Economic Impact Assessment for the Proposed Revisions to the EPA Stack Height Regulation Draft. November 1984 rev. li/1/84 ------- Table of Contents Subject page List of Table and Figures ii Executive Summary iii Introduction 1 Plume Impaction 7 Definitions of "Excessive Concentrations" and "Nearby" 11 Reliance' on the 2.5 H Formula 16 Limitations on the Use of the Formula 19 Definition of "Dispersion Techniques" 21 Prohibition on Credit for Tying New Facilities into Grandfathered Stacks Above GEP Height 26 Two-Stage Implementation Process 28 Automatic Credit for Formula Height 30 Estimate of Emissions and Economic Impacts 32 Append! x - Li st of References 41 ------- List of Tables and Figures page Table 1 - Summary of Estimated Impacts in 1995 of Proposed Revisions to the Stack Heights Regulation 6 Table 2 - Estimated Changes in Ambient Concentrations and Emissions Due to Prohibition of Credit for Combining of Stacks 24 Table 3 - Emissions Impacts in 1995 of Proposed Revisions to the Stack Height Regulation 35 Table 4 - Cost Impacts in 1995 of Proposed Revisions to the Stack Height Regulation 36 Table 5 - Number of Power Plant Units Affected by Proposed Revisions to the Stack Height Regulation - Low Impact Scenario 37 Table 6 - Number of Power Plant Units Affected by Proposed Revisions to the Stack Height Regulation - High Impact Scenario 38 Table 7 - Coal Production and Shipment Impacts in Year 1995 of Proposed Provisions to the Stack Height Regulation 39 Figure 1 - Map of United States Showing CEUM Demand Regions 40 11 ------- Executive Summary As required by Section 123 of the Clean Air Act, the Environmental Protection Agency (EPA) promulgated a regulation in 1982 that governed the extent to which tall stacks and other dispersion techniques could be relied on by emission source owners in lieu of constant emission controls. This regulation was challenged by the Sierra Club Legal Defense Fund, Inc.; the Natural Resources Defense Council, Inc; and the Commonwealth of Pennsylvania, On October 11, 1983, the U.S. Court of Appeals for the D.C. Circuit issued its opinion, overturning certain provisions of the regulation, upholding others, and remanding certain other portions to the Agency for reconsidera- tion. The mandate, formally issued on July 18, 1984, requires EPA to promulgate a revised regulation within 6 months, or by January 18, 1985. In terms of their impacts on emission sources, the most significant changes to the regulation concern EPA's redefinition of several key terms, "excessive concentrations," "nearby," and "dispersion techniques," and the court-ordered deletion of credit for plume impaction. Other changes are also being made, but either have no significant impact or have impacts that cannot be quantified. Both major and minor revisions to the regulation are discussed in the following report. The report considers two estimates of emissions and economic impacts, a "high impact," or worst-case scenario, and a "low impact" scenario that presumes that many potentially affected sources will, in actuality, be able to justify their stack heights, configurations and existing emission limitations. Rather than absolute impacts, this report presents findings in terms of the changes that will occur relative to the 1982 regulation that was overturned by the court. n ------- Under the "high impact" scenario, the analysis predicts that the revisions to the regulation will impose annualized costs of up to $1.4 billion and total capital costs of as much as $4.6 billion. The additional control requirements will yield reductions in S02 emissions of approximately 2.88 million tons per year. The "low impact" scenario predicts that annualized costs will run approximately $300 million, with total capital costs of $900 million. S02 reductions under this case are predicted to be approximately 790,000 tons per year. To a great extent, industries will be able to respond to these changes in the regulation through conversion to lower sulfur fuel. However, some sources will have to install additional control equipment, i.e., scrubbers, and there is likely to be some increase in reliance on those sources with scrubbers already in place. i v ------- Introduction Section 123 of the Clean Air Act requires that EPA promulgate regulations to define the extent to which dispersion techniques may be used in lieu of constant emission controls. Specifically, these regulations are intended to ensure that the degree of emission limitation required for the control of any air pollutant under an applicable implementation plan is not affected by tall stacks--!'.e., those in excess of good engineering practice—or by any other dispersion technique. Regulations governing credit for stack heights and other dispersion techniques were promulgated on February 8, 1982. Portions of these regulations were subsequently overturned or remanded to EPA for reconsideration and revision as the result of a suit filed in the U.S. Court of Appeals for the D.C. Circuit by the Sierra Club Legal Defense Fund, Inc., the Natural Resources Defense Council, Inc., and the Commonwealth of Pennsylvania [Sierra Club v. EPA, 719 F.2d 436 (D.C. dr., 1983), cert, denied, 52 U.S.L.W. 3929 (U.S. July 2, 1984)]. The Agency is presently proposing a number of revisions to the stack height regulation to comply with the court decision. These revisions address a number of important concepts, including definitions of terms such as "excessive concentrations," "dispersion techniques," and "nearby," and the basis for determining good engineering practice (GEP) stack height for all sources to which the regulation applies. The following report presents an assessment of the potential impacts of the proposed revisions to the stack height regulation in terms of emissions and estimated costs of compliance. The analysis was designed 1 ------- to focus primarily on sources affected by the changes in the definitions of excessive concentrations, the allowable use of terrain in fluid modeling, plume impaction, and the definition of dispersion techniques (discussions of the expected impacts of other aspects of the regulation are also included in this assessment, however). Furthermore, to make the scope of the analysis reasonable, environmental and economic impacts were analyzed only for power plants. However, The Agency also attempted to identify potentially affected smelters and pulp and paper mills. Using several data bases, EPA identified those sources potentially affected by revisions to the regulation. For purposes of this assessment, the Agency presumed that sources with stacks in excess of the 65 meter de minimis height and constructed after December 31, 1970, are subject to the regulation and thus, are potentially affected. However, since many of these sources will, in actuality, not be affected by the revised regula- tion--i.e., they will be able to justify their existing stack heights, configurations and emission limitations—the impacts stated in this report are generally