K 0
O * O O *** •* O O t5
(K WSZEH^ZZZ
b o;r-3MO5tOZW*;HW
H !v; tO t/1 HH O O W O t_ ) EH C«) O
XU HtOO EHCSiJOWOO
UO<» O3W UtO >nOSOO5O3
Z i_) "SCJWEH (JZO4«!QJiawtnwtri^5tj
WiJO U 32 6HHtOXO5!«3O3HH
O5XCQ Q5 d4O3W6HOEHWt/lWEHEH
»R 32 Q3 irtl "11 W ^B to 0*1 Z CO HH CD X X
E£H«< 3= CdWWMW^MXHWW
QW(J D CJ3CQt>Oiic:V)ti4r»l*H£HE-*
ouuo UKrouuuuuuuuouo
antnffiu EOjC^toffiiED^a^iEEirTEcnE
Lnu^ipO OLTlOOOcOOOOOOOO
r^r^r-o o™mm^u^oir)inininu->o->tn
00 Q> o ^ »™ ^™ ^~ O4 ^ J LO U~) ^O f** 03 O"i ^5 *™
to
M3
?
-------
144
/^
T3
4_l
(H
0
U
*
en
i — i
!
cti
H
§
D
rH
rH
£
o
>
•H V
•M H
oj o
I— i <4H
3m
£ w
(H
nj
£
,-J
W
3
'»H
J
<
3
Q
Q
Z
^- ui «s
w»jp- & co>-ir)cn>HCKO!>HW tu
H m E-I u w oscn COKSWEO EHZ u >j
QK^^XCOW WE O&iUK&iUWMW CO O «S
•swdWH^j liicrio H'<«:CLi«:wa;coc-i£-iEtJ 03(/>£-«CJ «S 05> Q3QO ZZ WCOCO WCb O
^ CO ^— ^^ ^^" hH W Z ^ Oj U '^^ CC CJ3 O W W ^-1 C£ 0^ EH _- ^ ^"^
oq-JJi-1 K tt,f<(tii-I w O WOiJ"^ OCQ wJWW»~ME-< W
KtOXW 03 COB3E«S Z XXe-a:«S *- WEnHUPMli. ,J i^t
IX^'ZCE.> CCWOJZE-, Z H WKb-iHH>H * E ,J ^J I/) ^4 «S M^^W ,^
03 MW coWfuW«C (i-03 CJ ^JWWHWCC OW CO6JWCOD05 HtJD XI
WWZCOZ03 Z(i-,COfc<03<:CW Z Ci.Z^-ltJEQ _JO EEZCOU:UXOfci O
ZE-iHCOMO OCOZCOE-ia^ EH KH '"^ M *-* *^ *™^ ^; *— ' M 03 CO CO "^"' *^' ^^ Z W O M
WEHC/JWPKEHMZrtZHCiZ fa o P3 W MEHpcdx:
03<;wo6JOC5EH«:o3«<:!/)EZM i-J cowcocot/io wQ Ci-ia305OD3EZn OiZ-i U 03 030305 WE OWWHWHWCOCOH CO
COQL>QJECJZCO ^5 zi-nce H «:E«:«S«:Z .jz ONi~5aiGiCuutocos: «
•^MM OZ-< WM.JZ &-rt t.5 S O X"* iJ ,J »-3 O «i < 1 >
UEHWWMWwsiowovj z o owouuoa tn xs-iiwoDDwai-ico M
Q5i-itaWW03K«J!a3W>aiHE-l «; 03W03M03u^iru^Lri/>Lrt^o^'— f^LTLOLor^ r^-oooooooooof^-1 f^cNtNcNc^^cNcgrsicNLnuOf^-
'-CNO'-'— '-rgroH/inior-ooc^O'— »— '-r\imitinvcr--cDC^oo'-'-
T— r- T- r-r-<~ *— »— i— t—
O ^ O
r- r^ co
r- c~ r-
CT^ cr* o^
f— T— ^-
-------
145
'""X
-0
"•
4-J
C
O
u
\ /
w
LPl
1 — I
A"
-sT
i
r~i
'cd
H
•H J->
+J JH
rt o
rH '4_j
nJ
CD
^
Z
O
E-l
Q
-~ O
W 05
CJ O-
•33
Z CO
05 «C
3 (J
,J
X <
05 05
0 — D
E-l CO EH
*£ «3 «C
05 !J Z
W
CD iJ P
CG W B _
H D < W
t> B-i ^-^ Z
W ^J X t]
CC X H EH tJ (J »~
"" 05 O H X Z O
W CO X H Z C5
05 Z W Z | CO M Z
WHCWO CO 3 H
fnCnEQ-^ W O CO
iJ W 05 CJ i-J CO
wtauxwwo co w
:c — ~" C5 o O « ^. — ' (J
CO_HHMCLi U O
BKXXX0305 (J HC5 CB
QO0305~^C O 05 Z .JZ CU
-3 W M OH
W~^>>W X HisCW X ZB-, ^1
iJ OOZ Z UZZ CS WWO O
COUUW < MW B-, ZXO O
>-iiaiiJK)iJ ^J> 6JCMCB *
re>cc:cax CJ xo EH 03 —
«tH X33H S5ZQ < X Er< ^
OCOQiCCE-iCOfJ HMO ti< FHCO--J «i
ZOE3OWM* >E-iO COZ«C CC
Oi-JWC^XZX XZBC C^ XMX W
()D-i-Ji-Ji-J03EH _]HX H ^JCOCU Z
WXDDOrtX OOSiJ Kl OWCO H
cowcocoft'>cu cucbCM o o o>
__
o
z —
M 03
CO W
CO fc
W CO
CJ Z
o o •*
03 Z 03
_&, H H
03 *•" CO •—
X CO
NS^ W w W
C3 C5 CJ CJ
EH «C O «!
_ CQ 03 05 03 CO
W O ft* O 03
= ^0 H H O
M W CO D CO EH
E 0 Z <
«C ^~ t- Q «£ Q O3
h-5 i-l — X Z Z W
WO z U O«CC5«!Z
E O «* Z in Z H
ICt COWM (NUHOU
*C — ' IZEi IZXZZ
W COWCO OH03MH
CBCO CQJw! »-i_lcCi-4
S3CO «^«: — cues HnMQ
J O CO E O E O
CO C5 CO Q3 Kl P3 CQ
Z03 Z Cu W (UZUZ
HW MXCt. hJHZHO
COCQ cO>JIii |_|«SO«!R
WM WOO O03E-I03S3
03B-i CCC^tj CQOCOC5««!
OCJCJOCJCJUE EEEKU
cjarxcjxxaroj a/cupuOjX
oooipmmino ooooo
o c3 o fN f^J r^j nj in in m m cs o
T— fj [t^
HO «1 ^
(SI 32 Z2 H
[vj 03
X *<3 X H
03 O 03 M
<•* E «S Z
O CO Q O
Z Z i-l
O EH OX
U «* U 03
M W W CJ
CO E CO <
OCJOOEOCJOCJO
CJ32CJXClp-p-cocDa>oo^.-
-------
146
x — s
•
n3
f.
•P
o
v, t
^
1 1 1
rH
i
£
•H -P
"3 m
tH
ed
* fv]
O-. U PH O3 U 03 33
W CO EH Z Q EH „
*-* Z "^ O ,— O U H — ' O 03
oToo^CJ^ PS UOlOH,~ ^03(1-1 EH!^
XHEZC5 H ECQO3O3U WQOW^~IO«:
\EH\Hr< Ul/)H~-'WDZ •" «COWpqO3
S-IDP3 W03(« HEHH >-)CO«CU>-iD
HQHiJO ^ M (O CO >-q CJ U lO«COO3' H >aj&i jen«c-— Z^NEHZ o 10 w
>- H <— E «t «t UO top Z iJDCOE H H^'lHW»-|U OWHOOH WtOWZ
U"i inUSSQOW COU O3OCLiUWW«>,EUHO HWHZZtOO'-'WZO
(NQfNXHOCJO COH Q&H&JEHZEHO3E3OOO3 «i£Htt;HMOOSS 03WCQ
AHAhJiJO >H WO Z O«*WlOOi-)« miO(i.1Z^WM>H i-5O3
*— ' U "^^ •aJ^isEHX CJ DZUCUt* -3Oi-^OU^'"**
«! MHIU63 OW OO OO i^EH WQ WMOi-)iJMO-*EHQZZ^>-iCQ'< tnZW»— lEft5n*JEHO
Q3OO3EH pc^Oh^ CXiH HO3hjO'*C'^ICciW«tIX W<;fHC_J &jR»-? «BHO MEH Hi(OO
CQZCQHC2 CQm ^JW lrt(JIX-CU UHZUOOafc.|fc
-------
147
0>
H
3
-7 £
rX3
-
£
o
.
H
1
*
•M &H
nj O
| W
CJ
i
>"
CJ
2
CC
•3
fc
—
ce U
O «c
«; CS
CC ID
W CM in
w w D
> •< a
W ,J O
CD -— — ' DJ
CJ
6-, Cq [y «£
^-" E-» fn ^
>-! i-l U
Qj Q E E Q
W M t/j to W
_ Z to H
5>-.Bw:nwww
S£ rt; U fci ^J 1-^4 t-^ W
S5 ^-4 ^
^°£-»M«Sz
rj &J Z «I3 ''e5ZtKj
EH«CW(BixOOU
OWHWOMwS
cua,CL. fca,atuix
OOOOOOOO
tnLnm^LnLninm
-cNon^uovo^co
m
T—
CO
r
D
aa
a
o
u
0
o
^
^3
M
E
z
H
>J
*^ » 1
CD O
M
Z Q
02 Z
.— * D *C
IS — CQ
Z O CC CJ
W (J MM fc
« EH Q hJ «C ^~ 02
W z Z H IB DS «S
H to 3: CC CQ H to
*-3 *~^ ^ W ^^ «!,' "*^
M O ^ CC
EH c/5 Z O D 10
OJ£HM wzEHf-nc)
Wz>-i EHHrtZZ
^JQ e>:cco~'_i«
W pi ^^ z f-^ W CU C3
EH H C/) CJ CJ EH
Swo w£SSwS
D EH 03 U O H D
EQH SSrt^QE
S z «H Z CJ EH Z
M»airn SO !-}•<££
z ix a a ce < cj
OZIO COJC-CEZO5
E«33 tHMDC^ffiH
cua,(x aixa-a.ci.a,
ooo oooooo
mmin unirimmmm
r- T—
0
OJ
00
T—
O
-d
CB
ro
>H Z
O EH £
EH «! O
«C ,^ CC H
CC U O EH
W Z >H 10
CC Z ^ W CQ
W h-t CJ O E
> ft* Z O
w w H «so in .—
CC 03 >-l fcj E-i c/)
*-^ O h-l C/] Z C/l
O «c a: i-! fc o
M a: in cc
t>!=< ^wS ^iF
DMH WCJCQ ^JZ
OfHCC CJOCJE *^ M
cowtn aaojMco ce H
Q« E ^ O *~^ t/^ C/^ W CJ CJ
COE EH W< EZi-J
:D COU>H •-'c/)cjz
ZO3O3 QWOCGCJ C/l^'H
HWW zzcewzcjcaw in
Soo o e> w >-! S w In « § o u
"*!UU ^S^o^zwu^^S
K ** M 2.^J 0 * M to 0 S § " ^
"3! >4] <4 t — 1 CtP »_4 CJ Q3 O *^* ^ rT1
Q O Q CO E t—3 ^ *^J tE Oj 32 O EC FH
HZ25Z (B O03 to OiCQOiM
zooo WQcawa^EH^Ojco^.)
«BWW(O MWWMWi-lCBCaDXW
ti.o.cuft, cucLd.a-ci,(i
-------
^
•
""O
•.
4_)
d
0
3
B
LO
H
1
"*
CD
i— 1
'S
H
CD
t^
a
$
P
CO
1 — 1
r— <
o
(X
•H P
•P Si
as o
i-H M-l
1' w
^
al
M
o
H
in
£T
03 M
(J QuCCBZH Z C
HU^ ««J03 rtZNQ
< a w a w H w
XjJ^WXEHZh-ltSJXW
O W««««H >H>I«I!
cazo>Jciine>o3O3ci^
O03OSI Z«S.«8Z<
E-iQ3E-i««:U«OZHHUH
tD«SHQ3Wi-jMK«WZ
«euooinu>c'iii1'(n«!
ooooooooooo
OOOOOOOOOOO
*~"rN)nnju~)v£>[ OOC^OT—
o
PO
CO
—
O3 .
w w ^
H U SE
03 *G2 O
Q Z H
Q3 E-I
0 B ^ tn
Z t, _ W p
^ «t W U CO
W U U •< JC
u in o3 M: z o
•<: 03 ^ XBS: u &<
O>J WJE OO'^'^'W \E-i\O
E-IH tuinKH«;Ojin in«cw EH fc-i CL <
BE-i £i t/^«JQ3 E-i EiZE-l CQvjOCQ *"* ^^ *-} in
oainx J r: M w w H z z CB >j w (H u z
HO3 WB&-<^ O3W
1 C) O EH *" H*(S!W i-l r; in H «; z H H i-J rs o o •* m t/i cc «c ce u
H O3 WO3(JHin inx /\ r- V O W W iJW
lOX XXUHHDj OX —"-••— -On to UQU^E-1
«t; ,J «sj«!Q3 OBS5 ZiJ«! [/ItntO **W ^J 03 «S U W B
O3QP3 QQCuE-i|-3ajoos ^cr:«so
CQUin-J ta M HQ3WHx
Q3iouiotnint-ciQ.*H Mfcin « CQ 03 u o, fc, jtnuzaa
EEJCErrE^ECoO OOO OOOOOOOOOOOO
ooooooooooo ooo oooooou")uitf">if)Lr'u~)
OOOOOOOOOOO OOO OOOOOOtNfN(NrMrM(N
T^CNrO^-LO^or^OOCTlO^" ^"CNOO T~(NfT13'Ln'i'^t COCJ>O^~
T— *^ »— 1—
iT^ O tT) O
m a- 3- ui
00 00 00 CO
-------
149
^-^
id
-
4J
C
O
u
s-'
.
LO
1
u
i — !
'cfl
H
f)
^
P
o
CO
T3
ni 0
-o X)
rt 3
•*— ' -2
co
•M
T-H
r— I
O
OH
•H •(-"
•M !-.
cU o
O
^
ni
£
W
3 O
Q H
EH
Q H
Z Z
<3 O
H
W *"-
^ H 0.
>n Q CO
H W W W
EH Z O Z
"~ ST CJ £? Z 1?
U z z to cc z
M M [d CD D W
a >-J t/i fc t^.
E^ ,~ Z H W Z
CJWUOU K HO
..^ W dj Z fH B t/) M
CC vJt-Hl'HfHO O «CEH
cc ,•-* w cij ^ to o z t— 5 c/)
CO \, 03 *~* ^"^ C**i B OS *tf CD B
03 so: OCQPJ >— CQ
OOEH^COCOy; t_) E
EH Z CQ O W W >J O >* M CCO
«C M HZZ*5OB* O WU
P3 t/) \OCQMW3C »-J *-^ EH
WlOWCOCOCBi-lU iJi-5
M CJ "-WDCDEZQ W EZ
U o xoHEHfHCcwtj) p loce
-S 03 O O ^~ >~' W EH Z Cn pi]
M OjZ^"XCOCO fH*CH QE^
MlonfljKtJUZi-^fcC CD Q«-i:>HZSM CQ E >iQ3
L?O 03 -J "tWCBCBOOUO iJ CB 03QO
OC/lOSWWWhiM H^«S W DZH
ECCO&JfJMkJMfHEHhJfH^ja^ ^ Ci-lOfH
EH«:zrtiHM<-l!«SH M
W «- »- > CD P3
0 X X O E W
>- o o WE
x «- in w co E
0 1
n^ C-1 ^— ' c^J u p^ i r^ cj
m^r-r-oocor. cnor-r^
-------
150
S~ *s
•
*"O
-M
c
O
Cj
*
i-O
1 — 1
i
•
•iH 4-J
•P JH
rt o
5 m
3
u
s
^^
03
^~ B *~»
ce X o=
!E BE
X EH V
» in m D
EH ce EH
03 O ^ 03
EH U
VO «fi O \£>
w (B «- w
o u w x o
«- z z o T-
X H H T- X
m x u in
• U z ro •
O EH H . o
v «J o v
••* 03 _3 -"-*
^
in EH Cu tO tO
CS J M CB 03
w «s u w w
J EM J iJ
M Ou Z MM
O to B O O
CQ •< Z3 ffi 03
uouuor.se
E U E DC t_) 0. tu
o in in in o o o
o ^ Q
EH ^
M
»J to ^^
M m tn
f ( IJgB p^J
C .^ M W
W CD tJ
U Z Z 0
r- M W O
O-- iJ u
E- Z
O W O 03
t^ PJ (^ CO
M H EH v:
63 pu to Z
— "-" D M
CQ iJ
10 10 E U
W w o in
2. Z U •• 03
H M in O
03 03 iJ z EH
C. tc «q ^ «t
B B Z ,~M K
EH H PC W !>c; W
W E «-*S5
W) in EH M M
«: •* z iJ t/5 U
O C5 H 1 EH Z
rtl Z M
>-* >H >H Q «t
a; 03 03 o hJ rj
<«3 «i; «*; 10 cu -4 B3 En
in «s 10
tO CLi Q
«! O Z Cl
C5 *<
03 IO IO
w in to z
CD <
•rl 0)
i — 1 r4
f| td
•H
CD
o cu
•H
• I — 1
o a,
^ 0
•H
Tt
rl ^1
to
d o
n) f5
4-)
C/] •*
CO
PH
• CO
IO 2
1"-.
vj ' ' }
i — I Co
ri
P CU
•ri T3
0)
4-1 M-l
U
01 4-1
"4-1 CD
U-l VH
a) -H
M-l
•ri 0)
Q) 4J
W
O CD
4-1 -H
^X) PJ
co S
CO 5) rH
iH a)
1 tO •
o) !3
0) T)
43 Clj CD
n3 t) CU
H CO
•> 4-J 3
ON OD O
CO
>. CO
00 (3 &
a) -H cu
4-i 4-J C
cd 02
iJ * o
nt ' _o
-------
60
151
CO
CO
CO
o
50
40
30
20
10
0
-10
X
X
CO
_J
-20
-30
-40
-50
1975
Fig. 4-13.
