VOLUME II
ESTIMATED COST OF MEETING
ALTERNATIVE SHORT-TERM N02 STANDARDS
DRAFT REPORT
ENERGY AND ENVIRONMENTAL ANALYSIS, INC.
1111 North 19th Street
Arlington, Virginia 22209
(703)528-1900
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VOLUME II
ESTIMATED COST OF MEETING
ALTERNATIVE SHORT-TERM N02 STANDARDS
DRAFT REPORT
Submitted to:
Mr. Kenneth H. Lloyd
Economic Analysis Branch
Office of Air Quality Planning and Standards
Environmental Protection Agency
Research Triangle Park, North Carolina 27711
Submitted by:
Energy and Environmental Analysis, Inc.
1111 North 19th Street, 6th Floor
Arlington, Virginia 22209
June 30, 1978.
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STATEMENT
This Draft Report is furnished to the Environmental Pro-
tection Agency by Energy and Environmental Analysis, Inc.
(EEA), Arlington, Virginia. The contents of the report are
reproduced herein as received from the contractor. The opin-
ions, findings, and conclusions expressed are those of the
authors' and not necessarily those of the Environmental Pro-
tection Agency.
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TABLE OF CONTENTS
Title Page
A. Introduction and Caveats 1
B. Air Quality Assessment Methodology . 4
1. Point Source Modelling 5
2. Area Source Modelling 17
C. Air Quality Modelling Results 24
1. Point Source Analysis. . . ..- 24
2 . Area Source Analysis 28
3. Point and Area Source Analyses Together 28
D. Control Options and Cost Analysis 33
1. Point Source Control Options and
Unit Costs 33
2. Point Source Cost Analysis Procedure 43
3. Point Source Control Costs 44
4. Impact of Growth on Point Source
Control Costs 50
5. Area Source Control Options and Costs 53
6. Area Source Costing Procedure and
Results 55
E. Comparison of the Nationwide Cost Analysis With
the Chicago Case Study 60
F. Economic Impact 61
1. General Comments 61
2. Point Sources 64
3. Area Sources 66
G. Summary and Conclusions 66
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VOLUME II
ESTIMATED COST OF MEETING ALTERNATIVE
SHORT-TERM N02 STANDARDS
A. Introduction and Caveats
This study is the second volume of a three-volume report
which attempts to identify the causes of high short-term con-
centrations of nitrogen dioxide (NOO and the additional cost of
controlling sources of nitrogen oxides (NO ) emissions to
x
levels consistent with attainment of the ambient standards under
consideration (that is, the costs in addition to those required
to meet the Federal motor vehicle emission standards and the
NSPS for stationary sources). Volume I focuses on the mecha-
nisms by which high ambient concentrations of N02 are believed
to occur. Volume II provides a preliminary assessment of the
sources which, through the mechanisms identified in Volume I,
might cause or contribute to high short-term (i.e., one-hour
averaging period) concentrations of N02. Control strategies
are developed for these and used to estimate nationwide control
costs. Volume III describes a detailed case study of short-term
N02 concentrations in Chicago. An area source and multiple
point source model was used to capture the interactive effects
of all NO emission sources in a region. The results shed light
J^
on the accuracy of the nationwide study.
It should be emphasized at the outset that actual monitor-
ing data which can be used to estimate the expected contribution
of point sources are extremely sparse. Lacking those data, a
dynamic modelling technique based on a nonreactive Gaussian dis-
persion model and empirical NO -to-N09 conversion curves was
X £
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used to estimate maximum ground-level concentrations of N0_.
Although it is believed that the results are reasonable, vali-
dation of the technique with monitoring data should be performed
to confirm this belief.
Any short-term study which attempts to assess the national
dimensions of what is, in effect, a multiplicity of localized
problems must necessarily impose simplifying assumptions on the
analysis. The most significant of these assumptions are de-
scribed below:
• Though ambient concentrations of NO- are
created by a mix of emissions from both
point and area sources, the two categories
of sources are treated separately in this
analysis. The area source analysis is
based on proportional ("rollback") model-
ling of monitored air quality and area
source emissions in urban areas. This is
a reasonable approach if, as appears true
from the available evidence, most monitors
in urban areas reflect contributions pri-
marily from area sources of NO emissions.