expected to be greater than the actual impacts of the revised regulation. Wherever possible, the Agency has produced high and low estimates of emission changes and economic impacts likely to result from the combina- tion of the specific changes in the regulation that were analyzed. In both cases, the estimates tend to err on the side of greater impact, as noted above, in that more source owners are likely to be able to justify their present stack configurations and emission limitations than EPA is assuming in this assessment. Rough estimates of the individual impacts of each of the changes were derived from the compound estimates; however, the compound estimates ------- should be viewed as more accurate than these estimates of individual impacts for several reasons. First, it was impossible, given the scope of the analysis, to disaggregate the effects of individual changes on sources affected by more than one change. Second, the industry's response to each change will affect coal markets, and will therefore influence the cost of responding to other changes. Finally, the limitations of the analysis do not enable cost and emission impacts at specific plants to be evaluated separately; thus, the impacts on sources affected by any one change cannot be perfectly disaggregated from impacts on other sources. The assessment also considered the impacts of the proposed revisions in the absence of other regulatory requirements. The actual impacts of the proposed regulation could be greater or less, to the extent that other regulations impose more stringent requirements or affect the degree of emission limitation required for individual sources. Examples include cases where the new source performance standards (NSPS) impose an emission limitation on a source that is more stringent than any revisions mandated by the revised stack heights regulation, and where a revised ambient air quality standard requires a greater level of emissions control than presently exists. In the first example, the revised stack height regula- tion would have no practical impact on a source; in the second, the revised regulation could impose additional costs by restricting the extent to which sources may comply with stricter air quality standards through the use of dispersion techniques. The assessment used the 1982 regulation as a baseline; i.e., rather than evaluating the total emissions impacts and compliance costs, it considered only the changes to source emission limitations that will be ------- needed as a result of imposing the requirements of the proposed revisions rather than the requirements of the 1982 regulation. This assessment was constrained by a lack of data necessary for more detailed evaluation and by the severe time constraint imposed by the court- ordered 6-month proposal and promulgation deadline. Lack of the following information imposed the most significant constraints: 1. source-specific information on building dimensions needed to more accurately estimate GEP stack height where sources must reduce their stack height credits; 2. site-specific background air quality and meteorological data needed to adequately model changes in emission limitations for each source affected by the regulation; and 3. more detailed terrain data than was possible to collect in the time available. Even if the Agency had sufficient resources to collect and adequately analyze all of the data needed for a more thorough assessment, the 6-month deadline imposed by the U.S. Court of Appeals would limit the scope and level of detail for this assessment to that presented in the following report. This report will describe, individually, each aspect of the Court of Appeals decision, how the Agency has responded to it in the proposed regulation, the methodology used in conducting the assessment of impacts, and the results of the analyses. Sources may be affected by several changes to the regulation; in this event, the impacts on source emission limitations, and resulting costs, are not necessarily cumulative, but rather may be functions of the most limiting aspect of the revised regulation. ------- It is important to note that the report provides an estimate of the approximate costs to emission source owners of the changes to the regulation; the assessment does not attempt to estimate the benefits that would accrue from the reduction in $63 emissions as a result of the revisions to the stack heights regulation. Such analyses would far exceed the time and resources available to the Agency at this time. Reductions in S02 emissions resulting from the revisions are expected generally to yield benefits in terms of reduced atmospheric loadings, acid deposition, and regional haze. Table 1 provides a summary of the total estimated impacts of the proposed changes to the regulation. More specific information about the effects of specific changes to the regulation can be found in the following sections. All impacts are projected for the year 1995 and assume total compliance with the regulation by the year 1990. A variety of information sources were used for this assessment and are summarized in an appendix to this report. ------- Table 1 Summary of Estimated Impacts in 1995 of Proposed Revisions to the Stack Heights Regulation* S02 Reductions Annualized Costs** Capital Costs*** Average Cost per ton of Sulfur removed Retrofit Scrubber Capacity**** Low Impact Scenario 790,000 Tons $300 Million $900 Million $395/Ton 4.0 Giqawatts High Impact Scenario 2.88 million Tons $1.4 Billion $4.6 Billion $493/Ton 17.4 Gigawatts * All costs are given in 1984 dollars. ** Includes amortized capital costs, operation and maintenance, and fuel costs, *** Cumulative through 1995. **** Refers to the quantity of electrical power produced by units whose emissions are reduced through the use of scrubbers. ------- Plume Impaction Description of Change The 1982 regulation allowed sources to take credit for building their stacks above GEP height to avoid plume impaction, i.e., high pollutant concentrations that occur when a plume contacts elevated terrain (e.g., a hillside) before it can disperse sufficiently. In its ruling, the Court of Appeals held that the Agency exceeded its statutory authority in allowing credit for the additional height, and reversed this portion of the regulation. In developing the proposed regulation, EPA has deleted credit for plume impaction. The effect of this deletion will be to require sources that could previously have received such credit--i.e., sources with plume impaction problems—to address the problem by reducing their emissions instead. Review of Potentially Affected Sources To estimate the number of sources that may be affected by this change, the Agency drew, from its inventory of sources with stacks exceeding the 65 meter de minimi's height and constructed after December 31, 1970, those sources with terrain features greater than GEP stack height within 25 km (15 miles) of the stack.1 These sources are identified in the draft report, conduct