I960
1985
1990
YEAR
Combined Pollutant Emission Projections for Stationary
Sources with NO Emphasis (Strategy 9) .
-------
152
80
70
1990 STATIONARY SOURCE EMISSIONS
BASELINE PRIORITIZATION
5 10 15 20 25
STANDARD SETTING RATE, NO./YEAR
30
Fig. 4-14. Emission Projections as a Function of Standard-Setting Rate
-------
153
Strategy 14 is a simulation of the effect of parallel versus serial
standard development as discussed in Section 6.2. This strategy shows that
developing a larger group of standards simultaneously with the same resources,
assuming that the time between groups of standards is larger although the
average number of standards per year is constant, results in a small but
measurable increase in projected emissions.
Since only sources that initiate construction or modification after
the standard promulgation date are regulated by the standard, there may be
a time lag of up to 4 or 5 years before these new regulated sources are in
operation and the emission control is effective. This important consideration
was approximated in Strategy 15 by assuming that the effect of any new standard
from the baseline Strategy 4 would not be in effect for 2-1/2 years. (This
is equivalent computationally to not allowing standards to be "set" for 2-1/2
years after 1975. The date a standard is "set" is then the time when the
standard's effect is noticed when in actuality it was promulgated 2-1/2 years
earlier. The effect of existing standards was approximated to begin in 1975.)
The emissions from this simulation shown in Fig. 4-15 are significantly larger
than when the effect is ignored and is probably a more realistic estimate of the
actual emissions than is Strategy 4. The addition to this simulation of
transportation emission projections from Appendix A is shown in Fig. 4-16.
The total NOX emissions relative to 1975 are less than for point sources
alone, but still more than a 16% increase by 1990. The relative total
emissions for HC and CO are considerably less than for point sources alone,
but there is little difference in TSP and S02 projections resulting from the
addition of the transportation emissions.
Strategy 16 simulates the impact of setting standards for all pollu-
tants emitted by a source category at the same time. In effect, when a source
is scheduled to have a standard set for its priority pollutant, the constraints
on all other pollutants are relaxed so that all may be set simultaneously.
(The exception is the fuel switching and research and development constraints
which are still maintained until 1985.) The advantage to this procedure is
that economies of effort may be achieved through the use of common data
for all pollutant standards. In part (a) of the strategy it is assumed that
each additional standard requires 25% more effort than the initial priority
standard. In part (b) it is assumed that 75% more effort is required for
-------
154
CO
CO
CO
60
50
40
30
20
10
-10
-20
-30
-40
-50
1975
I960
1985
1990
YEAR
Fig. 4-15. Combined Pollutant Emission Projections for Stationary
Sources with Delay in NSPS Impact (Strategy 15).
-------
155
to
O
en
CO
60
50
40
30
20
10
S02-]
a:
o
-10
-20
-30
-40
-50
1975
1980
1985
1990
YEAR
Fig. 4-16. Combined Pollutant Emission Projections for Stationary
and itobile Sources with Telay in NSPS Impact
(Strategy 15).
-------
156
each additional standard. Comparing these results to the baseline (Strategy
4) show very little change in hydrocarbons, NOX, and SC>2 with improvements in
the emission pattern for particulates and CO. This is true because the
priority emphasis placed on hydrocarbons, NOX, and 862 has not been altered
by very much. Standards for particulates and CO, however, are accelerated
by being tied to the higher priority pollutants. Assuming a .75 effort
increment instead of a .25 increment (i.e. Strategy 16b. compared to 16a.)
produces only small perturbations in the emission pattern. It is evident,
therefore, that this strategy could be used to effect standard development
cost savings with a minimal impact on emissions. This procedure would apply
to about 62 industry categories.
4.8 SPECIAL PRIORITY AREAS
The combined pollutant priority ranking just described relied on the
use of objective emission reduction criteria to determine the pollutant that
should receive priority consideration. The special priority areas of emphasis
of Section 3.3 outline other considerations that can alter the ranking. By
making these alterations, it is evident that gains in emission control for
the priority pollutants or industries will be made at the expense of others.
The question of determining the magnitude of the penalties can be answered
with the emission projection model. The more crucial question of whether
the penalties are acceptable in light of the priority needs can only be ans-
wered by an evaluation of national environmental control objectives.
Using some of the information previously discussed as well as some
additional computations, Table 4-16 summarizes the emission control benefits
and penalties associated with the special priority areas of emphasis identified
in Section 3.3. The baseline case against which these are measured is a criteria
of no emission increase over 1975 levels for all criteria pollutants except
NOX. For NOX, the maximum achievable reduction of 44.4% is set as the criteria.
This baseline, then, is identical to Strategy 4 in Section 4.7.
For the pollutant priorities of Section 3.3.1, it is possible to dis-
criminate between priority pollutants and nonpriority pollutants. For the
strategy priorities of Section 3.3.2, this is not always possible. In such
cases, all pollutants are considered nonpriority and the impact is determined.
In all instances, the measure of benefit and penalty is the change in the
-------
157
Table 4-16. Impact of Special Priorities on Stationary Source Emissions
Pr
1 .
2.
3.
4.
5.
6.
7.
8.
iority ^rea of Emphasis
Nitrogen Oxide Control
Hydrocarbon Control
Particulate Control for
NAAQS Attainment
Air Quality Maintenance
Fine Partriculate Control
Sulfur Oxide Control for
NAAQS Attainment
Air Quality Maintenance
Sulfate Control
Nondegradat ion Source Control
F-merging Industry Control
Energy Conservation
A. Accelerate conservation
standards
standards and prohibit
fuel -consumption- increasing
standards
f
Noncriteria Pollutant Control
All Changes Measured Relative to
Priority Pollutants
Change in Max. Change in 1990
Emission Rate Efficiency Ratio
(103 tpy) (%)
NOX -120 +1.7 TSP
S02
HC
CO
HC - 75 -H.3 TSP
S02
NOX
CO
TSP -262 +7.7 S02
NOX
HC
CO
S02 ~385 +1.5 TSP
NOX
HC
CO
ISP -130 +0.7 NOX
S02 -225 +0.9 HC
CO
rsp
S02
NO
HCX
CO
TSP
SO 2
NO
HCX
CO
ISP
S02
NOX
HC
CO
Data limited on noncriteria TSP
pollutant emissions S02
NOX
HC
CO
the Baseline Strategy
Nonpriority
Change in Max.
Emission Rate
(103 tpy)
+100
+335
+233
+243
+108
+710
+582
+ 125
+571
+424
+452
+636
+107
+317
+307
+434
+525
+541
+ 592
+ 14
+ 67
+ 2
+ 24
+ 78
+ 9
+ 44
+ 60
+ 4
-838
i n
— 1 U
-214
+ 97
- 9
-838
+ 85
+103
+ 17
+106
+265
Pollutants
Change in 1990
Efficiency Ratio
m
-3.2
-1.7
-1.1
-2.2
-3.3
-2.7
-8.4
-2.4
-2.2
-6.1
-3.0
-4.1
-3.3
-4.6
-J.8
-3.1
-7.6
-3.5
- 2.5
-0.4
-0.3
0
-0.1
-0.9
-0.3
-0.2
-0.9
-0.1
+6.9
n i
u . j
-1.5
-1.4
-1.0
+3.4
-6.0
-0.4
-0.3
-1.2
-5.8
Baseline is chosen as Strategy 4, Table
bStrategy 9, Table 4-13.
""Strategy 6, Table 4-13.
Strategy 5, Table 4-13.
eStrategy 7, Table 4-13.
Strategy 12c, Table 4-13.
4-13.
-------
158
maximum emission rate and in the 1990 efficiency ratio relative to the
baseline strategy.
4.8.1 Nitrogen Oxide and Hydrocarbon Emphasis
These pollutants were identified in Section 3.3.1 as having priority
consideration. The baseline strategy discussed in Section 4.7 reinforces this
conclusion. By imposing a zero emission increase criterion, both pollutants
are ranked near the top of the priority list as a result of their high growth
rates without NSP'S controls. The first two cases on Table 4-16 show the
impact of further emphasizing each pollutant by imposing tighter emission
reduction criteria on these compared to the other pollutants (see Strategies
9 and 6 on Table 4-13).
For NOX, a reduction in the maximum emission rate of 120 thousand tons/
year over the baseline case is possible with a corresponding penalty of emission
increases for the other pollutants. Most seriously affected are SOj, CO, and
hydrocarbons, which will experience increases of 335, 243, and 233 thousand tons/
year, respectively, in the maximum emission rate relative to the baseline. Par-
ticulate emission control will suffer the most in 1990 with a 3.2% reduction in
efficiency ratio relative to the baseline. A judgment as to whether the reduc-
tion in nitrogen oxides is sufficiently warranted to justify these penalties
must be made prior to adopting this strategy.
Emphasis on hydrocarbon control could reduce the maximum emission
rate by 75 thousand tons/year, but only with a severe penalty to NOX control;
the maximum emission rate of nitrogen oxides is increased by more than half
a million tons/year. S02 emissions increase by more than 700,000 tons/year.
This result is primarily due to the fact that large increments in the control
of HC emissions are achieved only through the control of many moderately-sized
industries rather than a few large ones. The development of many standards
takes more time and results in substantial delays in the development of NOX
and SOa standards. This is evidently a poor change in priorities if NOX control
and HC control are to be considered of equivalent importance.
4.8.2 Partioulate and Sulfia1 Oxide Control
The emphasis for control of particulates and sulfur oxides was
identified in Section 3.3 as the result of the need to augment NAAQS attainment
-------
159
programs and the air quality maintenance planning program. Particulate control
can also be viewed as stemming from the need to control fine particulates under
the assumption that the setting of a particulate NSPS could be geared to con-
trolling particle sizes also. Likewise, S02 standards can be tied to the need
for sulfate control.
Using a more stringent emission reduction criteria for particulates
and S02 (see Strategies 5 and 7, Table 4-13), a reduction of 262 and 385
thousand tons/year, respectively, in the maximum emission rate could be
realized. The penalties would be more than 400 thousand tons/year for NOX
and HC with particulate emphasis and over 300 thousand tons/year for NOX
and HC for SOa emphasis. The NOX penalty is not as great as for the increased
emphasis on HC, since substantial emission reductions are achieved through
control of a few large particulate and 862 sources with shorter time delays in
the starting of work on NOX standards. Nevertheless, the impact on NOX and
HC control is significant and must be weighed in the light of requirements for
control of these pollutants.
4.8.3 Won/degradation Source Control
Table 4-17 lists those sources currently identified for control under
Q
proposed nonsignificant deterioration regulations; the emphasis is on par-
ticulate and S02 emission reduction. Some of the sources have NSPS set already,
hence the emphasis for NSPS development in support of nondegradation regulations
would be on setting standards for the other sources and perhaps revising existing
standards. To determine the maximum impact of accelerating the development of
these standards, it was assumed that all new or revised NSPS for these sources
would be set prior to all other standards. Fuel switching and research con-
straints were maintained, however. Using the nominal standard-setting pace
of 22 per year, the necessary new and revised standards could all be set by the
end of 1976.
It is evident from the data on Table 4-16 that accelerating the pro-
mulgation of standards for these industries will incur an emission penalty
for all non-priority pollutants. Particulate and SC>2 emissions experience only
relatively small decreases in the maximum emission rate.
-------
160
Table 4-17. Source Categories Considered for
Nondegradation Controls of TSP and SO
Source Pollutant
Boilers (>250xl06 Btu/hr)3 TSP, S02b
Coal Cleaning Plants TSP,C S02
Kraft Pulp Mills S02
d e
Portland Cement Plants TSP, S02
Kilns, Clinker Coolers
Concrete Batching
Primary Zinc Smelters TSP, S02
Iron and Steel Mills ,
Basic Oxygen Furnace TSP
Electric Arc Furnace TSP8
Sintering TSP
Scarfing and Rolling Mill TSP
Primary Aluminum Ore Reduction TSP
Primary Copper Smelters TSP, S02C
Municipal Incinerators TSP
Sulfuric Acid S026'8
Petroleum Refineries
Fluidized Catalytic Cracker Unit TSP
Process Gas Combustion TSP,S S02
Lime Plants TSP, S02
Phosphate Rock Processing
Grinding TSP
Drying TSP
Calcining TSP
By-Product Coke Oven TSP
Sulfur Recovery
Refineries S02
Oil and Natural Gas Production S02
Carbon Black (Furnace Process) TSP
Primary Lead Smelters S02C, TSPC
Fuel Conversion Plants i
The proposed regulations cover only boilers > 1000 x 106 Btu/hr. This dis-
aggregation is not available from the Model IV data so all the large boilers
are included and considered for revised NSPS .
Subject to fuel switching constraint (FS) .
£
Standard recently promulgated.
It is assumed that regulations must be adopted for all operations in the
plants,
Subject to research required constraint (RD) .
Existing standard.
gRevised NSPS.
The proposed nondegradation regulations cover only incinerators > 250 tons/hr.
Data not available.
-------
161
4.8.4 Emerging Industry Control
Table 4-18 lists the emerging industries considered for special NSPS
priority. Since only a few standards are involved, the impact on the overall
NSPS schedule is minimal. Table 4-16 shows that the maximum impact, resulting
from setting all these standards before any others, changes the 1990 efficiency
ratio by less than 1% for all pollutants. The indications are, therefore,
that the allocation of some resources to the development of emerging industry
NSPS can be tolerated without serious disruptions to the total emission control
program.
4.8.5 Energy Conservation
The restructuring of the NSPS prioritization to accommodate energy
considerations can take two forms. The first is to accelerate the promulga-
tion of standards that result in energy conservation through their implementation.
Included in this group are sources with Factor 7 on the standard industrial
evaluation form (Fig. 3-1) rated as 0. These sources consist primarily of
evaporative loss sources (e.g., petroleum storage and handling) and sources
that are controlled through the use of an afterburner that requires no additional
fuel input and from which heat recovery is possible. The second form of
energy conservation consideration is to delay standards for all sources that
would incur energy penalties (i.e., Factor 7 rated as 2 or 3). Specific
source categories falling into these two groups can be identified from Tables
4-2, 4-4, 4-6, 4-8, and 4-10.
Table 4-16, Case 7, gives the impact of energy conservation con-
sideration on stationary source emissions. In part (a), standards for the
energy conservation sources are promulgated prior to starting any work on
other categories. A total of 25 standards are involved. The change in
emissions over the baseline case is relatively small since most of the stan-
dards set are for hydrocarbons and NOX, which are emphasized in the baseline
strategy anyway. The CO emissions drop significantly due to the early standard-
setting for the carbon black, ammonia (regenerator and CO absorber), and
charcoal source categories.
In part (b), the standards for those sources that would require
moderate or heavy increases in energy consumption are delayed to some time
later than 1990. As before, the emission impact is small. The clear indication
-------
162
Table 4-18. Source; Categories Considered for
Emerging Industry Priorities
Source
Pollutant
Stationary Gas Turbines
Pipeline
Electric Utility
Sulfur Recovery Plants
Refineries
Oil and Natural Gas Production
Sewage Sludge Incinerators
Mixed Fuel Boilers
Oil and Refuse
Coal and Refuse
NOX, CO
S02
S02
TSP
TSP°, S02,C NOX
TSP, S02, NOX
Subject to fuel switching constraint.
Standard already set.
'Subject to research required constraint (RD)
-------
163
here is that the reordering of NSPS priorities to minimize increases in
energy utilization can be achieved with only minor emission penalties.
4.8.6 Nonom-teri-a Pollutant Control
Case 8 on Table 4-16 shows the effect of allocating some resources
to the development of NSPS for noncriteria pollutants. In this instance,
the number of criteria pollutant standards is decreased from 22 per year to
18 per year. Only a limited amount of data was available to assess the possible
benefits in noncriteria pollutant emission reductions; however, the increases
in criteria pollutant emissions are nominal. There appears, therefore, to be
some margin for diversion of resources without the need to create intolerable
emission increases.