X
Point sources are assessed by estimating
theoretical maximum contributions to
short-term NO- levels with the dynamic
modelling technique noted above and de-
scribed in Volume I. As noted, these
results are largely unverified by empiri-
cal observation.
• Interaction between point and area sources
is captured in a limited way by adding area
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source background concentrations to the es-
timated point source contribution. The high-
est annual average value recorded in an AQCR
is used to assess the area source back-
ground for all 'point sources located in that
AQCR. Based on the results of the Chicago
case study, a background value 50 percent
higher than the highest observed annual
average is used to represent area source
contributions to ambient NO- levels under
conditions which maximize area and point
source interaction.
• The need to verify our dynamic modelling
technique has already been noted. Alterna-
tive approaches for representing the secondary
(derived) nature of NO- have also been dis-
cussed. Cole suggests setting maximum NO-
equal to the ambient 0- level plus 0.1 times
I/
the NO level. This appears to work well
JC
for summer conditions, but should underesti-
mate NO- under conditions of low 0- concen-
trations characteristic of winter. In- addi-
tion, empirical analyses of relationships
between NO- and its precursors suggest only
limited correspondence between levels of NO-
2/
and 0-. ' However, this approach is used
here for comparison purposes.
• Plumes from individual point sources are
assumed to be non-interactive. This is a
reasonable assumption for sources separated
by tens of kilometers, dependent, of course,
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on stack height. Unfortunately, time limi-
tations did not allow an interactive analysis
for sources where this assumption does not
hold. This leads to some underestimation of
control costs, though in combination with
the following simplification, the degree of
underestimation may be small.
• Ambient levels due to NO emissions from
^C
multiple stacks in single plants are assum-
ed to be additive. This is the same as
assuming the emissions all emanate from the
same location within the plant. Ambient levels
and control costs are consequently overesti-
mated. However, the Chicago results show that
the overestimation in this case tends to
balance the underestimation introduced by the
previous assumption.
• The point source modelling assumes every
source is located in flat terrain; where
this does not hold, ambient concentrations
may be underestimated.
B. Air Quality Assessment Methodology
Since both point and area sources emit NO , an assessment of
Jt
the causes of high short-term NO- concentrations must consider
each type of source and their respective concentrations. Studies
have shown that either can lead to relatively high concentrations.
However, the nature of their.impacts are different. Point sources
tend to produce infrequent and spatially confined N0_ peaks,
though the slow formation rate of N02 smooths out these "hot
spots" to some extent. Area sources, on the other hand, are less
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varied in their impact on peak N02 levels in both time and space.
Due to the placement of NO,, monitors in urban areas and to
the relatively small variation in recorded levels over time (for
continuous monitors), a case is built in Volume I for the use of
monitoring data in assessing area source contributions to N02
problems. The impact of point sources, however, can only be
captured through dispersion modelling exercises.
The following sections of the report discuss the separate
treatments of point and area sources. Each approach attempts to
account in some manner for the influence of the other source type.
The results of the two analyses are then brought together in a
final discussion and assessment.
1. Point Source Modelling
a. General Approach
A detailed modelling of all point sources in each AQCR was
far too ambitious for a nationwide study. Instead, a model plant
technique was devised and applied to EPA's NEDS file of point
sources. This approach may be adequate for isolated sources, but
for urban areas, a means was needed to assess the interaction of
multiple point sources and the degree to which area source emissions
exacerbate point source problems. To assist in this regard, a
separate, detailed study of a single AQCR was undertaken. The
results of this case study can then be used to judge the adequacy
of the nationwide assessment.
The NEDS modelling analysis was based on a series of model
plants which ranged in size and operating parameters corresponding
to combustion processes in various source categories (e.g.,
utility boilers, industrial boilers, and furnaces). ..The model
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plants were analyzed individually using a simple Gaussian dif-
fusion model (PTMAX) to assess the meteorological conditions
associated with ground-level maximum NO-- These conditions were
then used with a simplified version of PTMAX to model the air
quality impacts of all NO sources in the NEDS file. Once the
X
concentration of NO around each point source had been charac-
terized by the diffusion model two alternative approaches were
employed to translate NO into NO-. Emission control methods and
X ^
their associated costs were then estimated for each source.