this analysis, the Agency relied on regional estimates of GEP stack height that were developed in 1980 to evaluate the 1981 proposed stack height regulation. These estimates were obtained from actual plant data collected from an inventory of 102 plants. The calculation of actual GEP formula heights would have required information on the dimensions of buildings near each of a large number of sources; such information is not readily available and could not have been obtained within the time available to the Agency for this proposal. It is important to note that this informa- tion was collected and analyzed solely for the purpose of estimating the range of probable impacts on changes to the regulation; it should not be construed as implying that any of the identified sources are, in fact, affected by a specific change in the regulation. ------- "Evaluation of Sources Affected by Revisions to the Stack Height Regulations," GCA/Technology Division, September 1984. The rationale for focusing on this particular relationship to terrain is that EPA believes that plume impaction may be significant--!.e., impaction tion may affect the emission limitation for a source—when terrain features exist within 25 km of the stack (plume impaction will not necessarily occur whenever this condition is fulfilled). Method for Evaluation Plume impaction cannot be reliably predicted to occur based on the simple existence of terrain features within 25 km of a stack. Plume impac- tion is sensitive to a number of considerations, including wind direction, wind speed, and atmospheric stability. Furthermore, even where the highest concentrations are predicted to occur in elevated terrain, due to plume impaction, such concentrations may not represent the controlling situation for the source. For example, a lower concentration may be predicted to occur elsewhere where it would violate a PSD increment. In this instance, the source may be required to control its emissions to a greater degree to eliminate the violation than it would be to eliminate the predicted plume impaction problem. Actual plume impaction must therefore be evaluated on a case-by-case basis by conducting field studies or appropriate modeling. In this respect, the Agency has conducted a worst-case analysis by presuming that all potentially affected sources would be required to reduce their emissions. To estimate the effect on source emission limitations of deleting plume impaction credit, EPA presumed that potentially affected sources would not be able to justify stack height credits above GEP formula height, and calculated revised emission limitations accordingly. EPA then selected ------- a representative source from each region, based on the relationship between the source and surrounding terrain. These sources were modeled at the estimated GEP stack height, using the VALLEY model, to determine the appro- priate revised emission limitation (see footnote 1 regarding estimated GEP height). The results of these analyses were then extrapolated to other potentially affected sources within each region. The results of this stage of the analysis are described in the draft report, "Evaluations of Sources Affected by Revised Stack Height Regulations," GCA/Technology Division, September 1984, and indicate that no change in allowable emissions would result if the surrounding terrain were greater than 500 to 750 feet above the actual stack height. The Agency determined that this result was reasonable.2 Based on the results obtained from modeling the representative sources at which the height difference was less than 500 to 750 feet, the Agency developed a formula for predicting the expected reduction in allowable emissions as a function of the net defference in height between the top of the actual stack and the surrounding terrain.3 The formula predicts that allowable emissions will decrease by about 54 per- cent for sources where there is no net difference in height, and that there would be no decrease for sources where the net difference is greater than 600 feet. For the "high impact" scenario, the Agency assumed that allowable emissions at all of the 60 sources identified as potentially affected were reduced in accordance with the formula. For the "low impact" scenario, the 2Memorandum to the Files from David Stonefield regarding plume impaction estimates; October 25, 1984. 3Memorandum to the Files from Stephen Greene regarding derivation of the formula predicting reductions in emissions as a function of the difference between actual stack height and surrounding terrain height; October 31, 1984. ------- Agency assumed that only those 32 sources identified as potentially affected and having terrain within 0.8 km (1/2 mile) below 40 percent of GEP height would be required to reduce their allowable emissions. Under this scenario, other sources potentially affected by the plume impaction provisions were presumed to be able to justify their actual stacks through fluid modeling, and would therefore not incur plume impaction effects. 10 ------- Definitions of "Excessive Concentrations" and "Nearby" Two changes to the regulation are being made that may significantly affect requirements for field studies and fluid modeling demonstrations: revisions to the definition of "excessive concentrations" and to the definition of "nearby." In both cases, estimates of affected sources include those that have conducted, or may in the future conduct fluid modeling and field studies to justify credit for stack heights in excess of those established through the use of the GEP formulae. The effects of these changes to the regulation are closely interrelated. Consequently, while it is possible to make some estimate of the numbers of sources affected by each change, calculating their effects on source emission limitations and resulting costs cannot readily be disaggregated. For this reason, the assessment considered the revisions to the definitions of "excessive concentrations" and "nearby" in combination for the purpose af analyzing their economic impacts. The following is a description of the changes proposed, and the sources potentially affected by each change. Description of Change - "Excessive Concentrations" Section 123 of the Clean Air Act allows sources sufficient credit for stack height to avoid excessive concentrations of an air pollutant due to downwash. In the 1982 rule, EPA defined "excessive concentrations" as a 40 percent increase in ground-level concentrations over what is predicted to occur in the absence of downwash. This definition was rejected by the court as not responding adequately to public health and welfare concerns. Consequently, the Agency is proposing a revised definition that requires, in addition to the 40 percent increase, that downwash result in an exceedance 11 ------- of the applicable NAAQS or PSD increment before sources may gain credit for greater stack height. Review of Affected Sources The "high impact" analysis presumes that none of the 190 sources with