-------
165
5. EMISSION CONTROL TECHNOLOGY: LIKELY NEAR-TERM PROGRESS
The timetable for setting New Source Performance Standards (NSPS)
has already been shown to depend on new developments in the capabilities of
control systems. Ongoing research and development programs in EPA's
Industrial Environmental Research Laboratory and elsewhere are designed to
advance the technology of measurement and control, thereby permitting both
the development of performance standards for source categories not previously
covered and the modification of existing standards. Consequently, an informed
prioritization scheme for setting NSPS should attempt to anticipate technologi-
cal developments and to provide for timely incorporation of improvements in
demonstrated technology as they become available. In addition, the analysis
of priorities for setting NSPS can be used to identify deficiencies in the
research programs, as critical needs for improved control technology are un-
covered. The aims of this section are to describe the ongoing research pro-
grams in air pollution control technology and to indicate expected tech-
nological developments on the near horizon.
Descriptions of research programs on control systems can be found
in many sources, including journal articles, laboratory reports, and company
publications. Only technological developments carried through demonstration
testing in industrial plants are included in this review. Unfortunately,
many reports of research programs on control systems give no indication of
when commercially proven technology will be available. Most of the informa-
tion on which the development schedules given below are based was obtained
from achievement plans for research programs of the EPA/IERL, ERDA, EPRI,
and from other publications in the open literature.
5.2 EXPECTED DEVELOPMENTS IN EMISSION CONTROL TECHNOLOGY
5.1.1 Sulfur Oxides Emission Control Systems
Sulfur, emitted to the atmosphere as sulfur oxides, results largely
from the combustion of sulfur-bearing fuels, with coal combustion accounting
for about 60% of the total. At the present state of the art, three methods
are available that can effectively reduce sulfur oxide emissions: 1) switching
to a low sulfur fuel, 2) desulfurizing the fuel, and 3) desulfurizing the flue
gases produced.
-------
166
22
Based on a recent survey of control technologies for sulfur emissions,
flue gas desulfurization (FGD) appears to be the only viable alternative
(through 1980), other than the burning of scarce, clean fuels that can meet
the current regulatory specifications. Desulfurization techniques for the
production of clean fuels are not expected to make a substantial contribution
until after 1980. Therefore, in considering the near-term needs of the country,
the continuing development and implementation of FGD technology is of considera-
ble importance.
The major division in the present FGD technologies is between regen-
erable processes and non-regenerable processes, as summarized in Table 5-1.
Since the descriptions of each of these processes are presented in a great
number of publications, they are not discussed in detail here. Descriptions
of these processes and information on their performance, reliability, opera-
ting experience, relative advantages and disadvantages, and their SOa removal
23-25
efficiencies can be found in a number of status reports. In addition,
9 f\
proceedings devoted entirely to this subject are available for general
reference.
Some of these processes have been operating successfully In a number
of commercial plants. The installations include steam boilers, oil refinery
Glaus sulfur plants, sulfuric acid plants, copper smelters, and iron-ore
sintering. The units range in size from 5 Mw or less to as large as 250 Mw.*
Present progress in this area is advancing toward design and construction of
units 300 Mw and larger. All of these FGD processes are expected to find
widespread commercial use within the next few years.
In addition, many other FGD processes that were not as well known
ry r
before the Atlanta symposium are gaining recognition. These are the Foster-
27 28
Wheeler Bergbau Forschung process, the Citrate process, the Consol Stack Gas
29 25 30
process, and others. ' Since most of these processes are still in early
stages of development, significant contributions are not expected before 1980.
*A11 plant sizes are expressed in megawatts (Mw), on the assumption that
1900SCFM of wet stack gas corresponds to 1 Mw.
-------
167
0)
0)
03
cd
O
^
o
cd
4-1
CO
g
o
M
MH
rH
CO
£>
O
g
0)
Pi
CM
o
CO
M
o
(4_|
01
rH
^o
cd
rH
•H
cfl
£>
•<^
j>j
rH
4-J
C
0)
M
M
3
O
O)
O
^
4-1
0)
J^J
MH
0
!=-.
cd
g
£3
j3
CO
.
rH
1
m
QJ
cd
H
G
O
•H
4-1
p.
•H
M
O
CO
0)
0
03
CO
Ol
O
O
M
p ,
CO
4-1
a
3
T)
o
M
p,
p^
fd
TI)
O
^
4-1
a;
S
g
0)
4-1
to
J>^
CO
M-l
o
oo
£
(|_|
n
n
3
M
cj
CO
4-J
QJ
|5
Cfl
>
iH
Q
>
a
CO
CO
0)
o
$H
fX
QJ
c"|
H
CM
O
CO
-a
0)
4-1
cd
M
4J
rj
0)
a
G
0
0
c
o
4-1
M
O
CO
T3
cd
O)
c
•H
H
cd
K^
rH
Cfl
1
4J
0)
^
^
i — l
01
r-H
| /"i
CO
M
01
C
0)
00
0)
ai
G
O O 4-1
4-J cd
O) ^ • cfl T3 4J
0 M 01 M ' — ) i — 1
•H M 4-> Ol Ol 3
i — I 3 *H C *H CO
cd rH MH QJ ^ o)
rM CO I 1 00 M
r-H 3 01 0
Cd Ol 03 M 4-1 0)
TJ iH rG
03 *rH rQ i — 1 0) E"~f
3 X cO 4-1
O O M g *H
Ol O !-i MH •
3 g Ol i — t g
CJ1 3 01 rG 3 cd
cd -H 4-i 4-> co oi
CO vH -H M
Cd G rH ,0 03
00 3 M
r| cd CO T3 O c>j
4J g 01 O
•H CO ^ QJ CO
^ cd cd O 4—)
rH "rH "~^
en j-i csi rH MH cu
QJ O O O ' — 1 -M
CO CO M-J 3 fl3
d C co j-i
00 O 0) CO 4J
•H J-( *H Q) C
r^ 4-* 13 ,-C CJ
o ^ -u co -M a
cd t-H PH *H (13
-I~J O cd r*~! ' i i o
CO co O H O O
g
Cg
0)
M
4J
03
to
cd
00
c
o
•H
cd
0)
G
cu
00
0)
M
i-H
cfl
e
M
0)
1-C
4J
*Td
G
cfl
1 01 0)
rH 4-1 M
3 -HO)
CO M-4 ^»
• i — 1 O
4-J ^ 3 CJ
a -H 03 01
cfl O M
4-J Cd 4-1
C o G cd
O OO 4-1 TJ
CT» i — 1 G
cfl 3 cO
00 03
O G 11 **
4-1 -H M CM
U O
i-^ ^ QJ CO
Q) T3l rC
J^ ^_J , — 1
O (X CO QJ
fX CO -H
CO 4~* OJ ^**
ceo
cd cd o o
J_l tH J-i JJ
-U PH O-t
T)
QJ ^ O QJ
rQ tp-j 00 f^
U S »H
C cd o
cd QJ iH
o o ,n cd
•H -u a
CO H
cd 3 c co
00 IH M -H
id
QJ
rH
cj
K*^>
CJ
QJ
}_i
CO
*H
O
&0
s
>,
iH
4-1
CO
Q
S
00
c
•H
0
«H
cd
4J
p^
o
a
^
JH
^j
rH
CO
i / — •
G 3 O 4-i
o G C 03 O
MO Ol cfl 43 3
TdO-H ^3g •>4-'rd
01 4-1 01 CX -H O
o x — \ cd f~i M 0) 0) J5 J-i
MOM O g 4-1 {X
O 3 0) M O 03 4-J
03 O G 0) TI) CO O CU
T3 o) rG *H G cd i — t
CdC0004-IO OCll^Q
Cfl O) 'rl Cfl • 'H M Cfl
CO MO) M 4-1 0)
•H f~! O 3 cd G rH
O 0) ^~-i *H MH 'nJ cfl cd
03 SrCcdMrH'H OCO
Cfl 03 4-1 g 3 3 X
00 ^-^ MH 03 O *X) Cfl
G "N i — 1 Ol N^x
^ 0) rH O 3 i — I 0) O
O ^ CO 03 Cd rG 3 £5
cd -H 4-1 4-J T3 3
4-lX-rOTJC O03
WOGOlrHOIMMfX
O) I — 1 rQ 3 "H 0) MH 00
p£jcflM4-*E>i! — IO1T3
4J 4-1 Cfl O. OJM-Hg
0) O cfl o . CX O M
G g O 4-J O cfl O
•H T3 4-J 03 MH
cd 01 O) T3 MO)
CM 4-1 f~1 QJ rrj (L) f~] O
OMcd4-)NOIM4J4-J
CO 0) > -H O 3
f. -H P.T3 34-14-1 a)
0)4-i4-iO)'HrOOcdg
r^ *rH O 4-) ^ QJ Cd P] »pH
HO)CdCOOMMH4-lrH
CM
O
C/3.
T3
0)
4-> g
cfl cd
M 0)
4-1 M
OJ W
O
G w
O CO
cj oo
G
o
•H
4-1
a
M
o
CO
TJ
cd
t*->
M
o
.
CN
•
Ol
M
CO 3
Cd 4-J
oo cd
j_i
oj QJ
O f"Xt
CO g
01
4J 4-J
CO
K^ J~l
I— j (j£
cd *H
4J &
O 4-*
cd
cd
MH O
O C/l
QJ O
U 4J
pj
QJ T3
CO QJ
QJ 4-t
V-* rH
P-t QJ
>
r^H O
4-1 O
d CO
M -H
O
•H
M
3
MH
rH
0
to
M
0
Tl
O 0
co cd
o
•H
4-1
cd
T3
•H
X
O
O
•H
4-1
£*•>
rH
Cfl
4-1
cfl
O
.
m
M
1 4J 0)
4-J 03 >
CO -H O
•H g 4-1
O
g -3" 13
O Ol
rG CO *•*]
4-1 CM O
•H K cfl
a ^
4-J O ,-G
Cj MH 4-J
cd
oi o G
M 4-1 *H
m CO 4-1
co cd ^
co oo o
QJ Fbtfi n^
pC CJ QJ
4-» cd ,-Q
4-" rO
QJ CO 3
CO JH
cd QJ O
O ...fi CO
4J
CO CO
•H C *H
rG "H
4-1 4-1
QJ cd
G ^-1 f~!
M 3 4-1
O
4-1
g
cd
M
1 i
CO
rrj
•H
CJ
cfl
T)
01
1 i
cfl
rH
CJ
M
cj
Ol
01
~j
rH
•H
cd
^1
rQ
•
rrj
•H
O
cfl
gs°
O
oo
rrj
rH
0)
•rH
>.
-------
168
T
T)
4J
C
0
U
•
,__(
1
0)
cfl
H
C
O
•H
4-1
ft
•H
a
CO
cu
P
CO
CO
cu
a
o
j_i
P-I
CO
4-1
O
3
o
S-i
ft
pq
*"O
o
4J
CU
S
g
CO
4-1
CO
>^
C/}
|
^
O
cu
4-1
Td
0)
CO
Jd
4-1
CO
0
0
id
pj
cfl
4J
CO
CU
Td
rH
O
cu
4J
CO
•H
•H
&
H
CU
60
3
CO
J-
O
O)
cfl
O
— .
ro
O
to
cfl
C->
CU
pi
a
4J
CO
CU
B
•H
i-i
CU
£3
•rf
hJ
-
0)
cfl
0)
C
CO
60
0)
1
Pi
O
>»
CO M 1 1
•H ^-i £5 1 cfl
3 O cfl *^3 CO
CO iH M rH -H iH
cd co f~{ t— i ^
60 4-1 Cfl O 4-1
CU 4J O
C\| £j Cl3 W Cj ^ •
^^ O £4 cO ""O ^""^
CO 4J CO -H O 4J
CO -H CU M O
0)0) 0) *uj ft 3
J3 0 ,13 CO 3 1 T3
H -H O 0) rH Td O
rH -H Pi 0 Pi rl
_ .C cd C CU ft
rH cfl CU CU
Cfl M •* ^ CO ,£* rH
£> O CO CO 4-1 ,Q
O 60 4J CU cfl
S CU *T3 CO CJ 4-1 0)
CU B 3 O O cfl rH
H CO ft 4-> CO
CM
O' ,*"! 4J • CO O cO
C/D 4-1 0) 4-1 "H CO v — '
•H S O ,C ^
Q •* nj ,5 ^ p^ g
•4H TJ o MH a) co
QJ S ^l O 4-^ pi ,
t*^ O J-j p^ CO ^»
60 ^3 O CO 60
rH S ^ rt O O >-,
O O O & -H -H S-i
Cl CO 4-1 Cfl 4J 4-1 T3
•H
rH
o
co
J-
o
CO
cd
o
M
0
60
c
•H
rO
Is
O
co
UH
O
pj
O
•rH
4-1
Cfl
M
cu
ft
cu
4-1
CO
0)
^
H
0
>
PI
•rl
CO
cu
o
o
^_(
ft
0)
H
j-
O
CO
cfl
c_>
s^
CO
o
CO
cfl
U
0)
c
•H
rH
cfl
»M
,— 1
cfl
01
^
3
O
P
CN
[ i rj
CO -H
^
•H ft
IK 0)
4J
CU CO
c~j
H pi
•H
• 4-1
CO CJ
ft Cfl
0 rl
rH
-a "B
4-1
cfl pl
rH O
0) -H
ri 4J
>~, rl
"al S
CO 13
O Cfl
r- )
° §
O
4-> -H
CU
60
T3
3
CO
60
a
•rH
rQ
's
O
CO
60
P! CU
T3 -H 1 4J
cu c cd cd
M -H M 4H
3 CO CU r-H
4-1 4J C 3
ft P! 60 CO
U CJ M 0)
^J
CO fl cfl -H
•HO MH
•H CO rH
CO 4-) "H 3
cd 3 co
GO rH rO
0 C 60
^i W 0 C
cd o) o) 4J
4-1 P» CO i — 1
CO *H 3
rH 0) CO
0) cfl f"1 CU
f~J ^ f_) ^_J
4J rH
cfl 0)
B • J3
0 CD ffi H
•*H O d-
X 3 2 ft
O cr cu
CO CO ^-1 4-1
O CO
•H O O
f^ rj (ij *r^
^ -rl "Z 4-1
^_l
0
CL)
B
r-H
^
•H
^
nd
4J
CJ
CO
0)
£_4
PJ
CU
4J
Cfl
•H
PI
o
•H
4J
rH
Q
CO
•
cu
60
rrj
3
T 1
CO
J-
Q
CO
cd
o
^
o
CO
rf
o
0
M
O
M— 1
o
4J
0)
pl
o
4-1
CD
B
1-1
CO
•H
C
o
•H
4-1
3
r— i
O
CO
cu
•H
r— I
ns
^
rH
cfl
T3
4J
CO
1-1
fl
cu
6C
CU
•f-t
0)
[~l
E-1
•
CO CU
. 60
l~~i TJ
3
0) CU rH
CJ ,£< CO
3 4-1
- CD T3 CU
Pl CO O Pl .'"I
•H CU rl -H 4J
cd a ft
60 O CO A
•^ J-l O -I-J 4~*
ft 4-1 rl -H
0 &
. CO ft MH
rl -H CU <4-l rH
XI 4-1 CO CU
o ^O
3 *4-H Pl •
M O O CU O
O *H rH 4-1
CO CO 4-1 Cd
a cd co >,
CU O T3 cd
Jhj o UH CU
O CU t3
^ CO § 3
T3 0) CD
CU CO 0) ft ^
rH 0) TJ >, O
cj a 3 60 P!
O ft O >, 0)
CU Cfl Pl J-< rl
J-i >n -H id cfl
•
B
0)
, — 1
^3
!-i
®~
f — 1
cfl
CO
0
CO
•l-j
Td
-------
169
Table 5-2 lists the seven basic processes used by suppliers in design-
ing commercial units now in successful operation. Among them, the approach
using lime/limestone scrubbing appears to be the most economical and acceptable
process for SOa emissions control. Based on current trends, technology avail-
ability, qualified system suppliers, and lead-time considerations, it appears
that the majority of FGD commercial installations through 1980 will be of the
lime/limestone wet scrubber type.
Table 5-2. Types of Processes Available for
Removal of Sulfur Dioxide from
Stack Gases.
1. Sodium sulfite scrubbing with thermal regeneration.
2. Lime slurry scrubbing.
3. Dual media system employing dilute sulfuric acid for scrubbing.
4. Dual alkali systems.
5. Copper oxide acceptor (dry adsorption).
6. Activated carbon (dry adsorption).
7. Catalytic oxidation.
One of the major problems inherent in the lime/limestone system is
the necessity to dispose of or utilize large quantities of a sulfur-containing
byproduct. With current efforts concentrating on throwaway processes, the
disposal of these sludges adds to the existing cost of fly-ash disposal in
coal-fired utility power plants.