The case study involved a detailed analysis of the multiple
•point and area source contributions to peak short-term N0_
concentrations in the Chicago region. An EPA-approved point and
area source interactive model, RAM, was used for this analysis.
A detailed point and area source emission inventory combined with
the versatility of RAM provided a unique characterization of N0»
concentrations in a large urban area. The reasons for selecting
Chicago as the case study AQCR and details of the study are
described in Volume III of this report. The results of the
Chicago case study provide both a sensitivity check on the as-
sumptions used in the nationwide study, and a means of gauging
the degree of over- or underestimation of control cost impacts.
It is important to re-emphasize that the nationwide point
source analysis focused on achieving alternative short-term NO-
standards through point source controls alone. Area source
emissions were treated as a background influence. Results of the
Chicago study were extrapolated to estimate the area source
contributions in other AQCR's.
b. Processing of Point Source Emissions Data
. Samples of raw data were retrieved from the NEDS point
source sub-file to determine the extent of erroneous and missing
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information. Upper and lower limits and default values for the
stack height, temperature, air flow rate,- hours of operation, and
fuel heating values were established for each source category
based on standard operating practice and substituted for erroneous
or missing data in the file. These are shown in Table 1. Default
values for flow were calculated for each type of fuel at the
excess air rate normally associated with it. For combustors fired
with dual fuels, estimates were made assuming 100 percent firing
of the fuel which had the highest emission rate.
The most up-to-date emission factors from the Control Tech-.
niques Document (Revised Draft Second Edition '), California Air
Resources Board ARE 2-1471,4/ and AP-42 (Fifth Edition) 5// were
used for this analysis. Data on the emission factors for industrial
combustion processes are limited. The variability in the emissions
*
with fuel type is not as significant as it is among processes in
the same category. The emissions factors used for industrial
combustion processes are, therefore, average values applicable to
the greatest number of processes in a fuel category. Revised
emission factors for cyclone boilers, significantly lower than
those listed in AP-42, have recently been reported by Aerotherm
and were used in this analysis . For example, the revised emission
factor for coal-fired cyclone boilers is 1.3 Ibs. NO /MMBtu,
X
approximately half of what is reported in AP-42.
Emissions were calculated for operation at full load. In the
absence of information on rated capacity or maximum operating
rate, the hourly heat input rate was calculated using the annual
fuel consumption and the hours of operation.
All existing nitric acid plants are assumed to meet the 5.5
Ib. N02/ton nitric acid regulation applicable to old sources.
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TABLE 1
DEFAULT VALUES
Source
Stack
Tempe rature
Stack Height
(m)
Hours of
Operation
Boiler
Acceptable range
Default
320 £ T <800
410
10 < H $ 500
30
0 < hours $8736
5400
Internal Combustion
Acceptable range
Default
320 £ T <. 800
410
5 $ H < 500
20
0 < hours $8736
5400
Chemical Processes
Acceptable range
Default
290 $ T $900
500
5 < H $ 500
15
0 < hours $8736
800
Petroleum Industry
Acceptable range
Default
320 $ T $1100
500
5 $ H $. 500
15
0 < hours<8736
8000
In-Process Fuel
Acceptable range
Default
310 $ T $1300
500
5 $ H $ 500
15
0 < hours $8736
8000
Incinerators
Acceptable range
Default
310 $ T$1100
370
0 $ H $ 500
15
0 < hours $8736
8000
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This regulation is in effect in most states with nitric acid
plants.
c. Dispersion Modelling Methods and Assumptions
The Gaussian diffusion models used in these, analyses are
non-reactive models. Maximum NO concentrations from the
X
single or multiple point sources were first estimated and then
translated to N02 levels using both of the approaches described
in Volume I of this study. The dynamic translation model de-
veloped by EEA is the preferred approach for isolated point
sources. For assessing the impact of interacting point sources,
it seems to be the only reasonable approach.
f.