stacks greater than GEP formula height will be able to show that such stacks are needed to avoid excessive concentrations, as that term is redefined, and will therefore be required to reduce their credits to those allowed by the formula. EPA believes it is more likely that many sources conducting fluid modeling to determine the effects of elevated terrain within 1/2 mile of the source will be able to show that such terrain produces downwash, wakes, and eddy effects resulting in excessive concentrations. However, it is not possible to refine significantly the Agency's estimate of sources affected by this change in the regulation without actually conducting fluid modeling for each of the potentially affected sources. Description of Change - Definition of "Nearby" The 1982 regulation allowed sources to base their GEP stack heights on formulae that considered the dimensions of nearby structures. The Agency defined "nearby" for this purpose to be 5 times the lesser of the height or width of such structures, but not more than 1/2 mile. Sources who wished could also demonstrate GEP stack height through fluid modeling to assess the actual effects of structures and terrain features of downwash in the vicinity of the source. For this latter demonstration, the Agency applied no distance restriction. The Court of Appeals held that EPA had acted improperly by not heeding Congressional intent to establish an arbitrary limit on the extent to which sources could increase their stack heights to account for terrain effects. In remanding this provision to EPA, the court 12 ------- directed the Agency to apply the same limitation to fluid modeling as to formula calculations. To respond to this directive, EPA is requesting comment on several alternatives to the application of the distance limitation in fluid modeling demonstrations. A 1/2 mile limitation forms the basis for each of these alternatives. Review of Affected Sources Eighty-one existing sources are potentially affected by this revision in that they do not have terrain features greater than 40 percent of the GEP formula stack height within 0.8 km (1/2 mile) of the stack. (See footnote 1 for a discussion of the GEP height used.) These sources are presumed to be unable to demonstrate downwash sufficient to justify taller stacks.4 This is clearly a worst-case presumption, for many of these sources would be unable to demonstrate downwash in a fluid model even under the current regulation. These sources represent a subset of the sources potentially affected by the proposed change in the definition of "excessive concentration" (under the "high-impact" scenario). Thus, the impacts on these sources were not evaluated separately. Method for Evaluation Impacts were determined by assuming that each of the affected sources had either considered terrain farther away than 0.8 km in its fluid modeling or had demonstrated a 40 percent increase in concentrations that did not exceed an ambient standard. Consequently, stack height credit for these the revisions, these sources would be unable to include terrain further from the source into a fluid model. Empirical observations show that terrain features greater than 40 percent of stack height are necessary to produce sufficient downwash to justify increasing stack height. 13 ------- sources was presumed to be restricted to the average GEP height for the appropriate region. (See footnote 1 for a discussion of regional GEP heights). Changes in emission limitations were calculated using the more stringent of either the plume impaction derived estimate or a ratio developed by H.E. Cramer & Company, Inc. that relates emissions from a stack at actual height to emission from a source at GEP height (see Cramer study in Docket A-79-01 Appendix C). The results of this analysis therefore presume that all of the potentially affected sources would have been able to justify their actual stack heights under the 1982 regulation, but will be unable to justify these stacks under the proposed regulation because of the changes in the definition of "excessive concentrations" and the allowable use of terrain in fluid modeling (i.e., the definition of "nearby").. Impacts resulting from these aspects of the proposed regulation were applied only under the "high impact" scenario of the analysis. Very few sources have actually used fluid modeling to justify their emission limits even under the current regulations.5 Thus, the "low impact" scenario assumes that sources found to have stacks above the regional GEP height nonetheless would be unaffected by the revisions that apply to fluid modeling demonstrations. This might be the case if these sources can justify their stacks by applying the formulae to site-specific data, or if these sources are already complying with the limits corresponding to GEP height. If a source was determined to be potentially affected by the deletion of plume impaction from the regulation, as well as the provisions discussed 5The Agency is presently aware of nine fluid modeling studies that were used to establish emission limitations; three in Region III and six in Reqion V. 14 ------- here, then, as noted previously, only the greater of the emission reductions resulting from the proposed regulation was applied to the source. Reductions resulting from the changes in the definition of "dispersion techniques," however, were assumed to compound the effects of other changes. 15 ------- Reliance on the 2.5H Formula Description of Change EPA's regulation provides several bases for determining GEP stack height. Among these are two equations that base stack height on the dimensions of nearby structures; sources constructed before January 12, 1979, could take credit for 2.5 time the height of nearby structures, while sources constructed after that date were required to use a somewhat more conservative formula (H + 1.5L) that minimized the likelihood that struc- tures with greater heights than widths might receive more credit than needed to avoid excessive concentrations due to downwash. In its ruling, the court held that EPA should not have automatically allowed pre-1979 sources to take credit for the 2.5H formula in establishing their emission limitations, but should require evidence that the sources actually relied on this formula in the design of their stacks. This change has been incorporated into the proposed rule, with a request for comment on what the Agency should consider acceptable evidence of such reliance. Review of Potentially Affected Sources Any source constructed after December 31, 1970, and before January 12, 1979, and with a stack greater than or equal to the 2.5H formula height could be affected by this change in the regulation. For reasons discussed under "Results," below, an inventory of such sources was not prepared. Method for Evaluation To assess the worst-case impacts of this change in the regulation, i.e., presuming that no source could demonstrate reliance on the 2.5H formula, it would be necessary to obtain