Recent studies of FGD systems have emphasized processes in which the
SOa is recovered as a product of marketable value, such as gypsum or sulfuric
acid. Most of the processes in this category are used in Japan and many
have been demonstrated quite successfully with respect to system reliability
and SOa removal efficiency. With the installation of recent demonstration
plants, it is now possible to run economic evaluations of these processes
that examine the tradeoff between process cost and byproduct income or waste-
disposal cost. The ultimate choice among these alternatives will become clearer
as operating experience with the newer processes accumulates.
-------
170
In addition to FGD processes, front-end or integral processes for
desuJfurization of fossil fuels offer an additional prospect for SOa control.
The objective of these processes is to convert high sulfur coal into low
sulfur coal, premium liquid fuels, or pipeline-quality synthetic natural gas
of low sulfur content. Processes currently being investigated are: 1) physical
coal cleaning, 2) chemical coal cleaning, 3) solvent coal refining, 4) fluidized-
bed combustion, 5) coal gasification (both high- and low-heating value gas), and
6) coal liquefaction. Since most of these are either at the pilot-plant stage
of development or are economically uncertain, it is unlikely that any can have
a significant impact on the total national sulfur emissions before 1985.
Recently, other new concepts in flue gas cleaning have begun to emerge.
These are systems that can remove simultaneously two or more pollutants. Pro-
cesses belonging to this category are discussed in Section 5.1.4.
5.1.2 Nitrogen Oxides Emission Control Systems
Current investigations of NOK control technology can be divided into
two different approaches:
1. The more near-term approach involves combustion modifications
such as reduction of the peak gas temperature, reduction of
the air/fuel ratio, and alteration of the time-temperature
history of the combustion gases; the use of alternative fuels
with lower nitrogen content; and flue gas cleaning.
2. More distant solutions include pressurized fludized-bed
combustion of coal, fluidized-bed gasification/desulfurization
of residual fuel oil, advanced power cycles, and other novel
devices such as catalytic combustors.
31 32
Based on recent reports by Brown et al. and Lachapelle et al. ,
it appears that the most attractive near- and long-term options for the con-
trol of NOX emissions will be through combustion modifications. Bench-scale
studies and field tests indicate that the projected near-term goals (through
1980) for NOX control of all utility and industrial boilers (burning gas, oil,
or coal) can generally be attained with present burner/furnace modifications.
Table 5-3 summarizes the methods currently being evaluated for NOX
control achieved through combustion modifications. Plans incorporating
applications of these methods, covering all types and sizes of f urmices and
many different fuels, are now underway. The results of these studies
will provide a basis for the evaluation of combustion control technology for
major sources of NOX emissions.
-------
171
TO
C
O
•H
nj
O
,.
•H
13
O
C
O
•H
4-1
W
*?
e
o
M
3
O
?-i
"T1
iH
0
4J
a
o
u
o
^
o
M-l
rH
43
n3
, — |
•H
rt
O -H
U
X QJ
O UH
C
O
•H
4-1
O
•H
rH
cx
M
O
S
-o
o
4-1
(U
£
QJ
CT
•H
C
U
01
H
i 'H O
•H QJ
T3 O TJ
C ^ 'co
VJ •- QJ
,2 ,| -H
ui -o
O T3 tfl
C
O 00
"oi QJ" -H
•H 3 OC
cn o
QJ S -
CO P
nj C O
QJ 0 -H
S-J J^ 4-1
C 03 r-
M
0)
)-l
3
CC
)-<
OJ
a c
g 0
OJ -H
U
"ni ^a
a tu
P- LI
b
CO
0
CN|
|
3
^
§
a
rH
•H
o
-o
c
c
CO 0
03 -H
g
o
a
•H
cfl
W
tn
QJ
CJ C
X 0
QJ -H
O 3
C
o
-H
4_1
H
C co
O C
a o
H
OO 4-1
•H CJ
4-i *H
M H
QJ 1^
P. 0
0 E
00
c
•H
00
OC
c
o
4-1
3
"O
Jj
>•>
u
QJ
U
•H
w
QJ
5
LJ
OJ
a.
g
.,
U
OJ
•H
•H
M-i
>-H
g
LJ
QJ
H
QJ
3
l_i
QJ
D. C
E 0
QJ -H
0
QJ QJ
>*>
4-J
c
OJ
QJ
QJ
3
£
QJ
cx c
g o
QJ -H
(J
QJ OJ
PH ^
4J
0
C
CO
4J
c
tfl
D.
QJ
C
0
4-1
•^
-H
O
QJ
ctf
•H
CX >H
n3
o
> c
tj -H ^
QJ 4-j C
M-i 03 O
OJ 3 4-J
3^3
rH OJ O
< ^ u
a
00
-H
CO
u
id
c
o
•H
CO
0
VJ
0
o
"a
nj
00
c
OC
OC
1 — I
QJ
3
2
QJ
CX
QJ
-^
OJ
a,
c
•H
(j
3
QJ
J-i
OJ O ^ 00
-------
172
The methods mentioned in Table 5-3 are noteworthy as they can be
effectively utilized in combination to achieve very low rates of NO emission.
33 X
For example, tests on a 320-Mw corner-fired unit using off-stoichiometric
combustion have shown that nitrogen oxide emissions are reduced from 330
to 110 ppm; and when combined with 30-35% flue gas circulation, the remaining
emissions are further reduced by 50%. Note, however, that the reductions
obtained by using individual techniques cannot be added when using systems in
combination. The combined-system effectiveness of NOX control must be measured
for each integrated system.
Perhaps the most difficult factor in developing effective NOX control
through furnace modifications is the removal of the NOX obtained from the fuel-
34
bound nitrogen as opposed to that derived from nitrogen in the combustion air.
The NOX formed from fuel-bound nitrogen is produced at much lower flame tempera-
35
tures than that for conversion of atmospheric nitrogen. Therefore, it remains
to be determined whether combustion modifications alone can adequately control
the NOX from fuel nitrogen. The answer to this question may be found when a
detailed understanding of the reaction mechanisms for formation of NOX in the
combustion process becomes available. It shouLd then be possible to construct
viable theories for the control of NOX.
An alternative to burner modifications is flue gas treatment to remove
nitrogen oxides that are produced during combustion. Flue gas treatment
appears to be especially promising for cases where either the NOX concentra-
tion is high or a very low level on NO emission is required. Three basic
o o o f.
approaches ' to flue gas cleaning for control of NOX emissions are under
development:
1. Catalytic processes including decomposition of NOX
to nitrogen and oxygen, selective reduction of NOX
by NHa, and simultaneous removal of SOX and NOX from
flue gas.
2. Physical separation processes involving adsorption of
NOX by solids such as activated carbon or molecular
sieves.
3. Chemical separation processes involving absorption of
NOX by liquids such as aqueous acid or alkaline scrubbing
solutions.
-------
173
Preliminary studies show that none of these processes is adequate,
by itself, for NOX control. To date there is no commercially available flue
gas treatment process for reducing the concentration of NOX in power plant
emissions. The known adsorbents and absorbents have low capacity, and known
catalytic decomposition and reduction methods cannot handle large volumes of
dilute stack gas. The indication is that flue gas treatment will be useful
only as a secondary cleanup step.
5.1.3 Particulate Emission Control Systems
The emphasis of the research programs on control of particulate
emissions has shifted in the last two years to development of systems for
removal of fine particulate matter (particles of diameter 0.01-3 microns).
This shift has occurred in response to the increasingly impressive amount
of evidence that particulates in this size range are a major health hazard
because of deep penetration into the lungs and long retention times that
result from their inhalation. In addition, there is a growing concern about
the health effects of trace metals in fine particulates. Evidence is accumu-
lating that many potentially hazardous trace elements including arsenic,
selenium, cadmium, and lead are concentrated in the fine particulate emissions
37
from coal combustion sources. Although the control of emissions of large
particles is fairly well handled by conventional devices (see Table 5-4), the
collection efficiency of these devices drops appreciably with decreasing size
for submicron particles.
The current research program on control technology for fine particu-
lates includes efforts to increase both the capability of conventional equip-
ment for the collection of fine particulates and a number of developmental
programs for novel devices. Both approaches are proving effective, and sig-
nificant improvements in the efficiency of control of fine particulate emis-
sions can be expected in the next few years. A summary of the current research
efforts in this area and the anticipated dates of completion of demonstration
studies for the various control devices under investigation follows:
1. Field tests of conventional particulate devices using
specially designed mobile units are planned to continue
through 1980. The purpose of these studies is to assess
the capability and limitations of fabric filters, scrubbers,
cyclones, and electrostatic precipitators for reducing
particulate emissions from different kinds of sources in
-------
174
CO
cu
CJ
S-i
3
o
CO
^
SH
cd
d
0
•H
4J
cd
4-1
CO
0
0
S-i
MH
rH
cd
o
E
QJ
erf
QJ
4J
cd
rH
3
O
•H
4->
S-I
ca
5-i
o
MH
CO
13
O
4-J
QJ
s
rH
cd
•iH
CJ
OJ
g
Q
0
MH
O
^>
5-1
cd
H
3
CO
.
v^-
I
in
QJ
o
cd
H
o
CO
d
0
•H
4J
03
CJ
•H
rH
ft
ft
<^
rH
cd
O
•H
ft
H
cd
co
SH
QJ
4-J
QJ
SH B
O CO
MH -H
O
£? 01
CJ
£>*» *H
O 4->
d 5-1
QJ 03
•H PLJ
CJ
•H 4-1
MH d
MH OJ
W S-I
QJ
<4H
MH
•H
O
d
o
CJ
•H
0
rH
V
d
o
5J
O
tH
0
i — 1
A
rH
rH
cd
S-i
QJ
Q
t)
O
4-J
0)
S
TJ
•H
3
cr
•H
rH
T)
C
cd
TJ
•H
rH
o
CO
M-i
6
r*N
4J
QJ
•H CO
SH QJ
cd rH
> CJ
•H
QJ 4-1
13 S-i
•H cd
S a
O^
O"\
1
o
oo
-f-
ON
ON
1
ON
_i_
ON
ON-
1
OO
CJ
•H SH
4J 0
Cd 4-1
4-J 03
CO 4-1
O -H
r^ fl,
4-J T-l ^-N
cj a CM
QJ 0) CO
rH 5-1 W
rjj p, x_x
.
I — 1
13
1 d
•rH OJ
0
•H -
rH CO
OJ 4-J
,d 60 CO CO
4-> d -H cd
•H 0 60
•\ rrj
QJ -H 13 QJ
CO > -H 3
3 O O i-H
S-i cd MH
i — I ft
03 " d
S-l MH SH -H
OJ O O
d T) CO
QJ OJ O 4-1
60 rH d
rO SH OJ
o cd o d
4-1 ft MH O
cd ft
d O rH 0
o o o
•H CO 5-1 CJ
4-1 -H 4-1
•H d QJ
T3 0 0 rH
nH fjl fin
OJ 4-J 3
CO 13 rH
d >> QJ o
H CO 4-1 CO
13
O
ON
1
r~^
-f-
ON
ON
1
o
0)
rH
fN
03
rH
•H
03
£>
0)
4J
O
^
S-i
QJ
pO
3
S-i
a
CO
.
CN]
QJ
13
3
rH CO
O OJ
d 4-1
•iH 03
rH
13 3
o a
4-J 4-J
0) 5-1
B co
ft
CO
•H QJ
-C >
4J -H
CO
MH O
O S-i
S-i
CO O
QJ CJ
SH
3 MH
4-J O
CO
QJ d
MH O
•H
rH 4-J
cd CJ
•H QJ
U rH
QJ rH
ft O
CO O
-|-
ON
ON
1
•st
ON
-|-
ON
ON
1
OO
ON
C5
-j-
ON
ON
CJ
SH
QJ
4-1
rH
•H
MH
CJ
•H
S-i
c<3
En
.
ro
QJ
4-1
cd
OJ
O
g
4-1
03
d
o
•H
4-J
CO CO
S-i QJ
QJ SH
a 3
0 4-J
cd
QJ S-i
> 0)
•H ft
CJ QJ
QJ 4-J
MH
MH ff.
QJ 60
•H
r*j ^r"1.
4-1
•H 0
IS 4-1
CO
cd
60
£x,
SH
cd
13
d
0
a
0)
CO
13
d
ctj
£*•»
S-l CO
03 d
B o
•H -H
S-i 4-1
ft cd
l-i
A 0)
4-J ft
0 0
60
c d
•H -H
d
13 cd
0) QJ
CO rH
P 0
0)
rH
rQ
cd
rH
•H
cd
cti
4-1
o
^
QJ
rH
o
cd
rH
•H
03
CO
4-J
o
13
H]-
ON
ON
1
O
LO
rH
CO
60 S-i >-•»
3 0 QJ
MH 4-J d
•H CJ O
5-1 OJ rH
4J rH cj
^ d rH >,
5-t QJ O O
a o u ^
•
-ct
0)
•H
rH
O
4-1
rrj
0)
4-1
O
QJ
ft
X
QJ
OJ
13
rH
3
0
CO
e
QJ
4-J
CO
CO
4-J
CO
o
e
SH
0
^
a
d
0)
•H
o
•H
UH
MH
pj
.
CO
0)
cn
cd
o
4-)
CO
OJ
o
4-1
4-1
CO
J^l
0
[5
0
o
SH
MH
CO
0) OJ
60 B
d o)
cd M
5-1 4-J
X
CO QJ
03
0
OJ 4-J
4-1
d QJ
01 f:
CO 4-1
OJ
s-i d
ft QJ
OJ
cd S
4-1 4-1
03 QJ
Q i-Q
cd
.
"' i d
co 03 O
4-J O -H
d -H 4-1
03 rH G
rH ft 3
ft ft 13
rd O
rH 5-t
cd 60 ft
•H d
S-i -H O
4-> 4-J -H
CO -H 4-J
3 B CO
13 T-l CO
d rH rH
•H a,
QJ
13 S-i T3
d 03 d
cd cO
0)
co !-i «
0) QJ C
•H f, O
4-1 4-J -H
•H -W
rH •« cd
•H CO S-l
4-1 C QJ
3 0 d
•H -H
4-J 4-1 O
CO CO d
O 5-1 -H
B cu
ft rH
d o cd
•H ft
rH -H
cu cd cj
CO CJ -H
3 1-1 d
60 3
5-15-10
0 3
MH rH -
rH >,
QJ cd 5-t
4-1 4-J QJ
cd a> >
3 B o
cr o
QJ 13 CU
13 d S-i
03 co
4-1
CO 60 CO
•H C >>
•H rH
^ d CO
CJ iH 4-J
d B co
OJ cj
*H •*
O co !>,
•H QJ S-l
MH TH QJ
MH 5»i d
QJ 4-J -H
CO MH
rH 3 0)
cd 13 5-t
> d
O -H CO
B co
OJ rH
S-l QJ ,C
Q) CJ
13 4-J 3
QJ CO CO
4-1
CO •> CO
•H a) d
rH d O
0 -H
CO -H 4-1
13 4-1 cfl
O cd SH
A S-i QJ
4-J Q) ft
QJ ft O
B o
OJ
5-14-10
300
0 3 CO
MH 13
0 0
rH S-l 4-1
rH ft
03 co
^ P3
SH 0 O
O O -H
Eu 5-1 4-1
rQ
•
cd
4-1
cO
13
0)
CO
QJ
r"1
4-1
0
S-i
•H
MH
d
0
O
O
4-J
60
d
•H
4-1
CO
0)
4-J
M
0)
f]
4-1
S-l
3
MH
13
QJ
0)
O
S-i
QJ
,0
,0
3
SH
O
CO
rd
4-1
•H
£5
d •
0 S-i
•H QJ
4J ,0
0 ^
QJ 3
rH 1-4
rH O
O CO
o
0)
CU £1
4-J 4-J
cd
rH 0
3 4-J
o d
•rH -iH
4-1
SH CO
03 4-1
ft 3
ft
cu d
C -H
•H
MH t^
60
d SH
•rH QJ
d
CO QJ
d
O £1
•iH 60
4-J TH
O3 rd
•rH
SH >,
cfl M
> QJ
$>
MH
O 0)
SH
4-J T-l
rH 3
3 cj*
CO QJ
QJ M
S-i
CO
cd QJ
•rH
CO CJ
•H d
QJ
CO iH
QJ O
•H T-l
O MH
d MH
QJ QJ
•H
O £l
•H 60
MH -rH
MH £l
QJ
QJ
M-t ^cj
0 H
OJ
bO •
d P-I
co o
S-i SH
i3
QJ
t) QJ
•rH SH
IS 3
CO
CO CO
•tH Q)
*d SH
H ft
T3
-------
175
order to find the best control device for each industrial
category. In-plant evaluations of the performance of these
devices is underway and is expected to continue through 1979.
2. Recent field tests of the capability of electrostatic
precipitators for control of fly-ash emissions from
coal-fired utility boilers have shown that collection
efficiencies of more than 90% may be possible for
particulate fractions down to 0.02 microns. ° Assess-
ment of ESP performance on these and other sources is
continuing in anticipation of the need to adopt perform-
ance standards for fine particulate emissions.™ Similar
performance has been obtained with ESPs on a utility
boiler and a Cat-ox reactor, indicating that effective
fine particulate control for a variety of sources may
be achievable with ESPs.