For sources with multiple stacks and each stack serving
multiple combustors, diffusion calculations were made on a stack
basis. The maximum impact of all stacks in a source was assumed
to occur at the same point and to be additive—clearly a conser-
vative approach. Finally, the list of sources that were esti-
mated to violate a 250 yg/m ambient NO- standard was screened
manually. Raw data for sources with unusually high estimated NO
JC
concentrations were reviewed, corrected if necessary, and ambient
concentrations re-estimated.
d. Influence of Meteorological Conditions on Point
and Area Source Interaction
As noted earlier, meteorological conditions play a major
role in the short-term build-up of N02 concentrations from both
point and area sources of NO emissions. Meteorological condi-
2^
tions, in addition to controlling the diffusion of N02, also
have a binding influence on its formation rate. A detailed dis-
cussion of this subject is presented in Volumes I and III of this
report. A summary of the conclusions derived from the
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Chicago case study is presented here. These were used to select
the meteorological setting for the nationwide study.
• NO emissions from either point or area
it
sources can result in high short-term
NO- concentrations.
• Two distinct groups of point sources can be
identified in terms of their response (dilu-
tion and NO- formation rate) to different
meteorological conditions: (1) plants .with
tall stacks such as utilities, and (2) plants
with a large number of short stacks such as
steel mills and refineries.
• The diffusion characteristics of the second
point source group seem to be similar to
those of the area sources.
• The meteorological conditions that maximize
the impact of sources with high effective
stack heights are at an opposite extreme
to the conditions that result in high con-
centrations from both area sources or point
sources with short effective stack heights.
• In the Chicago case study, an intermediate
set of meteorological conditions, closer to
the area source maxima end on the spectrum
of diffusion conditions, resulted in the
highest short-term NO- concentrations.
The following summary of the test case analyses from the
Chicago case study should be helpful. The results of the point
and area source interactions under three different meteorologi-
cal conditions are presented in Table 2. The table shows five
10
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TABLE 2
COMPARISON OF ESTIMATED NO LEVELS FROM POINT AND AREA SOURCES UNDER DIFFERENT
METEOROLOGICAL CONDITIONS IN CHICAGOa/ (yg/m3)
Five Highest
Worst Case - Point Source
Worst Case - Area Source,
Intermediate Case
Concentrations
1
2
3
4
5
Average of
all receptors
above 200
yg/m
Number of Receptors
Above 200 yg/m3
Total
509.
589
348
348
342
277
Percentage of Power Plants
With Significant Contribu-
tions, i.e., Effective Stack
Height Less Than Mixing
Height
Chicago Case Study - Cook
Point
428
409
209
225
219
165
47
17
, Dupage ,
Area Total Point Area"7 Total Point
81 568 549 19 603 493
81 479 279 200 602 434
139 472 272 200 600 407
123 472 272 200 598 430
123 472 272 200 553 383
111 371 142 199 316 142
68 67
0 3
and portions of Will, Lake and Porter Counties.
Area
110
168
193
168
170
174
receptors may reflect higher area source contributions, but lower total concentrations.
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highest estimated concentrations in each case and the average
concentration at all receptors estimated to be above 200 yg/m .
This sensitivity analysis was performed on a portion of the
Chicago AQCR which included Cook, Dupage, and portions of Will,
Lake, and Porter Counties. As can be seen, total NO- concen-
trations are highest for the intermediate case. In addition,
the degree of point source control required is higher in the
intermediate case due to higher area source background concen-
trations, as compared to the point source "worst case."
e. Selection of Scenarios
Since the point sources in NEDS include rural, isolated
sources as well as those located in dense urban areas, a single
set of meteorological conditions was deemed insufficient. For
sources in the urban areas, as noted in the previous section,
the multiple point and area source influence is overriding. An
intermediate set of meteorological conditions would be more
appropriate for assessing the point source impact. But for
large point sources located in isolated areas, the "worst case"
for point sources alone is the appropriate choice.
Ideally, the point sources in isolated areas should be
analyzed separately from those in the urban areas. Such an at-
tempt, of course, was not made because of the large number of
sources and lack of information on their location. Instead, all
•point sources were analyzed under the two sets of conditions.