the heights and projected widths of all potentially affected sources, calculate their GEP stack heights using the 16 ------- H + 1.5L formula, and compare the resulting emission limtations to those presently applicable to the sources. However, information about the dimensions of those structures forming the basis for individual GEP stacks is not readily available. Again, for reasons discussed below, this analysis was not performed. Results As previously noted, the proposed rulemaking notice requests comment on what the Agency should consider as acceptable evidence of reliance on the 2.5H formula. Regardless of the approach selected in the final regula- tion, however, the Agency believes that the impact of the change in the rule will be minimal and largely procedural in nature. EPA has issued a substantial amount of guidance in the past on source permitting and the calculation of emission limitations to State and local agencies, as well as to source owners and operators, much of which has addressed approaches to determining GEP stack height, based on the 2.5H formula (e.g., the 1976 stack heights rule, 41 FR 7150). Consequently, the Agency believes it unlikely that a significant number of sources will be unable to demonstrate reliance on the 2.5H formula in an acceptable fashion. Furthermore, while the H + 1.5L formula is more conservative in its assignment of stack height credit, the refinements to the formula arose out of observations made during fluid modeling research concerning windflow patterns around objects of differing shapes, and not out of any particular concerns that the 2.5H formula significantly overpredicted GEP stack height-- i.e., that credit allowed under the 2.5H formula resulted in less stringent emission limitations. 17 ------- The Agency believes that for the few sources that may be unable to demonstrate reliance on the 2.5H formula, the change in emission limitation resulting from the application of the H + 1.5L formula is not likely to be significant. Consequently, EPA has not assigned any economic impact to this provision of the regulation. 18 ------- Limitations on the Use of the Formula Description of Change EPA's 1982 regulation did not restrict credit for the use of the GEP formula to any category of structures, but allowed emission limitations to be set based on the formula for any structure. The court, in remanding the definition of "excessive concentrations" to the Agency for reconsideration, directed EPA to consider how well the formula protected against excessive concentrations and whether the formula provided more credit than needed to avoid excessive concentrations due to downwash. The Agency has responded by reaffirming the use of the formula, but prohibiting its use in two general cases where it is believed that the formula may provide too much stack height credit: (1) where structures are porous, so as to allow a portion of the wind contacting them to pass through, rather than over and around, them; and (2) where structures are aerodynamically smoother than the typical block-shaped structures on which the formula was based, thereby potentially creating less disturbance of windflow patterns. Review of Affected Sources While not addressed in the regulation or in the Agency's arguments in Sierra Club v. EPA, the "Guideline for Determination of Good Engineering Practice Stack Height," which served as technical support for the 1982 regulation, did not allow sources to base GEP credit on porous structures. Consequently, no sources are affected by the more explicit restriction of credit in the proposed regulation. EPA is not presently aware of any sources that have based their stack heights on the dimensions of aerodynamically smooth structures. Consequently, the only impact of this additional restriction to the use of the formula 19 ------- would be a cost savings foregone by sources that might have attempted to base their stack heights on such structures in the future. This effect cannot be quantified, as the number of such sources cannot be predicted. Finally, the proposed regulation allows agencies to require fluid modeling or field studies to demonstrate GEP stack height. It is possible that a State or local agency may wish to more narrowly restrict formula stack height credits by requiring fluid modeling for a more extensive range of sources. It is not possible to predict the number or type of situations where this may arise, or the effects of increased fluid modeling beyond noting that additional costs of approximately $50,000 to $100,000 will result for each additional study performed. Because, as noted in the preamble to the proposed regulation, the GEP formula is somewhat conservative in estimating the stack height needed to avoid excessive concentrations, an overwhelming majority of fluid modeling studies conducted in the past have resulted in justifications of greater, rather than less, stack height. For this reason, any increase in the number of fluid modeling studies performed is not likely to impose additional emission control costs resulting from more stringent emission limitations. 20 ------- Definition of Dispersion Techniques Description of Change In February 1982, EPA promulgated a relatively narrow definition of "dispersion techniques." That definition covered: 1. Stack heights above their GEP height. 2. Varying the rate of emissions with atmospheric conditions or ambient concentrations. 3. Addition of fans or reheaters in order to obtain a less stringent emission limitation. Specifically excluded from coverage were: 1. Reheating the gas stream following use of a pollution control system. 2. The use of smoke management. 3. Combining of exhaust gas streams. The U.S. Court of Appeals remanded that definition to EPA for reconsideration on the grounds that it was too narrow. The EPA has reviewed the 1982 definition and is proposing to make two changes to the general part of the definition. 1. Clarify that varying the rate of emission with atmospheric conditions or ambient concentration does not apply to episodic controls on resi- dential wood burning or debris burning. 