3. Development programs for over 20 novel particulate
collection concepts have begun,3" and the plans
include pilot demonstration testing of the more
promising of these to be run during 1976 through
1978. The candidate concepts include charged drop-
let scrubbing, flux force/condensation scrubbing,
sonic agglomeration, steam-hydro scrubbing, foam
scrubbing, granular bed filtration, and the use of
filter beds combined with electrostatic charging
of the particles. Definite prognoses for perform-
ance capabilities of devices based on most of these
concepts are not yet available, but major improve-
ments in collection efficiency of fine particulates
are expected. The steam-hydro scrubber, for example,
has been found to be highly efficient in a test on
an open-hearth steel furnace in which it exhibited
a removal efficiency of greater than 90% (mass basis)
for all particulate-size fractions above about 0.2 microns.
Though considerable progress has been made in recent years in the
measurement and characterization of particulates, not a great deal has been
accomplished in the measurement of particles of micron and submicron size. '
Of the various techniques (such as impactors, cyclones, diffusional methods)
presently available for the characterization of particulates either by mass
or size distribution, most fail to give reproducible results for particles
smaller than about 1 micron or for concentrations below about 1 gm/m^. in
addition, accurate data on the fractional efficiency of particulate removal
in commercial equipment are very meagre or inconclusive.
Among the various devices for measurement of particle size distribu-
42
tions impactors appear to show most promise. Reliable measurements with
-------
176
impactors, when properly conducted, can be made for particle sizes of about 0.2
microns. To extend the measurement capabilities to even smaller particles,
the Southern Research Institute recently tested a series of diffusion batteries
coupled with condensation nuclei counters to provide particle concentrations
and size distributions over a range of about 0.01 to 0.3 microns. Although
results obtained in these two test programs are quite encouraging, a major
effort is still needed before these methods can be developed to the point
where they are suitable for enforcement of fine particulate standards.
For the most part fine particulate measurement technology is still
at an early stage of development. In present investigations work in five
different areas is underway:
1. Generation of data bases for emissions of submicron particles
from major industrial sources.
2. Improvement of the existing measurement techniques
(particularly impactors and optical devices) and
development of compact and rapid readout systems.
3. Development of specialized instrumentation for measure-
ment of particulates containing potentially toxic sub-
stances including sulfate-containing compounds, trace
elements, and carcinogenic hydrocarbons.
4. Evaluation of new concepts for measurement of fine
particulates from different types of sources.
5. Development of techniques capable of measuring and
analyzing particles that are present in reactive,
damp, and high-temperature gases.
Research studies directed toward these objectives are expected to continue
through 1979.
5.1,4 Dual Emission Control Systems
This section provides a brief overview of the currently available
strategies that can be used to control the emissions of two or more pollutants
by a single operation. The intention here is to identify some of the potential
benefits that may result from the utilization of such dual emission control
systems and to discuss the feasibility of employing such control methods for
achieving existing and planned emission control objectives.
-------
177
The concept of employing a single device to control emissions of multiple
pollutants has been used for many years. As indicated by a number of investi-
gations of scrubbers for S02 removal, a significant amount of NOX and particu-
43 44
lates present in the flue gas can also be removed. ' The sludge and
associated liquors produced by scrubbing have been found to contain certain
trace elements, chlorides, and other volatile trace metals present in the
feed coal. Recent data show that certain S02 scrubber systems, such as the
marble-bed absorber and the turbulent contacting absorber, are also capable
of removing up to 90% (even more under some conditions) of the particulates
with diameter 2 y or less.''5
Since aqueous scrubbers are being installed on many sources emitting
both sulfur dioxide and particulate matter, characterization of the performance
of these systems with respect to S02 and particulate removal efficiency is of
considerable importance. This is an active area of investigation, and much
new data on dual S02-particulate control should become available in the next
two years.
Of the various approaches to NO control, flue gas cleaning is
X
regarded as the least feasible. To date, little effort has been spent on
development of this approach because of this. The only flue gas cleaning
methods now deemed feasible are those that remove SO,, in addition to NOV.
A. A
47
Of these, the Japanese Chiyoda Thoroughbred CT102 scrubbing process appears
to be the most likely possibility for commercial application.
In the early work carried but on aqueous scrubbing system the amount
of NOX removed was generally 20% or less of that ordinarily found in flue gas.
Nevertheless, techniques are available that can significantly improve the
removal efficiency of these oxides through scrubbing. It is known that by
increasing the N02/N0 molar ratio in flue gas from its normal value of 0.1
to an equimolar ratio, the absorption of NO can be greatly improved. Different
techniques for achieving nearly equimolar concentrations of N02 and NO in flue
gas have been examined extensively. They include: 1) catalytic oxidation of
NO, 2) addition or recycling of N02 to the flue gas, and 3) homogeneous oxida-
tion of NO with ozone or chlorine added. Of the first two techniques, much
*This capability is considered an important requirement of fine particulate
control technology, since in most power plants a significant fraction of
the particles emitted are in the submicron range.
-------
178
research effort will be required before they are technically and economically
feasible for industrial use. The known catalytic oxidation techniques are
48
either too slow or too costly and the addition of NOa to improve NOX absorp-
44
tion does not appear promising. With regard to the third technique, the
CT102 process has met with some success. This process is a modification of
49
the standard CT101 FGD system in which ozone is added to the stack gas
stream prior to scrubbing. The results of pilot plant studies of this system
indicate that removal of up to 90% of SOa and 60-80% of NOX can be achieved.
Since the amount of NOX removed in CT102 is directly proportional to the ozone
added, the amount of commercial use of the process will depend to a large
extent on the availability and cost of ozone. Furthermore, demonstration
of the general applicability of the process and further testing of its
reliability on a larger scale, especially for large coal-fired boilers, will
be necessary before the process is an accepted industrial control technology.
Another area of development of dual control systems for NOX and SOX
emissions is the work on fluidized bed coal combustion. ' Because of the
large heat transfer rates that are possible in Eluidized beds, the combustion
can be carried out at a lower temperature than is possible in conventional
combustors. The rate of nitrogen oxides emission is thereby reduced con-
siderably. With the introduction of dolomite to the combustor, high removal
of sulfur (greater than 90%) and a low NO level (less than 150 ppm) can be
achieved. Although the development of the fluidized bed combustor will not
reach the commercial stage before 1980, its potential for becoming an
environmentally and commercially acceptable coal utilization technology is
worth watching.
In summary, processes capable of simultaneous reduction of two or more
pollutants appear to be a trend in the development of future control tech-
nology. All of the processes mentioned in this section are still in one stage
or another of pre-commercial development. Nevertheless, it is likely that several
of these processes will be developed successfully as the need for more cost-
effective processes grows. Much more data on the performance of these processes
and evaluations of their expected usefulness are expected in the next few years.
5.2 BASIC RESEARCH EFFORTS
In future efforts to develop control technology for the removal of sulfur
oxides, nitrogen oxides, and particulates from industrial process gas streams,
-------
179
it is important that equipment designs be based on adequate understanding of
the physical and/or chemical processes responsible for the separation. Basic
research in industry is often regarded as not useful, and the approach of manu-
facturers to control technology development is usually highly empirical. Tech-
nology development often proceeds without knowledge of the actual separation
mechanism involved and/or without a full recognition of the process limitations
under specific operating conditions. Since the costs of empirical experimenta-
tion are often considerable, it is prudent to make use of information obtained
from conceptual and analytical studies in technology development programs.
Recently, this trend has reversed somewhat as the requirements for
cleaner stack gas have become more stringent. In the case of particulates
the situation has become rather critical. It has been observed that conven-
tional dust collectors are generally ineffective for controlling emissions
of particles having diameters below about 2 microns. In some instances,
as when using scrubbers, the collection efficiency can drop to near zero for
o o
particle sizes below 0.5 microns. In two recent IERL studies of fine
particulate control by flux-force/condensation scrubbing and electrostatic
52
augmentation, entrainment of water droplets was found to be a major problem.
As a result a program of theoretical and experimental research on entrainment
separator technology was initiated to find a solution to the problem.
It is evident, based on this and similar recent experiences, that
fundamental research on process gas cleaning must be undertaken as part of
the continuing effort to develop improved control equipment. EPA, ERDA, and
EPRI are currently sponsoring the following research in support of control
technology development programs:
1. Determination of the importance of particle/liquid inter-
facial properties to collection of fine particulates
by wet scrubbing.
2. Studies directed toward establishing the basic structures
of coal, thereby providing a basis for development of
more effective chemical cleaning processes for coal.
3. Determination of (a) the contribution of fuel-bound
nitrogen to NOX in coal and oil combustion, (b) the
mechanisms and kinetics of converting fuel-bound nitrogen
to NOX, and (c) the fate of fuel-bound nitrogen that is not
converted to NOX.
-------
180
4. Development of standard laboratory resistivity apparatus
and procedures for fine particulate characterization;
determination of essential parameters for the prediction
of ESP performance through a computer simulation study;
identification of the important mechanical problems respon-
sible for ESP operating failures.
5. A study to isolate and identify the nature of organic sulfur,
mineral, and trace metal compounds in coal.
6. Determination of the effectiveness of combustion modifica-
tion techniques for controlling emissions of NOX, SOX)1 HC,
CO, and particulates from utility boilers.
7. Identification of the limitations on retrofitting flue gas
desulfurization and/or other pollution control devices on
existing plants.
5.S SUMMARY AND CONCLUSIONS
The objectives of this section are threefold:
1. To provide a brief state-of-the-art review of currently available
emission control methods.
2. To describe the near-term technological developments
expected from current research and development programs.
3. To identify among these expected developments those
most likely to find commercial application by 1980.
Most of the control technologies discussed are for coal combustion in
industrial and utility boilers. Emissions of primary concern are sulfur
oxides, nitrogen oxides, and particulates. Special attention is given to fine
particulate emission control and measurement. Processes also included are
those that have dual or multi-pollutant control capabilities.
The conclusions obtained in this review cam be stated first by identify-
ing the best available emission control techniques for sulfur oxides, nitrogen
oxides, and particulates, and second by giving a forecast of developments
expected from current research efforts and a list of areas where further
research is required.
1. In regard to process availability, process reliability,
pollutant removal efficiency, costs, and lead times for
installation, it is apparent that:
-------
181
a. The majority of sulfur oxide removal systems
installed or planned in this country are of
the flue gas desulfurization (FGD) type, over
70% of which are lime/limestone scrubbers. How-
ever, it is doubtful that the capacity of the
scrubber manufacturing industry is adequate to
meet more than 10% of the anticipated demand through
I960.53
b. The approach to reduce NOX formation in any com-
bustion process will be mainly through combustion
modification.
In the case of particulate control the choice among the
three basic processes (i.e., ESP, fabric filtration,
and wet scrubbing) is less obvious. The main factor
inhibiting the choice is the inefficiency of each of these
systems for removing particles in the submicron size range.
Much research and experience are still required to find a
system capable of collecting fine particles.
2. In view of EPA's and EPRI's current technology development
plans and their resource utilization patterns in support of
the various sections in the Clean Air Act (109, 110, 111,
112, and 113), the near-term (prior to 1980) technological
achievements will include the following:
a. For sulfur oxide emission control: 1) solutions of the
problems of disposal or utilization of waste sludges
from non-regenerable FGD scrubbing systems; 2) continued
progress on development of FGD systems of the regenerable
type, with one or more expected to be commercially avail-
able by 1980.
b. For NOX emission control: current research efforts are
expected to lead to modifications of operating procedures
and equipment in utility and industrial boilers that reduce
NOX emissions. There is insufficient information at the
present time to predict which modifications will prove most
effective and what level of control will be ultimately
achievable.
c. For fine particulate emission control: 1) continued
improvement on instruments for the characterization of
fine particulates by total mass, chemical composition,
and size distribution; 2) modification of existing tech-
niques and development of novel systems for effective
removal of submicron particles down to 0.001 microns in
diameter.
3. The following are the areas for which a substantial increase
in the amount of research effort is needed:
-------
182
a. Dual or multi-emission control systems: to determine
the removal capability for all pollutants of current
control systems including those still under develop-
ment; and to explore new concepts for existing or
novel devices by which dual or multi-emission control
might be obtainable.
b. Basic research: the need is to improve and upgrade
present pollutant control systems using information
about the fundamental processes that effect the
removal of the pollutant from the stack gas.
-------
183
6. PROCEDURES FOR DEVELOPMENT OF
NEW SOURCE PERFORMANCE STANDARDS
Preceding chapters have discussed the impact on future levels of emis-
sion control that results from setting priorities based on factors such as
pollutant health and welfare effects, availability of control and measurement
technology, cost of control, emission rates, growth rates, source location,
energy conservation, and existing regulations. In this section is evaluated
various aspects of the EPA standard setting and implementation procedure and
the impact of these and alternative procedures on the rate of standard-setting
and resulting projected emission levels.
The procedural requirements contained in Section 111 of the Clean Air
Act for the development and promulgation of NSPS are limited to the following
basic schedule (Section lll(b) (1)):
1. Publication of a list of categories of sources that
contribute significantly to air pollution that causes
or contributes to the endangerment of public health
or welfare.
2. Within 120 days after publication of the list, proposed
regulations are to be published.
3. After a 90-day comment period, the proposed regulations
with approproate modifications are promulgated.
4. Standards may be revised as necessary using these same
procedures.
In actual practice, the full process of establishing standards follows
the procedure outlined in Fig. 6-1. Phase I of the process, Source Priority
Determination, includes as a major element prioritization of all possible
standards as is discussed and implemented in Sections 3 and 4 of this report.
Additional aspects of priority determination are discussed in the following
section.
Prior to making a commitment to the development of standards for a
source category, it is generally useful to conduct industrial surveys and to
establish contacts through appropriate trade associations or other industry
representatives to gain information relating to current status of emission
control, expected industry growth, and other factors (Phase II).
-------
184
PHASE I
SOURCE PRIORITY
DETERMINATION
PHASE n
INDUSTRIAL
SURVEYS
PHASE
NSPS DATA
ACQUISITION
PHASE
PREPARATION OF
STANDARD SUPPORT
DOCUMENT
PHASE Z
EXTERNAL REVIEW
AND PROMULGATION
PHASE
IMPLEMENTATION
AND ENFORCEMENT
PHASE YE
EVALUATION
Fig. 6-1. Procedures for Development and Implementation of NSPS
-------
185
The procedures for data acquisition (Phase III) and establishing a reco-
mmended standard (Phase IV) are discussed further in Section 6.2. Section 6.3
discusses the review by EPA and others which culminates in a promulgated
standard (Phase V). Implementation and enforcement of the standard (Phase VI)
and the subsequent evaluation of needs for revision (Phase VII) are the topics
of Section 6.4.
From previous experience, the time required from the start of the data
acquisition (Phase III) through standard promulgation (Phase V) can be six-
teen months or more, and evaluation of the standard's effectiveness through
the evaluation of new sources regulated by the standard will require an addi-
tional 2-5 years. This long time span between start of standard development,
its evaluation, and the process of revising a standard (another 16 months)
emphasizes the importance of selecting categories for standard setting with
largest impact, establishing the most stringent standard possible, and main-
taining a tight standard development schedule.
For the development of standards for each category, approximately
75-95 man-weeks of effort are required for industrial evaluation, cost analysis,
and emissions measurement (not including assistance of subcontractors for
emissions measurement). In addition, the review process and preparation of
materials for publication of proposed and final standards in the Federal Regis-
ter requires an additional 10-20 man-weeks for a total of 85-115 man-weeks per
standard.
6.1 SOURCE PRIORITY DETERMINATION AND SCHEDULING
STANDARD DEVELOPMENT
The determination of source priorities (Phase I, Fig. 6-1) consists
of two rather distinct levels:
Level 1. An initial prioritization of all possible stand-
ards.
Level 2. A detailed prioritization of a limited number of
the higher priority categories identified.
4
This study, building on the TRC data provided, is a Level 1 prioritization.
Because of the somewhat cursory analysis of each category to which this study
was limited, the more detailed Level 2 evaluation is required for final priori-
tization.
-------
186
For the Level 2 detailed prioritization the high ranking categories in
each of the constraint groups identified in the individual pollutant evalua-
tions in Section 4.2-4.6 are to be considered. Evaluation of top categories
in each of the constraint groups provides a check on the validity of a con-
straint factor for a category that may have a high ranking based on Ts-Tn
alone.
Because of unavoidable changes in factors upon which source priorities
are based, the process of establishing priorities as described in Section 3 -
must be an iterative and on-going function of the standard-setting procedure.
Priorities will necessarily change as a result of changes in goals for sta-
tionary source emission control, decisions to control additional pollutants,
new developments in emissions control and measurement technology, and avail-
ability of clean fuels. Source priorities must also be reevaluated periodically
because of additional information made available to the EPA concerning the
industry emission factors and control methods applicable to that industry.
The prioritization process in Section 3 is designed so as to easily allow
reevaluation of priorities and expected emissions under different assumptions
and criteria. Subsequent prioritizations could also be linked to other EPA
data, such as the SIP reviews and SAROAD files on emissions and air quality,
which may be more precise in defining needs for standards for specific pollu-
tants and categories.
Industry categories that are already regulated by NSPS should also be
included in the future priority analysis if changes in control or process
technology, for example, make possible a revised standard that is more strin-
gent.
Because of changing priorities, a decision-making methodology is
required for defining when it is desirable to delay completion of a standard
under development because of a priority change and when it is more advantage-
ous to continue in spite of the change. The standard-setting priority analysis
method can be used for this purpose by including in the priority analysis
the industry category for which a standard is in the process of being developed.
In this situation the time for standard development (t ), the priority
O i-f
factor introduced in Section 3.2.1, becomes the time required only to complete
the standard.
-------
187
The possible desirability of delaying completion of standard develop-
ment in certain cases has an impact on the type of contract written when the
standards development is performed by contractors. The most efficient type
of contract is one covering the entire preparation of the Standards Support
Document draft. However if there is uncertainty in the priority ranking, a
phased contract would have the advantage of allowing delays in completion to
account for the change in priorities. Each phase of such a contract would be
designed to supply sufficient information to allow a priority reevaluation
before proceeding with the subsequent phase.
A guideline for making the decision between a full commitment to
develop a standard for a source category or collecting more preliminary
information to support such a commitment can be obtained by analyzing the
impact on the priority factor (Section 3.4) of the inaccuracy in the emission
factor and growth and production factor estimates. In the most obvious case,
if the uncertainty in priority factor for two categories is less than the
difference between their respective priority factors, a full commitment to
the higher priority category is possible.
In the case of a category with high priority factor, but also large
uncertainty bounds which overlap the value of the next lower priority factor,
a preliminary study to remove the uncertainty in priorities may be indicated.
However, an additional consideration is the estimated time required for stan-
dard development that appears in the denominator of the priority factor; the
preliminary analysis will increase the priority factor, assuming that the
subsequent development will be shortened as a result of that preliminary
analysis. A possible result is that the category with the higher priority
factor will retain the higher priority even if the original estimate was
in error. In other words, the effect on the priority factor of bringing the
category nearer to promulgation may more than offset the error in the original
estimate of the factor and a commitment to full standard development without
preliminary analysis would be preferred.
The above discussion suggests the usefulness of including an indica-
tion of expected error bounds in the initial evaluation of priorities. Such
an estimate of error, although not a part of this study, could be implemented
based on an accuracy ranking.
-------
188
Previous sections of this report have emphasized the importance
of developing standards at the earliest possible date to minimize the number
of sources not regulated because of construction or modification commencing
prior to standard promulgation. Because of this objective there may -be a
tendency to initiate standards development for too many categories, which
can lead to counterproductive results as illustrated by the following simple
example.
Consider two unrelated categories with comparable emission and growth
factors and equal times, At, required for standard development, and as a
result equal priority. Assume that the available EPA resources can be allocated
to (1) develop the standards serially such that one standard is promulgated
at time At and the second is promulgated at time 2At, or, (2) develop the
standards in parallel such that both standards are promulgated at time 2At.
Clearly the serial development results in lower emissions for this example
because of the earlier standard setting for the first category.
The conclusion to be drawn on the basis of this example is that effort
should be concentrated on the higher priority sources to the extent that maxi-
mum rate of development is achieved. This provides an argument against the
development of standards in groups that are to be promulgated simultaneously.
Each standard is to be developed individually at its own maximum rate. There
is of course a limit on the rate of development and when that rate has been
achieved remaining resources can be allocated to standard development for lower
priority categories. Decreasing the emphasis on serial development was simu-
lated by Strategy 14 in Section 4.7 by increasing the time increment between
standards plus a corresponding increase in number of standards at each discrete
point in time. The result was a small but noticeable increase in emissions.
A counter argument in favor of parallel development occurs in the
case where efficiency results from simultaneous analysis of two or more
related categories. The benefit from simultaneous development can be diffi-
cult to assess, in particular if one of the categories is being shifted to a
higher or lower priority for the purpose of simultaneous development. The
gain or loss in emission control for such a case can most directly be deter-
mined by using the priority impact analysis tools discussed previously.
The prioritization of categories forms the basis for developing a
program plan for carrying out the various tasks related to standard promulgation.
-------
189
At a high rate of standard development, the proper sequential planning of the
necessary tasks and allocation of available manpower and resources can become
quite cumbersome. In recent years, various computer systems have been developed
that provide automated management assistance based on techniques such as critical
14 15
path analysis, resource allocation, and PERT. ' These management tools should
be further evaluated as to their usefulness in NSPS scheduling.
6.2 PROCEDURES AND RATIONALE FOR DEVELOPMENT OF NSPS
Under the mandate of Section 111 of the Clean Air Act, the EPA has
promulgated or proposed, since the passage of the Act in 1970, about 34 NSPS
for pollutants in 21 source categories. During the course of those actions,
there has evolved a series of guidelines for the process of establishing NSPS.
The following is documented description of those guidelines:
Congress mandated that sources regulated under sec-
tion 111 of the Clean Air Act be required to utilize
the best practicable air pollution control technology
that has been adequately demonstrated at the time of
their design and construction. In so doing, Congress
sought to :
1. maintain existing high-quality air,
2. prevent new .air pollution problems, and
3. ensure uniform national standards for new facilities.
The selection of standards of performance to achieve
the intent of Congress has been surprisingly difficult.
In general, the standards must (1) realistically reflect
best demonstrated control practice; (2) adequately
consider the cost of such control; (3) be applicable
to existing sources that are modified as well as new
installations; and (4) meet these conditions for all
variations of operating conditions being considered
anywhere in the country.
A major portion of the program for development of
standards is spent identifying the best system of
emission reduction which "has been adequately demon-
strated" and quantifying the emission rates achievable
with the system. The legislative history of section
111 and the [subsequent] court decisions make clear
that the Administrator's judgment of what is adequately
demonstrated is not limited to systems that are in actual
routine use. Consequently, the search may include a
technical assessment of control systems which have been
adequately demonstrated but for which there is limited
operational experience.
-------
190
To date, determination of the "degree of emission
limitation achievable" has been commonly based on
(but not restricted to) results of tests of emissions
from existing sources. This has required worldwide
investigation and measurement of emissions from control
systems. Other countries with heavily populated, indus-
trialized areas have sometimes developed more effective
systems of control than those used in the United States.
Because the best demonstrated systems of emission reduc-
tion may not be in widespread use, the data base upon
which the standards are established will necessarily
be somewhat limited. Test data on existing well-
controlled sources are an obvious starting point in
developing emission limits for new sources. However,
since the control o£ existing sources generally
represents retrofit technology or was originally
designed to meet an existing State or local regulation,
new sources may be able to meet more stringent emission
standards. Accordingly, other information must be
considered and judgment is necessarily involved in
setting proposed standards.
Since passage of the Clean Air Amendments of 1970, a
process for the development of a standard has evolved.
In general, it follows the guidelines below.
1. Emissions from existing well-controlled sources
are measured.
2. Data on emissions from such sources are assessed
with consideration of such factors as: (a) the
representativeness of the source tested (feed-
stock, operation, size, age, etc.); (b) the age
and maintenance of the control equipment tested
(and possible degradation in the efficiency of
control of similar new equipment even with good
maintenance procedures); (c) the design uncer-
tainties for the type of control equipment being
considered; and (d) the degree of uncertainty
affecting the judgment that new sources will be
able to achieve similar levels of control.
3. During development of the standards, information
from pilot and prototype installations, guarantees
by vendors of control equipment, contracted (but
not yet constructed) projects, foreign technology,
and published literature are considered, especially
for sources where "emerging" technology appears
significant.
4. Where possible, standards are set at a level that
is achievable with more than one control technique
or licensed process.
-------
191
5. Where possible, standards are set to encourage (or
at least permit) the use of process modifications
or new processes as a method of control rather than
"add-on" systems of air pollution control.
6. Where possible, standards are set to permit use
of systems capable of controlling more than one
pollutant (for example, a scrubber can remove both
gaseous and particulate matter emissions, whereas
an electrostatic precipitator is specific to parti-
culate matter).
7. Where appropriate, standards for visible emissions
are established in conjunction with mass emission
standards. In such cases, the standards are set in
such a way that a source meeting the mass emissions
standard will be able to meet the visible emission
standard without additional controls. (In some cases,
such as fugitive dust, there is no mass standard.)
Finally, when all pertinent data are available, judgment is
again required. Numerical results should not be transposed directly
into regulations. The design and operating conditions of
those sources from which emissions were actually measured
cannot be reproduced exactly by each new source to which the
standard of performance will apply.
Section 111 of the Clean Air Act requires that cost be
considered in setting standards of performance. To do
this requires an assessment of the possible economic
effects of implementing various levels of control tech-
nology in new plants within a given industry. The first
step in this analysis requires the generation of estimates
of installed capital costs and annual operating costs for
various demonstrated control systems, each control system
alternative having a different overall control capability.
The final step in the analysis is to determine the economic
impact of the various control alternatives upon a new
plant in the industry. The fundamental question to be
addressed in this step is whether or not a new plant would
be constructed given that a certain level of control costs
would be incurred. Other issues that would be analyzed
in this step would be the effects of control costs upon
product prices and the effects on product and raw material
supplies and producer profitability.
The economic impact upon an industry of a proposed standard
is usually addressed both in absolute terms and by compari-
son with the control costs that would be incurred as a
result of compliance with typical existing state control
regulations. This incremental approach is taken since
a new plant would be required to comply with state
regulations in the absence of a federal standard of
performance. This approach requires a detailed analysis
-------
192
of the impact upon the industry resulting from the cost
differential that usually exists between the standard of
performance and the typical state standard.
It should be noted that the costs for control of air
pollutants are not the only control costs considered.
Total environmental costs for control of water pollu-
tants as well as air pollutants are analyzed wherever
possible.
A thorough study of the profitability and price-setting
mechanisms of the industry is essential to the analysis
so that an accurate estimate of potential adverse economic
impacts can be made. It is also essential to know the
capital requirements placed on plants in the absence
of federal standards of performance so that the addi-
tional capital requirements necessitated by these standards
can be placed in the proper perspective. Finally, it is
necessary to recognize any constraints on capital
availability within an industry as this factor also
influences the ability of new plants to generate the
capital required for installation of the additional
control equipment needed to meet, the standards of
performance.
The end result of the analysis is a presentation of
costs and potential economic impacts for a series of
control alternatives. This information is then a major
factor that the Administrator considers in selecting a
standard.
During the course of developing and implementing the above procedures
for standard development, the successive background information documents have
shown a definite trend toward providing more detail and comprehensiveness.
Although this implies increased effort for the standard development, the re-
sult has been in general standards that are more easily defendable. This
increased effort for each standard results in fewer standards being promulgated,
but on the basis of the analysis in Section 4 relatively small increases in
rate of standard-setting do not have a significant impact on total national
emissions. In fact, less detailed supporting documents could lead to less
stringent standards causing the increased standard-setting rate to be counter-
productive.
The question of how sources should be subcategorized and how affected
facilities within a subcategory should be selected and the resultant impact
on emissions controlled is not an issue that can be answered in general because
-------
193
of the opposing effects of increased efficiency in standard development for
similar sources and the possible lower priority for some of the sources
in the combined category. The most direct approach to this issue is to
delineate alternative subcategorizations and evaluate the impact using the
analysis tools described previously.
Although not legally required, a possible useful addition to the cost
analysis is an evaluation of the cost of control per unit weight of pollutant
removed as a result of the standard. This estimate along with similar esti-
mates for other standards would provide a coarse indication of the cost effec-
tiveness of the standard. A cost evaluation based on final product-cost impact
alone could show as acceptable an excessively large cost for a small emission
reduction if the cost were distributed throughout a large industry.
6.3 REVIEW OF PROPOSED NSPS
Following development of the initial draft of the standard support
document, comments are solicited from a wide variety of groups and individuals
from within the EPA, other Federal agencies, affected industries, and other
interested persons, in order to provide adequate opportunity for input from
divergent sources of information (Phase V). This aspect of the standard
setting procedure is crucial to the development of a defendable standard
but tends to be time-consuming and is usually an important consideration
in the scheduling of final standard promulgation. A proper balance must be
established between the need to provide an adequate hearing to divergent
interests and the need to promulgate standards at the earliest possible
date.
The legal requirement for involvement of interested parties in setting
NSPS is defined in Section 111 of the Clean Air Act as discussed in the
introduction to this chapter. The EPA must first publish (in the Federal
Register) a list of categories for which it intends to establish NSPS, thus
giving interested parties an initial opportunity to comment on EPA source
priorities. After submitting a proposed standard, the EPA must promulgate
final standards following a period of not more than 90 days during which
comments from interested parties are publicly solicited, and if valid,
incorporated into the standards.
-------
194
Additional specific requirements for standards review are defined in
the Clean Air Act in Sections 117 (d) and 117 (f):
(d) In order to obtain assistance in the development and
implementation of the purposes of this Act, including
air quality criteria, recommended control techniques,
standards, research and development, and to encourage
the continued efforts on the part of industry to improve
air quality and to develop economically feasible methods
for the control and abatement of air pollution, the
Administrator shall from time to time establish advisory
committees. Committee members shall include, but not
be limited to, persons who are knowledgeable concerning
air quality from the standpoint of health, welfare,
economics, or technology.
(f) Prior to -
...(2) publishing any list under section lll(b)(l) (A) or
112 (b) (1) (A),
(3) publishing any standard under section lll(b)(l)(B)
or section 112(b)(l) (B),
...the Administrator shall, to the maximum extent
practicable within the time provided, consult with
appropriate advisory committees, independent experts,
and federal departments and agencies.
The continuing procedure used by the EPA for obtaining information
from industrial interests is through direct contact with representatives
from trade associations, equipment vendors, and individual companies. As
shown in Fig. 6-1, the contact with industrial representatives is one
of the first steps in the standard-setting procedure and generally precedes
a firm commitment to develop an NSPS for the industry. Examples of associations
that have contributed information to the standards development process are
the American Boiler Manufacturer Association, the Edison Electric Institute,
the American Iron and Steel Institute, the American Petroleum Institute,
the National Asphalt Pavement Association, the Portland Cement Association,
and the Industrial Gas Cleaning Institute. These industry-related contacts
are not only part of the review process but are used extensively in the
development of the initial draft of the standard support document.
Detailed internal EPA review is provided by a "working group" and
"steering committee." The working group, which assists in the formulation
and implementation of an NSPS development plan, includes representatives
from EPA organizations involved with enforcement, research, water effluents,
solid waste, legal council, and economic analysis. The steering committee,
-------
195
chaired by the EPA/Office of Planning and Evaluation, is responsible for
reviewing the progress of standards at several key milestones. Approval
by the EPA Administrator and Assistant Administrator for Air Programs is
also required.
In compliance with the intent of Section 117 of the Clean Air Act
given above, the standards are reviewed in detail externally to the EPA
by the National Air Pollution Control Techniques Advisory Committee (NAPCTAC)
and by other federal agencies. The NAPCTAC members represent industry,
control equipment manufacturers, regional air pollution control agencies,
and consultants specializing in air pollution control. Frequently individuals
with expertise related to the specific source category being considered are
invited to participate in committee meetings as technical consultants.
The function of federal agency review is to provide input into the
standard development in view of the possible impact on their respective
programs. This review process is coordinated by the Office of Management
and Budget.
Because of the large number and diversity of interests by necessity
represented in this review procedure, there exists the danger of the review
process becoming excessively long because of delays in reviewers' response
and revisions piling on top of revisions as separate interested parties
attempt to prevail with opposing views. As an indication of the possible
impact of delays in the review of standards prior to being proposed in the
Federal Register, during an eight-month period prior to promulgation of the
second group of standards, construction was initiated, and thus the NSPS
did not apply, for approximately 140 asphalt concrete plants, 40 sewage
sludge incinerators, 2 petroleum refineries, and 300 storage tanks. This
translates into an emission penalty of more than 10,000 tons of particulates,
5000 tons of S02, and 14,000 tons of hydrocarbons per year.
To prevent such extensive delays, the EPA must establish firm schedules
for receipt of reviewers' comments and clearly indicate that consideration
of these comments depends on schedule maintenance. Having received reviewers
comments, the EPA must then formulate and publish a proposed standard on the
basis of best available information. Reviewers will then have a second oppor-
tunity for comment prior to promulgation.
-------
196
A nominal schedule currently used by EPA for review following initial
drafting of the background document is given in Table 6-1, and an accelerated
schedule is given for comparison in Table 6-2. The current and accelerated
schedules indicate 37 and 27 weeks, respectively, for review prior to promulga-
tion. However, more importantly, tie respective time periods in the two
schedules prior to publishing the proposed standard are 28 weeks and 15 weeks.
The effective date for a NSPS is the date on which the proposed standard was
first published (Section lll(a)(2) cf the Clean Air Act) and thus there is
no advantage to shortening the time for comments following the proposed
standard publication. In view of this, the accelerated schedule has a
lengthened comment period following proposal publication to offset the
shortened time prior to publication.