2. Expanding the definition to cover manipulating source process parameters, exhaust gas parameters, stack parameters, or combining exhaust gases from several existing stacks into one stack; or other selective handling of exhaust gas streams so as to increase the exhaust gas plume rise. 21 ------- In addition to excluding from coverage the reheating of exhaust gases following use of a pollution control system, the proposal also excludes the merging of exhaust gas streams following pollution controls. Review of Affected Sources The first change simply makes it clear that varying the rate of emission with atmospheric conditions or ambient concentrations does not apply to episodic controls on area sources. This change will not have any impacts, since it is only a clarification of existing policy. To determine the impacts of including combining stacks as a dispersion technique, the E. H. Pechan Associates' "SIP data file" was reviewed to determine the number of stacks that served more than one boiler. That review identified 294 multi-unit stacks in the nation. Some of the 294 stacks serve units which came on line as early as the 1920's; thus, combining of stacks has been a traditional engineering practice. Only 54 of those stacks serviced units which came on line after 1970, and for these, it was impossible to determine whether the stacks had been constructed before 1971 (sources which combined stacks before 1971 would have a dispersion technique implemented before passage of the Clean Air Act and thus would be grandfathered). In addition, any facility with multiple stacks could potentially combine those stacks in the future (although for a number of engineering and economic reasons, doing so would not be possible or advantageous at some facilities). Thus, it was not possible to identify a list of sources that might potentially be affected by the revisions. EPA therefore reviewed SIP revisions involving S02 emission limits and identified those that involved combining of existing stacks. That review identified 30 sources that might be expected to be affected by the revisions. 22 ------- Fifteen sources were power plants, six were pulp and paper mills, and nine were other industrial sources. Method for Calculating Impact Calculating the effect of limiting the credit that sources may receive for combining stacks requires an evaluation of the change in the ambient concentration as a result of combining of the stacks. Mo general ratio can be developed since the relationship depends upon site-specific conditions such as the ratio of effective stack height to physical stack height and the plume rise under the controlling meteorological conditions. Therefore, to estimate the impact, EPA reviewed the change in ambient concentrations as a result of combining stacks from a typical 900 MW power plant and a typical 144 MW industrial source.6 The review looked at 3- and 24-hour averaging times and two different meteorological data sets. From that review, one set of meteorological data and one averaging time were selected as representative of the change in ambient concentrations for these sources. Since most of the sources which were identified as combining stacks are located east of the Mississippi River, the Atlanta/Athens, Georgia meteorological data set was selected as the more representative. The maximum change in ambient concentration is generally for the 24-hour averaging time, thus that averaging time was also selected for this analysis. Table 2 illustrates the estimated decrease in ambient concentrations that result from combining stacks, and the decrease in emissions expected to be required if credit for the stack combinations are disallowed. For power plants, combining four stacks into two was found to reduce ambient concen- trations by 41 percent, and combining four stacks into one was found to ^Memorandum from Johnnie Pearson to Dave Stonefield, "Investigation of Potential Impacts of Combining Stacks," October 4, 1984. 23 ------- Table 2 Estimated Changes in Ambient Concentrations and Emissions Due to Prohibition of Credit for Combining Stacks Combining Stacks From To 3 2 3 4 5 6 2 1 1 1 1 1 Power Ambient Red.* 28 4.^**** 54 68**** 81 95 Plants Industrial Plants Emission Red.** Ambient Red. Emission Red. 22 29 35 40 45 49 N/E*** 41**** 29 50 33 59**** 37 77 44 N/E*** * Percent reduction in ambient concentrations achieved by combining stacks. ** Percent reduction in emissions required to compensate if credit for combining stacks is disallowed. *** Not estimated; no source with this stack configuration identified. **** Value from modeling typical plant. Other values were estimated based upon these values. 24 ------- reduce ambient concentrations by 68 percent. For industrial plants, combining four stacks into two was found to reduce ambient concentrations by 41 percent; combining four stacks into one was found to reduce ambient concentrations by 59 percent. A straight line interpolation between and extrapolation beyond those points was assumed to estimate the change in ambient concentra- tions resulting from other types of stack combinations. New emission limits were calculated to compensate for the increased ambient concentrations that would result if these sources were assumed to have separate, rather than combined, stacks. These limits are based on the conservative assumption that the existing emission limits are those just necessary to meet the NAAQS or applicable PSD increments. In addition, it was assumed that no power plant would have to reduce its emission below 1.2 pounds of sulfur per million Btu, the NSPS limit. Results The results indicate that 13 of the 15 power plants identified as using combined stacks would have to reduce their emissions; the average reduction would be 37 percent. (Two power plants have existing limits equal to or less than 1.2 Ibs/MMBtu, and one is projected to have to reduce its emissions to 1.2 Ibs/MMBtu.) Six pulp and paper mills would have to reduce their emissions an average of 30 percent, and nine other industrial sources would have to reduce their emissions an average of 31 percent. 25 ------- Prohibition on Credit for Tying New Facilities to Grandfathered Stacks Above GEP Height Description of Change In the February 1982 promulgation, EPA grandfathered stacks "in existence" on December 31, 1970, the date of passage of the Clean Air Act. However, EPA did not prohibit new sources, which tie into the grandfathered stacks from receiving credit for the stack heights which exceed GEP heights. The U.S. Court of Appeals remanded "this issue to allow the Agency to explain why it refused to prohibit tying new sources into pre-1971 stack heights." After review of the issue, EPA could not adequately justify not prohibiting such credit, and is now proposing such a prohibition on such credit. Thus, new sources which tie into grandfathered stacks above GEP will only receive credit for the GEP height. Review of Affected Sources The E. H. Pechan Associates' "SIP Data File" of power plants was reviewed to determine the number of power plants which have combine exhaust gas streams from pre- and post-1970 units. That list was compared with the regional survey of stacks conducted in conjunction with the 1981 impact analysis and information from other sources. EPA could not identify any power plants which received credit above GEP for tying in a post-1970 unit to a pre-1971 stack. Only one industrial source was identified as receiving credit above GEP for tying new unit into a grandfathered stack, a aluminum smelter in the State of Washington which received a PSD permit based upon use of an existing stack. 26 ------- Method for Calculating Impact Since only one source was identified as receiving credit above 6EP for tying new units into a grandfathered stack, the technical analysis for that source PSD permit (included in the docket) was reviewed. As part of the BACT evaluation, the source stated that it could reduce its S02 emission enough (approximately 800 tons per year) to be exempt from the PSD regulations if it installed a S02 scrubber on part of its emissions. The source estimated it could install that scrubber for $7.5 million. Results The maximum cost for the one source which received credit above GEP for tying new units into a grandfathered stack will be $7.5 million. For a twenty year useful life and a 4.2 percent lost opportunity cost, the annualized cost would be $560,000. However, that is the cost of reducing the emissions enough to exempt the source from the PSD regulations and it may be possible for the source to meet the PSD requirements at a lower cost. 27 ------- Two-Stage Implementation Process Description of Change In the preamble to the 1982 regulations EPA provided for a two-stage process for State implementation of the regulation. This process allowed 9 months for the preparation and submittal of State rules complying with the final stack height rules, 4 months for EPA review and approval, and an additional 9-month period for the States to review and revise emission limits to be consistent with the EPA approved state rules. The court found that this 22-month period between final promulgation of EPA stack height rules and the submission of State revised emission limits to be contrary to Section 406(d)(2) of the Clean Air Act and reversed the Agency's two-stage plan. Under Section 406(d)(2) States are required to submit within 9 months of the promulgation of final stack height regulations any necessary State rule revisions as well as emission limitations modified to be consistent with this regulation. Relative to the 1982 regulations, the major impact of this change will be the shortened time allotted for the submittal of SIP's. Within this period States would have to examine the SIP's for major sources to determine if the new regulations would affect the manner in which the existing SIP was calculated. If so, then a SIP revision would be required to be submitted for such plant. Review of Affected Sources While this process will be taxing on limited staff and resources at the source, local, State, and Federal levels, EPA does not believe that this process would result in a different emission limit than that which would be determined in a 22 month process. Thus, EPA does not believe that this change will result in a significant economic impact. 28 ------- Admittedly, for a facility which may wish to conduct a fluid modeling analysis, the lost time (13 months) could limit the opportunity for such an analysis and could be valued in terms of lost opportunity costs. Relative to a SIP emission limit change EPA believes that this cost would be negligible. 29 ------- Automatic Credit for Formula Height Description of Change The 1982 regulations contained several bases for the determination of GEP stack height. The first approach was to establish a de minimis stack height of 65 meters. Stacks would be allowed credit up to de minimis height without any additional demonstration required. The second approach was the use of formulae which calculated GEP stack height based on the dimensions of nearby structures. The third approach based GEP stack height on fluid modeling analyses or field studies of downwash, wakes, and eddy effects due to nearby structures or terrain obstacles. In its decision, the court found that EPA had not sufficiently established the adequacy of the formulae, holding that there was a reasonable possibility that the formulae provided more stack height credit than neces- sary in certain circumstances to prevent excessive concentrations due to downwash, wakes or eddy effects. Furthermore, the court held that the regulations allowed sources to increase the height of their existing stacks up to that allowed by formula without a demonstration that such an increase was necessary to avoid excessive concentrations due to downwash, wakes, or eddy effects. For this reason, the court remanded the definition of GEP stack height to EPA to consider how well the formulae protect against excessive concentrations and whether they are sufficiently reliable to preclude the need for demonstrations to justify increasing the height of existing stacks. Based on a reanalysis of the validity of the formulae and the conclusion that the formulae are typically conservative in establishing GEP heights relative to the use of fluid modeling, EPA generally intends to continue to allow sources to raise existing stacks up to formula height without requiring 30 ------- demonstrations (the technical conclusions are fully discussed in the "Guidelines for Determination of Good Engineering Practice Stack Height," September 1984, submitted to the docket of this proceeding). Consequently, no sources are affected by this aspect of the revisions to the regulation. 31 ------- Estimate of Emissions and Economic Impacts Based on the information developed as described in the preceding sections, forecasts of emissions changes, utility cost and fuel consumption, and coal production were conducted. The ICF Incorporated Coal and Utilities Information System (GUIS) was used to relate the effects of the proposed regulations to individual power plant units and calculate applicable reduc- tions in sulfur dioxide emissions. ICF's Coal and Electric Utilities Model (CEUM) was then used to perform the economic analysis of the emission limitation changes that resulted. Forecasts were developed for two scenarios—a "high impact" case and a "low impact" case—from a base case that assumes continued enforcement of present State implementation plans and emission limitations, new source performance standards, and prevention of significant deterioration regula- tions. Railroad rates were assumed to be held to 95 percent of the current average rail rates in real terms, although a sensitivity analysis has indicated that this is not a significant assumption for this study. The "low impacts" scenario assumed that changes in the definitions of "excessive concentrations" and "nearby" did not affect those sources with greater than regional GEP stacks; this assumption results from considerations discussed earlier in this report. Consequently, only those sources that had combined stacks or were affected by the prohibition on plume impaction credit were analysed in this scenario (other provisions previously discussed in this report were not assessed for economic effects, for reasons discussed in the preceding sections). Where units were presumed to be affected by both the plume impaction and combined stacks restrictions, a combined effect was determined by multiplying one adjustment factor by the other to arrive at a total emission limitation adjustment factor. 