The first major change in the accelerated schedule is the earlier
time (8 weeks vs. 12 weeks) for the completion of "Receipt and evaluation of
comments" following the presentations to the Working Group, NAPCTACj, other
federal agencies, and industry. This schedule is reasonable if these groups
are given for review initial draft background document immediately after
completion. If the initial draft of the document is completely developed by
a contractor, delays in distribution of the document and in the overall
schedule may result from preliminary EPA review of the document. An alterna-
tive that avoids this delay is the distribution of the unedited contractor's
report marked with an EPA disclaimer. (This procedure has been used by the
EPA Effluent Guidelines Division in uhe development of water effluent stand-
ards.) EPA review of the contractor's document can proceed in parallel with
the review of other groups and EPA suggested revisions could be sent to the
review groups prior to the formal meetings. These revisions should not be
major if the EPA has maintained close contact with the contractor during the
background document development.
The second major change in the accelerated schedule is the absorption
of the major steering committee functions by the Working Group. As experience
is accumulated and the standard development procedure and rationale become
more firm, the inputs required from these advisory groups are expected to
decrease as related to specific standards. The need for input from these
groups related to long-term priorities and scheduling is, however, expected
to continue.
-------
197
Table 6-1. Current EPA Schedules for Review
And Promulgation of NSPS
Activity
Completion Date,
Weeks
First draft of Standard Support Document
Presentations to Working Group, NAPCTAC, Other Federal
Agencies, Industry
Receipt and evaluation of comments
Second presentation to Working Group
Draft of proposed standard and briefing document
Review by Steering Committee and AA/OAWM
Review by Administrator
Publish proposed standard
Solicit comments from Federal Agencies
Evaluate comments and forward to AA/OAWM, OMB
Final action by Administrator
Promulgate final standard
0
5-1/2
12
13
16
22
25
28
31
33
36
37
Table 6-2. Accelerated EPA Schedules for
Review and Promulgation of NSPS
Activity
Completion Date,
Weeks
First draft of Standard Support Document
Presentations to NAPCTAC, Other Federal Agencies, Industry
Receipt and evaluation of comments
Draft of proposed standard and briefing document
Review by Working Group and AA/OAWM
Review by Administrator
Publish proposed standard
Solicit comments from Federal Agencies
Evaluate comments and forward to AA/OAWM, OMB
Final action by Administrator
Promulgate final standard
0
4
8
10
11
13
15
18
23
26
27
-------
198
Although the accelerated schedule in Table 6-2 represents a decrease
in the time required to promulgate standards, the effort required by the EPA
in terms of total man-weeks will not change in direct proportion but rather
the number of staff involved in the review process at any one time will need
to be increased somewhat.
The feasibility of the accelerated schedule can partially be evaluated
by comparison with the EPA Effluent Guidelines Division review schedule that
has been implemented for setting water effluent standards of performance. The
scheduled time from completion of the initial background document draft to
publishing the proposed standard for that group is 13 weeks as compared to 15
weeks in the accelerated schedule in Table 6-2. The reader must, however,
keep in mind the different constraints involved in setting effluent: standards.
In particular, the strict schedule for effluent standards demanded by a court
order is a convincing argument to require reviewers to maintain a tight sche-
dule in submitting comments. Also, prior to implementing a similar schedule
for NSPS development, a detailed evaluation of the effectiveness and problems
of the Effluent Guidelines Division's program should be made.
6.4 INVOLVEMENT OF CONTRACTORS IN STANDARDS DEVELOPMENT
A broad range of alternatives is available in the use of contractors
in the development of NSPS. An overriding factor, of course, in the decision
to use contractors is the availability of funds in addition to those required
to support present in-house projects. Assuming that additional funds are
available for the development of NSPS, use of contractors must be weighed
against the option of increasing in-house manpower resources.
The primary motivations for the use of contractors in the development
of standards are:
1. The limitations on available manpower are relaxed in terms
of both numbers and expertise in selected subject areas.
2. Involvement of outside personnel can broaden the overall
perspective on standard setting issues.
3. Major alterations in funding levels can be more easily
accommodated.
-------
199
These advantages are offset by the disadvantages of:
1. Extra time requirements of writing requests for proposals,
negotiating contracts, and monitoring performance.
2. Risk of inadequate performance by a contractor.
3. Future difficulties related to not having developed
in-house expertise.
4. Commitments of funds to contractor studies reduces
flexibility to shift goals or emphasis.
In order to establish effective policies in the use of contractors
in view of the above advantages and disadvantages, the following basic pre-
cepts will be useful.
The range of levels for in-house funding should consider long-range
needs. As a minimum, the EPA must develop a sufficient base of expertise
to defend promulgated standards in legal challenges and to evaluate standards
in post-promulgation reviews for consideration of possible revisions or addi-
tions covering new categories. As a coarse estimate, one staff person can
become sufficiently knowledgable to perform these post-promulgation activities
for 4 to 8 categories (depending on the assistance obtained through contrac-
tors) and there are approximately 200 categories, and thus the future EPA
manpower needs in this area will Be in the range of 25-50 staff persons,
although short-term needs may indicate larger manpower requirements.
Broad limitations can also be established in regard to the degree of
participation in standards development that is desirable by contractors. As
a minimum, certain standard development tasks for which the EPA has no current
expertise or equipment capabilities and for which, furthermore, it is not in
the long-term interest of the EPA to develop these capabilities, should be
contracted. Examples of such activities that should be given to contractors
are extensive source monitoring using existing methods and economic and social
impact analyses for particular standards for Environmental Impact Statements.
Organizations, such as the Industrial Gas Cleaning Institute, that have a unique
access to information, should also be involved in the standard development
procedure.
A second use of contractors is for preliminary studies used to develop
information required to finalize source priorities (Phase II) as discussed in
-------
200
Sec. 6.1. This provides for desirable early involvement of outside, expertise
in identifying needs for NSPS. This outside contracting would not affect
development of EPA expertise, which results primarily from experience gained
in compilation of the Standards Support Document in Phase III.
These high priority uses of contractors in supportive tasks and pre-
liminary studies should have only minor impact on cost per standard in com-
parison to in-house performance of these activities. The costs of contract
negotiation and monitoring should be offset by the efficiencies of contractors
whose selection is based on prior knowledge and experience.
The most extensive use of contractors is through their assignment
of the full responsibility for development of the first draft of the Standards
Support Document in Phase III. Allocation of funding for this use of contrac-
tors should only be considered after higher priority needs identified above
are fulfilled. In spite of the low priority given to this use of contractors,
it is the most significant in that it permits the largest increzise in rate
of standard development without increasing EPA staffing.
Through the use of contractors to completely develop the initial draft
on the Standards Support Documents, the maximum number of standards that could
be under development at any one time is attained. The upper limit results
from the need to avoid pitfalls indicated in the above list of disadvantages
of using contractors. The activities of the contractor must be monitored more
closely than in a typical EPA-funded contract for the dual purpose of (a) in-
suring adequate performance as required in a defendable Standards Support
Document and (b) allowing EPA to attain adequate expertise related to the
source category. In view of these constraints, approximately one half the time
of an EPA staff person would be required to oversee the contractor efforts
during the approximately 30 weeks required for development of the initial
draft Standards Support Document for each category,. Assuming subsequent
activities related to proposed standard review and promulgation cannot be
carried out by contractors, the total EPA staff time required for completing
Phases III through VII, Standard Promulgation, is reduced from an average of
100 manweeks for complete in-house development as indicated in the introduc-
tion to a minimum of 30 manweeks. For an EPA staff of 30 the standard promul-
gation rate could thereby be increased to approximately 50 per year.
-------
201
The assumptions presented above in relation to use of contractors for
full Standards Support Document initial draft development result in increased
EPA cost per standard. Assuming that the cost for initial draft development
is comparable if performed by the EPA in-house or by contractors, the 15 man-
weeks effort required by EPA to oversee the contract is the cost increment
for using contractors in this manner. However, there is an increased effective-
ness by way of reduced emissions resulting from a faster standard-setting rate.
Efficiencies in the use of contractors can be obtained by grouping
industries into broad categories and allocating to a single contractor the
responsibility to develop initial draft Standards Support Documents for all
categories within the grouping. This broader approach allows a more coordinated
analysis of related industries and permits the contractor to subcategorize indus-
tries in a manner that optimizes effectiveness of NSPS. A possible disadvantage
associated with simultaneous development of standards for all categories in a
grouping is that the chronological sequence dictated by source priority rankings
cannot be strictly followed. However, if the standards are being promulgated
at nearly the maximum rate, the loss associated with not following the ranking
will not be large.
The practice of grouping similar industries in a single contract
study has been used by the Effluent Guidelines Division of the EPA in their
development of water-effluent regulations. For example, all industries
primarily engaged in production of coal (Standard Industrial Classification
Major Groups 11 and 12) were studied under a single contract as were Machinery
and Mechanical Products Manufacturing, Mineral Mining, and Processing. Further
study of this practice as an NSPS development mechanism is needed to evaluate
its effectiveness.
A further implication of a decision to use contractors to completely
develop the initial Standards Support Document draft relates to organizational
structure of the EPA/ESED staff. The present practice of assignment of Indus-
trial Studies, Cost Analysis, Emissions Measurement, and Standards Development
tasks to separate organizational units would not be necessary or desirable
-------
202
since the first three of these tasks would be undertaken by the contractor.
The staff person, or team of staff persons, who are monitoring the contractor
performance would also be the most appropriate to carry through with the
Standard Development since they would have developed the greatest degree of
expertise related to the specific category.
6.5 DEVELOPMENT AND REVIEW OF FORMAL NSPS
ENVIRONMENTAL IMPACT STATEMENTS
While it is not legally bound to do so, the present EPA policy is
to prepare Environmental Impact Statements (EIS) for proposed NSPS and certain
other environmentally protective activities because of the resultant benefits.
Through evaluation and documentation of both positive and possible negative
expected environmental impacts of a proposed standard, the EPA obtains a more
substantial information base for decision-making and the proposed standard
thus becomes easier to defend and enforce.
The following subsections are a discussion of items that should be
given consideration in an EIS for a specific NSPS or for the general NSPS
program and how development and review of EIS relates to development and
review of the Standards Support Document.
6,5.1 Environmental Impact Analysis Related to a Specific NSPS
The following is a discussion of EIS contents that are necessary for
a NSPS. The listed points to be covered closely follows the guidelines
issued by the Council on Environmental Quality and EPA.
A description of the proposed action, a statement of its purposes,
and a description of the environment affected. The proposed action description
is sufficiently presented in other segments of the standard support document.
A statement on the purposes of the action is to include estimates of the total
emissions from the source with and without NSPS, percentages of total national
emissions for the pollutants affected, and the role of the particular standard
in the total national, state, and local air quality strategy. Background
information on the purpose can be provided by the study on cumulative impacts
of NSPS discussed later. Precise information on the location affected cannot,
of course, be provided; however, statements as to the general location
can be included (e.g., urban or rural). Also, projections based on historical
trends can be used to indicate regions expected to be most heavily impacted.
-------
203
The relationship of the proposed action to land use plans, policies.,
and controls for- the affected area. A NSPS will not in general have a
large direct impact on land use plans; however, indirect impacts may occur,
such as permitting greater industrial concentration due to reduced unit
emissions or restricting options for industrial development due to secondary
impacts.
The probable impact of the proposed action on the environment.
The positive impacts of reduced air emissions cannot be specified with
certainty; however, the range of impacts for any particular application
can be estimated in view of expected typical source size, existing regula-
tions, raw material composition, or other relevant factors. Secondary
impacts related to, for example, energy consumption, resource commitments,
and solid and liquid wastes should be included using as input the general
studies discussed below.
Alternatives to the proposed action, including, where relevant, those
not within the existing authority of the responsible agency. This section
should consider the relative impacts of alternate strategies such as retro-
fitting, growth control, development of substitute industrial products,
or no action.
Any probable adverse environmental effects that cannot be avoided.
This should be a brief section summarizing in one place those unavoidable
adverse effects discussed previously. A comparison should be made with
the expected environmental benefits.
The relationship between local short-term uses of man's environment
and the maintenance and enhancement of long-term productivity. This section
should show how the short-term effect of the NSPS on the affected source
economics and operations are related to the long-term benefits that will
be accrued as the result of environmental gains from reduced emissions.
Any reversible and irretrievable commitments of resources that would
be involved in the proposed action should it be implemented. This refers
primarily to an identification of labor and materials that will necessarily
be committed to the construction and operation of the emission control system.
-------
204
6.5.2 Envirormental Impact Analysis with General Applicability
Certain types of control systems with minor variations represent best
available technology for a variety of polluting sources. It would thus be
most effective to complete a comprehensive analysis of primary and secondary
environmental impacts, including cumulative effects of widespread use, for
that control system with only cursory consideration of the specific source
applications. The EIS relating to a specific NSPS based on use of that con-
trol system could then draw heavily on information from that general environ-
mental analysis.
Wet scrubbers are a prime example of a control system that could
benefit from an independent environmental impact study that contains more
detail than is possible in the statements for each specific application.
A comprehensive wet scrubber environmental impact analysis would include:
1. Characterization of water effluents and treatment
technology. The chemical and biological properties
of dissolved and suspended solids in the effluent
are a function of scrubber size and type, composition
of scrubbed gas, maintenance practices, normal and
abnormal operating conditions, and composition of
lime or other scrubber chemicals. The current state
of the art of the technology for treatment of these
effluents including settling ponds, chemical removal,
closed and open cycles, regeneration, etc. These con-
siderations should be directed as closely as possible
to the requirements and objectives of the Federal Water
Pollution Control Act of 1972.
2. Environmental impact of primary and secondary energy
requirements of scrubbers. Direct energy requirements
for the operation of various type and size scrubbers
depend on concentration of pollutants in the gas, scrubber
efficiency for various size particulates, and scrubbers'
age and maintenance practices. The significance of
secondary energy requirements such as for production and
transport of scrubber chemicals and treatment of water
effluents are included. By providing information on the
environmental impact of the consumption of a unit of energy
including the impact on availability of clean fuels, the
energy-related environmental impact of scrubbers can be
determined.
3. Solid-waste disposal. The quantities and physical and
chemical properties of solid wastes and slurries would
be described in detail for various types and sizes of
scrubbers in different applications. Of primary con-
cern is the polluting potential of the land fill disposal
-------
205
in terms of surface water runoff and groundwater
contamination. Both short-term and long-term effects
require consideration. The possibilities of alterna-
tive uses such as processing of wastes for use in
construction material should also be evaluated using
current knowledge.
4. Resource commitment and recovery. In addition to energy
requirements discussed above, the commitment or recovery
of other natural resource related to emission control
systems must be established. Examples are uses of large
quantities of chemicals in once-through systems and the
production of sulfur. The environmental impact of
production and consumption of these resources are in-
direct and possibly minor except for localized effects;
however, the relative importance must be documented.
Although the potential secondary environmental impacts of other types
of air pollution control equipment are not as extensive as for wet scrubbers,
these impacts should also be covered in detail in comprehensive studies that
could be referenced in environmental statements for specific applications. Of
particular importance is the impact of hydrocarbon emission control, which in
many applications with current technology requires energy-consuming afterburners.
For dry removal systems such as baghouses and electrostatic precipitators, a
comprehensive secondary impact evaluation would also be useful; however, the
expected impacts in terms of energy requirements and solid-waste disposal are
less severe and a less extensive effort is required for the analysis. Effluent
treatment and/or disposal must, however, be considered for precipitators utiliz-
ing liquids to flush collected particulates.
The cumulative environmental impacts of a group of NSPS may be signi-
ficant in spite of the fact that the impact from each NSPS taken singly is
relatively minor. Consideration of such a cumulative effect will become more
important in the future after large sources, which of themselves have a signifi-
cant environmental impact (e.g., power plants), have been controlled under NSPS
and attention is focused on numerous smaller sources. For this reason, effort
should be directed toward the development of a generic environmental impact
statement that considers the cumulative effects of both existing and planned
NSPS. Such a statement will be of increasing importance to EPA NSPS program
planning and for public justification of that plan.
-------
206
The positive aspects of such a statement would describe the importance
of the NSPS-induced reduction in emissions in the national air quality mainte-
nance strategy and show the relation of the NSPS program to other air quality
programs. Such a study would in many respects be an extension and more de-
tailed consideration of various analyses presented in this report. To the
extent possible, the cost effectiveness of the NSPS approach should also be
evaluated and compared with alternative approaches such as retrofit of exist-
ing sources.
6.5.3 Development and Review Procedures for EIS
Having defined the desirable contents for specific and general
Environmental Impact Statements for NSPS, consideration must be given to EPA
mechanisms for generating the statements, personnel and funding required, and
review procedures. These considerations are of importance because of the con-
flicting need to develop standards as soon as possible and the need to develop
meaningful and thorough impact statements.
The studies with general applicability identified above can be per-
formed largely independent of the development of any specific NSPS and as such
could be performed by EPA contractors. These studies primarily involve the
compilation, review, and analysis of existing information and would require
an initial effort of approximately 3-4 man-years with an on-going effort of
approximately 1 man-year for updating of the information and reassessing
impacts of on-going standards.