32 ------- The "high impacts" scenario assumes that all sources with stack heights greater than regional GEP height would be affected by at least one of the four major changes in the regulation: plume impaction, the definitions of "dispersion techniques," "nearby," or "excessive concentrations." This scenario reflects the assumptions that stack credits obtainable for downwash effects would not be sufficient to eliminate plume impaction problems, and that sources conducting fluid modeling demonstrations had relied on terrain beyond the 0.8 km limitation, or had demonstrated a 40 percent increase in pollutant concentrations that would not also result in an exceedance of an ambient air quality standard. The results of the analysis are presented in the tables 3-7. The major impacts were found to be: 1. Annual reduction in S02 emissions of 2.8 million tons in the eastern portion of the U.S. and 100,000 tons in the western portion is forecast under the "high impact" scenario. Under the "low impact" scenario reductions are projected to be 790,000 tons and to occur only in the east. 2. Annualized costs (including capital recovery) are predicted to be $1.4 billion per year under the "high impact" scenario, and approximately $300 million per year under the "low impact" scenario. 3. Retrofit scrubber capacity is expected to increase by 13.2 gigawatts in the eastern U.S. and 4.2 gigawatts in the West under the "high impact" scenario, and by 3.4 gigawatts and 0.6 gigawatts, respectively, under the "low impact" scenario. 4. An overall decrease in coal consumption of 1.2 million tons is projected under the "high impact" scenario. Under the "low impact" scenario, the total change is negligible. 33 ------- 5. Under the "high impact" scenario, the greatest production increase is projected for Central Appalachian coal (18.6 million tons), with the greatest decrease forecast for midwestern coal (14.0 million tons). Under the "low impact" scenario, the greatest impacts will be felt in the same regions, with the changes in production projected to be 5.3 million tons and 6.4 million tons, respectively. 6. Coal shipments from the West to East are expected to increase by 10.2 million tons under the "high impact" scenario and by 1.0 million tons under the "low impact" scenario. 34 ------- Table 3 Emission Impacts in 1995 of Proposed Revisions to the Stack Height Regulation (Thousands of Tons) Reductions from Base Low Impact High Impact Base Scenario Scenario Existing plants Coal Oil/Gas 17,420 1,320 18,740 1,390 800 - 800 - 10* 2,880 50 2,930 - 50* New Total U.S. 20,130 790 2,880 * Additional emissions from new sources result from reallocation of capacity utilization within utility systems. 35 ------- Table 4 Cost Impacts in 1995 of Proposed Revisions to the Stack Height Regulation (1984 dollars) Utility Annual Costs ($ billion per year) Capital recovery O&M Fuel Total Increase from Base Low Impact High Impact Scenario Scenario 0.1 0.1 0.1 0.3 0.5 0.3 0.7 1.4 Utility Capital Costs* ($ billion) 31 Eastern States 17 Western States Total 0.8 0.1 0.9 3.4 1.2 4.6 Average Cost ($ / ton S02 removed) Retrofit Scrubber Capacity (Gw) 31 Eastern States 17 Western States Total 395 3.4 0.6 4.0 493 13.2 4.2 17.4 * Cumulative through 1995, 36 ------- Table 5 Number of Powerplant Units Affected by Proposed Revisions to the Stack Height Regulation* - Low Impact Scenario - Plume Impaction Only Both Combined Plume Impaction Stacks and Only Combined Stacks Total Number of Units Affected 24 50 78 Capacity (Gigawatts) 14.3 8.3 ,7 23.3 Number of Units With Retrofit Scrubbers Capacity With Retrofit Scrubbers (Gigawatts) 3.7 0.3 4.0 Units refer to individual units; one powerplant may have several units. Therefore, the number of powerplants affected will be less. 37 ------- Table 6 Number of Powerplant Units Affected by Proposed Revisions to the Stack Height Regulations* - High Impact Scenario -** Plume Impaction Ex. Conc.+ Nearby Combined Stacks Both Plume Impaction and Combined Stacks Combined Stacks + Ex. Conc.+ Nearby Total Number of Units 28 108 22 28 190 Capacity (Gigawatts) 15.4 69.4 2.3 0.7 6.1 93.9 Number of Units Scrubbed 10 11 18 39 Scrubbed Capacity (Gigawatts) 6.4 7.7 3.3 17.4 Units refer to individual generating units; one powerplant may have several units. Therefore, the number of powerplants affected will be less. These figures do not necessarily reflect the highest impacts of Plume Impaction in the absence of other provisions of the proposed regulation. Where other provisions impose greater effects, those effects were assigned to the other provisions and not to Plume Impaction. Therefore, the actual range may be greater. 38 ------- Table 6 Number of Powerplant Units Affected by Proposed Revisions to the Stack Height Regulations* - High Impact Scenario -** Plume Ex. Conc.+ Impaction Nearby Combined Stacks Both Plume Impaction and Combined Stacks Combined Stacks + Ex. Conc.+ Nearby Tota Number of Units 28 108 22 4 28 190 Capacity (Gigawatts) 15.4 69.4 2.3 0.7 6.1 93.9 Number of Units Scrubbed 10 11 0 0 18 39 Scrubbed Capacity (Gigawatts) 6.4 7.7 0 0 3.3 17.4 *Units refer to individual generating units; one powerplant may have several units. Therefore, the number of powerplants affected will be less. **These figures do not necessarily reflect the highest impacts of Plume Impaction in the absence of other provisions of the proposed regulation. Where other provisions impose greater effects, those effects were assigned to the other provisions and not to Plume Impaction. Therefore, the actual range may be greater. 38 ------- Table 7 Coal Production and Shipment Impacts in 1995 of Proposed Revisions to the Stack Height Regulation (Millions of Tons) 1980 185.1 232.8 26.4 134.4 251.0 Base 1995 222.5 286.7 28.8 160.1 538.7 Low Impact Scenario -1.0 +5.3 +0.3 -6.4 +0.8 High Impact Scenario -17.4 +18.6 +0.1 -14.0 +11.5 Coal Production Northern Appalachia Central Appalachia Southern Appalachia Midwest West Total U.S. 829.7 1236.8 -1.0 -1.2 Coal Transportation Western Coal Shipped East 36.7 73.2 +1.0 +10.2 39 ------- CEUM DEMAND REGIONS Pacific Mountain West South Central • v> iou no no Middle Atlantic EASTERN STATES REGION New England South Atlantic Demand region Alaska (AK) not shown ------- Appendix - List of References "Evaluation of Sources Affected by Revisions to the Stack Height Regulations," draft report; CCA/Technology Division, September 1984 "Summary of State Implementation Plan Revisions Involving Stack Heights," Sharon Reinders, Control Programs Operations Branch, CPDD, OAQPS, January 1984 "Identifying and Assessing the Technical Bases for the Stack Height Regulatory Analysis," final report; H.E. Cramer Company, Inc., December 1979 "SIP Data File," E.H. Pechan Associates "Summary Utility Forecasts for EPA's Preliminary Stack Height Analysis," interim report; ICF Incorporated, October 1984 Memoranda: "Plume Impaction Estimates," David Stonefield to Files, October 25, 1984 "Formula for Predicting Reductions in Emissions as a Function of the Difference between Actual Stack Height and Surrounding Terrain," Stephen Greene to Files, October 31, 1984 "Investigation-of Potential Impacts of Combining Stacks," Johnnie Pearson to David Stonefield, October 4, 1984 41 ------- |