Although the EIS for specific pollutants as described above are
extensive, the additional manpower required should be less than 10% of the
total effort required for standard development. This small increment is
possible through the use of relatively standard formats making use of infor-
mation already contained in the support document or in the general statements
described above. For maximum coordination and efficiency, this additional
staff should be integrated into the existing organization as opposed to
being contained in a functionally separate group.
The CEQ Guidelines for EIS require review of the draft environmental
statements by appropriate federal agencies, the EPA, affected state and local
environmental agencies, and the public. With the exception of state and local
agency reviews, the current NSPS review procedure includes review by these
-------
207
entities. Since the precise location of future sources is unknown, review
by affected local agencies is not possible. However, by using the previously
discussed projection of regions that are expected to receive maximum impact,
the intent of this part of the review guideline can be carried out by requesting
these regions to review the EIS. Review by state and local agencies would also
be useful but should be at the request of the Regional Offices.
The distribution for review of the draft environmental statement
should occur simultaneously with the publishing of the proposed standard.
The CEQ Guidelines require that "to the maximum extent practicable no
administrative action ...is to be taken sooner than ninety (90) days after
a draft environmental statement has been circulated for comment." However,
Section 111 of the Clean Air Act requires promulgation of the standard within
ninety (90) days after the proposed standard is published and the EPA is
legally bound to this schedule. The schedule proposed in Sec. 6.3 provides
for 84 days before final action, which is not in major conflict with the CEQ
guidelines.
-------
208
APPENDIX A. Projected National Mobile Source Emissions
Projections of national mobile source emissions were computed from
the relation:
(Mobile source emissions, year Y) =
(Mobile source emissions, 1972)
,., _~,Y-1972 average emissions per vehicle, year Y
x (1.02) x = ; : c r~-—-, -, ^-.^
average emissions per vehicle, 1972
12
The National Emission Data System (NEDS), which was used to estimate
the 1972 mobile source emissions as shown in Table A-l.
Table A-l. 1972 NEDS Land Vehicle Emissions
Emissions
Pollutant 105 tons/year
CO 76.01
HC 14.61
NO 8.52
x
Particulates 0.52
SOY 0.51
The average emissions per vehicle for the various years were deter-
mined from Supplement 5 to Ref 20 which is the latest published EPA data on
vehicle emissio'ns. The emission factors for each model year for each
vehicle class includes appropriate weighting factors for deterioration, age
distributions, miles traveled for model year, and cold-start emissions.
Evaporative and crankcase hydrocarbon emissions are also added. For this
study, the low-altitude emission factors were assumed to apply nationwide.
No adjustments were made for region-specific Transportation Control Plans.
The second factor in the above equation simulated a 2% compound
growth rate in number of vehicle-miles traveled.
The projected total mobile source emissions are shown in Fig. A-l.
Because of the various assumptions used in this analysis, the projections
should not be considered as a precise portrayal of future mobile source
emissions, in particular because of possible changes in emission regulations.
-------
209
1990
Emission Projections for Mobile Sources
-------
210
However, the estimates should be sufficient to show trends of combined mobile
source emissions and the point source emissions analyzed in the main text of
this report.
One additional point needs to be emphasized. The NOX vehicle emission
rates used here assume that the statutory limit of 0.4 grams/mile will be
implemented in 1978. There is significant question as to if, and when, this
limit will actually be achieved due to amendments to the Clean Air Act
currently under consideration. Nevertheless, use of the 0.4 grams/mile
value here represents a conservative approach by assuming the best possible
control on mobile sources.
-------
211
ACKNOWLEDGMENTS
The authors gratefully acknowledge the efforts of various Individuals
and organizations whose assistance helped make possible the results documented
in this report. In particular, the authors wish to provide recognition to:
The U.S. Environmental Protection Agency for providing
financial support under Contract No. EPA-IAG-D4-0463.
Gary McCutchen and George Walsh of the USEPA, Emission
Standards and Engineering Division, for providing guidance
and technical assistance, and numerous other individuals
within the USEPA who provided insight into the standard-
setting process and control technology development programs.
The Research Corporation of New England for providing
the Model IV data.
Mr. Sam Wong at Argonne National Laboratory for assisting
in the evaluation of emission control technology.
Dorathea Seymour, Paul Studier, Robert Meyer, John Taylor,
and Kevin Francis of Argonne National Laboratory for
assisting in the data collection and analysis.
Sandra Bryant and Marjorie Brockman of Argonne National
Laboratory for typing of the manuscript.
Walter Clapper and Robert Neissius of Argonne National
Laboratory for preparation of the drawings.
-------
212
REFERENCES
1. Clean Air Act (42 USC 1857c-6) as amended in 1970.
2. A Legislative History of the Clean Air Amendments of 1970. Ser. No.
93-18, GPO. pp 125, 416-418, 804, 816, 893, 895. Jan. 1974.
3. Hopper, T. G., W. A. Marrone. Impact of New Source Performance
Standards on 1985 National Emissions from Stationary Sources.
The Research Corp. of New England. EPA Report No. 450/3-76-017
May 1976.
4. Ibid., Appendices A-F. EPA Report Nos. 450/3-76-018a,b,c,d,e,f,
450/3-76-019a,b,c. May 1976.
5. McCutchen, G. D. New Source Performance Standards - Present arid
Future. Proc. Fourth Ann. Ind. Air Pollution Control Conf.
Knoxville, Tenn. pp 7-34. March 1974.
6. Sherman, M. A., A. S. Kennedy, W. Horowitz. Forecasting New
Problem Areas in Air Pollution Control. Report prepared for
Office of Air Quality Planning and Standards, U.S. Environmental
Protection Agency by Energy and Environmental Systems Division,
Argonne National Laboratory. April 1975.
7. Clean Air Act Amendments of 1976, Report to the Committee on
Public Works. U.S. Senate. Ret>ort No. 94-717. March 1976.
8. Air Quality Implementation Plans, Prevention of Significant Air
Quality Deterioration. 39 FR 42509-42517, Dec. 1974.
9. Air Quality Implementation Plans, Maintenance of National Ambient
Air Quality Standards. 39 FR 25330, July 1974, and 39 FR28906,
Aug. 1974.
10. Guidelines for Air Quality Maintenance Planning and Analysis,
Volume 14: Designated Air Quality Maintenance Areas. EPA Report
No. EPA-450/4-75-002. Dec'. 1975.
11. Background Information for Proposed New Source Performance
Standards: Steam Generators, Incinerators, Portland Cement Plants,
Nitric Acid Plants, Sulfuric Acid Plants. USEPA, Office of Air
Programs. Aug. 1971.
12. 1972 National Emissions Report. EPA-450/2-74-012. USEPA Office
of Air and Waste Management. June 1974.
13. Projections of Economic Activity for Air Quality Control Regions.
Prepared by U.S. Dept. of Commerce for USEPA, Office of Air arid
Water Programs. Aug. 1973.
14. Project Management System/360. IBM Program Product. H20-0690-0.
Sept. 1969.
-------
213
REFERENCES (Cont'd)
15. FOCAS, A Network-based Project Management System. Westinghouse Elec.
Corp. Jan. 1974.
16. Background Information for Standards of Performance: Primary Aluminum
Industry. Vol. 1. Proposed Standards. EPA 450/2-74-020a. Oct. 1974.
17. Environmental Impact Statements, Statement of Policy. 39 FR 16186-16187.
May 1974.
18. Preparation of Environmental Impact Statements, Guidelines. 38 FR 20549-
20562.
19. Environmental Impact Statements, Procedures for the Voluntary Preparation.
39 FR 37419-37422. Oct. 1974.
20. Cirillo, R. R., T. D. Wolsko. Handbook of Air Pollutant Emissions from
Transportation Systems. ANL/ES-28. Argonne National Laboratory.
Dec. 1973.
21. Smith, A. E., N. F. Sather, M. A. Sherman. Role of New Source
Performance Standards in the Control of Potential Hazardous
Air Pollutants. Report to EPA/ESED. Dec. 1975.
22. Hurter, Jr., A. P. Flue Gas Desulfurization and Its Alternatives:
The State of the Art. Argonne National Laboratory. ANL/ES-39 (19TH).
23. Ponder, W. H. Status of Flue Gas Desulfurization Technology for Power
Plant Pollution Control. Paper presented at Thermal Power Conference,
Washington State University. Oct. 1974.
24. Rosenberg, H. S., R. B. Engdahl, J. H. Oxley, and J. M. Genco.
The Status of S02 Control Systems. Chem. Eng. Progr. , 71(5),
66(1975).
25. Murthy, K. S., H. S. Rosenberg, and R. B. Engdahl. Status of
Problems of Regenerable Flue Gas Desulfurization Processes.
Paper presented at 68th AIChE Annual Meeting in Los Angeles
Nov. 1975.
26. Symposium on Flue Gas Desulfurization Held in Atlanta, Georgia.
Vol. I and II. Nov. 1974. EPA-650/2-74-126-a and EPA-650/2-74-126-b.
Dec. 1974.
27. Bischoff, W. F. and Y. Habib. The FW-BF Dry Adsorption System.
Chem. Eng. Progr., 71(5), 59(1975).
28. McKinney, W. A. Pilot Plant Testing of the Citrate Process for SOa
Emission Control. Paper presented at Flue Gas Desulfurization
Symposium, Georgia. Nov. 1974.
29. Stouck, R. T., E. Gorin, and W. E. Clark. Consol Stack Gas Process for
S02 Removal. Paper presented at 68th AIChE Annual Meeting in Los
Angeles. Nov. 1975.
-------
214
REFERENCES (Cont'd)
30. Slack, A. V. Second Generation Process for Flue Gas Desulfurization -
Introduction and Overview. Paper presented at Flue Gas Desulfurization
Symposium, Georgia. Nov. 1974.
31. Brown, R. A., H. B. Mason, and R. J. Schreiber. Systems Analysis
Requirements for Nitrogen Oxide Control of Stationary Source.
EPA-650/2-74-091, Sept. 1974. NTIS PB 237 367.
32. Lachapelle, D. G., J. S. Bowen, and R. D. Stern. Overview of Environ-
mental Protection Agency's NOx Control Technology for Stationary
Combustion Sources. Paper presented in 67th AIChE Annual Meeting
in Washington, D.C. Dec. 1974.
33. Liptak, B. G. (Editor). Environmental Engineers' Handbook, Vol. 2
Air Pollution. Chilton Book Co., Radnor, Pennsylvania. 1974.
34. Kenner, W. The Occurrence of Nitrogen in Coal.. The Chemistry of
Coal Utilization. Vol. 1 (Lowry ed.) 1945.
35. Sarofim, A. F., G. C. Williams, M. Modell and S. M. Slater. Conversion
of Fuel Nitrogen to Nitric Oxide in Premixed and Diffusion Flames.
Paper presented at the 66th AIChE Annual Meeting in Philadelphia.
1973.
36. Koutsoukoo, E. P., J. L. Blumenthal, M. Ghassent, and G. Bauerle.
Assessment of Catalyst for Control of NOX from Stationary Power
Plants, Phase I. Vol. I & II. EPA-650/2-75-001a and EPA-650/2-75-
OOlb. Jan. 1975. NTIS PB-*239 745 and PB-239 746.
37. Natusch, D. F. S., J. R. Wallace, and C. A. Evans. Toxic Trace
Elements: Preferential Concentration in Respirable Particles.
Science, 183, 202 (1974).
38. Abbott, J. H. Performance of Particulate Control Devices on
Stationary Services. Paper presented in 67th AIChE Annual Meeting
in Washington, D.C. Dec. 1974.
39. Shannon, L. J. Control Technology for Fine Particulate Emissions.
NTIS PB-236 646. 1974.
40. Dorsey, J. A. and D. B. Harris. The Present Status of Particulate
Mass Measurements. Paper presented at EPA's Symposium on Control
of Fine-Particulate Emissions from Industrial Sources, San
Francisco. Jan. 1974.
41. Oglesby, Jr., S. and D. Teixeira. A Survey of Technical Information
Related to Fine-Particle Control. EPRI-RP 259. April 1975,.
42. Pilat, M. J. Measurement of Particle Size Distributions at Emission
Sources with Cascade Impactors. Paper presented at EPA's Symposium
on Control of Fine-Particulate Emissions from Industrial Sources.
San Francisco. Jan. 1974.
-------
215
REFERENCES (Cont'd)
43. Downs, W. Equimolar N0-N02: Absorption into Magnesia Slurry: A Pilot
Feasibility Study. Babcock and Wilcox Co., Research Center,
Alliance, Ohio. BW-4653. EPA-68-02-0022. Nov. 1971. NTIS PB 223
579/4.
44. Chappell, G. A. Development of the Aqueous Processes for Removing
NOX from Flue Gases. Paper presented for EPA by ESSO R. & E. Co.
EPA R272051. Sept. 1972. NTIS PB 214 053/1.
45. Accortt, J. I., A. L. Plumley, and J. R. Martin. Fine Particulate
Removal and S02 Absorption with a Two Stage Wet Scrubber.
JAPCA, 24(10), 966(1974).
46. Statnick, R. M. and D. C. Drehmel. Fine Particle Control Using
Sulfur Oxide Scrubbers. JAPCA, 25(6), 605(1975).
47. Chiyoda Chemical Engineering & Construction Co., Ltd. Tokyo, Japan.
The Chiyoda Thoroughbred 102 Simultaneous S02 and NOX Removal
Process. June 1975.
48. Hall, H. J. and W. Bartok. NOX Control from Stationary Sources.
ES&T, 5(4), 321(1971).
49. Tamaki, A. The Thoroughbred 101 Desulfurization Process.
Chem. Eng. Progr. 71(5), 55(1975).
50. Vogel, G. J., et al. Reduction of Atmospheric Pollution By the
Application of Fluidized-Bed Combustion and Regeneration of Sulfur-
Containing Additives. Annual report prepared by Argonne National
Laboratory. ANL/ES-CEN-1007 (1974), EPA-650/2-74-104.
51. Keairns, D. L., et al. Fluidized Bed Combustion Process Evaluation.
Phase II. Pressurized Fluidized Bed Coal Combustion Development.
EPA/650/2-75/027c. Sept. 1975. NTIS PB-246 116/8WP.
52. Cooper, D. W., L. W. Parker, M. Eugene. Overview of EPA/IERL-RTP
Scrubber Programs. EPA/600/2-75-054, NTIS PB-246 390/9WP. Sept. 1975.
53. Report on Sulfur Oxide Control Technology. U.S. Dept. of Commerce,
Commerce Technical Advisory Board. Sept. 1975.
54. Smith, J. R. (ed.). Scientific and Technical Assessment Report on
Suspended Sulfates and Sulfuric Acid Aerosols. Office of Research and
Development. U.S. Environmental Protection Agency. Washington, D.C.
55. Prioritization of Sources of Air Pollution. Monsanto Research Corporation.
Prepared for U.S. Environmental Protection Agency, Research Triangle Park,
N.C. under Contract No. 68-02-1320. July 1974.
-------
TECHNICAL REPORT DATA
(Please read Instructions en the rcveisc bcjorc completing)
1 REPORT NO.
EPA-450/3-76-020
2.
4.
AND SUBTITLE
rriorities and Procedures for Development of
--tandards of Performance for New Stationary
Sources of Atmospheric Emissions
6. PERFORMING ORGANIZATION CODE
7. AUTHOR(S)
Loren J. Habegger, Richard R. Cirillo,
Norman F. Sather
9. PERFORMING ORGANIZATION NAME AND ADDRESS
Energy and Environmental Systems Division
Argonne National Laboratory
Argonne, Illinois 60439
3 RECIPIENTT -CCESSICWNO.
REPORT DATE
_May_JL976
8 PERFORMING ORGANIZATION REPORT NO.
10 PROGRAM ELEMENT MO.
12. SPONSORING AGENCY NAME AND ADDRESS
Emission Standards and Engineering Division
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
11 CONTRACT/GRANT NO
EPA-IAG-D4-0463
Project _Np_.__2
13 TYPE OF REPORT AND PERIOD COVERED
Final __
14. SPONSORING AGENCY CODE
15. SUPPLEMENTARY NOTES
16. ABSTRACT
Because of the increasingly important role of New Source Performance
Standards in the national air quality program and the large number of
categories for which standards are being developed, a clearly defined
procedure for selecting category priorities and establishing schedules
for standard promulgation is a necessity. This report describes a
methodology that has been developed for selecting priorities and schedules
based on projected reductions in emissions resulting from the individual
standards and other considerations related to technological, legal,
institutional, and conservation factors. The methodology is used with
available data to develop an initial standard-setting program. The
program variations that result from alternate areas of emphasis are
also presented. The expected future developments in emission control
technology and various aspects of the process for developing standards
are reviewed in terms of how they may affect the long-term New Source Per-
formance Standards program.
17.
a.
KEY WORDS AND DOCUMENT ANALYSIS
DESCRIPTORS
Air Pollution
Stationary Sources
New Source Performance Standards
b.IDENTIFIERS/OPEN ENDED TERMS
COS AT I Field/Group
18. DISTRIBUTION STATEMENT
Release Unlimited
19 SECURITY CLASS (This Report)
Unclassified
21. NO. OF PAGES
216
20 SECURITY CLASS (This page)
Unclassified
22. PRICE
EPA Form 2220-1 (9-73)
------- |