Furthermore, the two alternative approaches for translating the
modelled NO from each point source into NO- were applied to
X ^
each set of meteorological scenarios. This produced four test
scenarios which are summarized in Table 3.
12
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TABLE 3
LIST OF SCENARIOS
Meteorological
Conditions
Translation
Approach
"Worst Case"
Point Source
Wind Speed =
5.0 m/sec
Stability Class 3
Intermediate
Case
Wind Speed =
1.5 m/sec
Stability Class 3
NO- = .1 NO +0.,
£ X j
EEA's Rate Curves
Worst Case Point Source
Use of meteorological conditions maximizing the point
source influence alone implies that all sources are located in
isolated areas. Under these conditions, the impact of area
source contributions is estimated to be a minimum. This scenario,
therefore, results in an underestimation of the short-term prob-
lem for point sources in an urban area.' The degree of control
required and the cost of control is lower. The selection of
meteorological parameters for this case is based on the model
plant analysis.
Intermediate Case
This scenario implicitly assumes that all point sources are
located in urban areas. The area source background is estimated
higher in this case than in the previous case. For sources in
isolated areas, this may overestimate the cost of controlling
them to achieve a given ambient level.
(0.1 NO + O.J Translation Approach
X j
The approach and its limitations are discussed in detail in
Volume I of this report. This approach assumes that, except for
the initial conversion of NO to NO- (about 10 percent), conver-
sion of NO is limited by the ambient levels of ozone.
EEA's Translation Curves
NO in each plume was translated into NO- concentrations as
a function of initial NO level in the plume and plume travel
time. A series of time-dependent curves relating NO to NO- for
different initial NO levels were developed based onxplume track-
ing studies. Detaili of the approach also are presented in
Volume.I. of this report.
13
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For a conservative (high side) estimate of the cost of im-
plementing point source control strategies to achieve a given
short-term standard, the intermediate.meteorological case was
chosen. In addition, EEA believes that the translation curve ap-
proach is theoretically more valid. However, due to the lack
of readily-available ambient NO- data around point sources and
to. time constraints, the translation curve approach could not
be properly calibrated. Scenarios one and two were therefore
used mainly to estiblish a basis of comparison. The final cost
and economic impact analysis was based on the results of the
fourth scenario.
f. Area Source Contributions as NO- Background
Referring back to Table 2, results of the Chicago case
study, one can see that the average area source concentrations in
each of the three cases are very close to the area source com-
ponents at the receptors with the highest total concentrations.
This implies a low spatial variation in the component of.peak
NO- concentrations due to area sources. Some loss of spatial
variation in the area source concentrations could have resulted
from limitations in the way RAM models area sources, and is ex-
plained in Volume III of this report. Regardless, observed am-
bietn data on a regionwide level supports the above deduction.
The use of an average value to account for the area source con-
tribution at all receptors in an AQCR is therefore reasonable.
As noted earlier, the area source background in an .urban
area varies with the meteorological conditions. To quantify
the area source background level for the two sets of meteorological
conditions used in the national study, the average area source
concentrations for the same conditions in the Chicago study
14
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were first related to the highest observed annual average NO-
concentration in the Chicago AQCR.* Table 4 shows a comparison
of the estimated average one-hour area source concentration and
the highest observed annual average concentration in the Chicago
AQCR. For the first case, maximizing the point source impact,
the average estimated one-hour NO- level from area sources alone
is almost equal to the highest observed annual average value; for
the intermediate case, the estimated area source background is
higher by about 50 percent.
Assuming Chicago to be a reasonable representation of area
source problems in other AQCR's in the country, the highest ob-
served annual N02 average in an AQCR was used for the area source
background in scenarios one and three, and 1.5 times the highest
annual average for scenarios two and four. These background
values were used uniformly across each AQCR for all receptors
irrespective of their location.
g. Changes in Point and Area Source Emissions
Growth in point sources was not considered explicitly in the
analysis for two reasons. First, the new source performance
standards for NO are sufficient to prevent any new source af-
X
fected from violating the most stringent ambient standard con-
sidered. Secondly, though clusters of new sources or expansions
at existing sites may combine to create a violation, the model-
ling approach used does not consider multiple point source in-
teractions .
*Studies have shown that the annual average NO- concentrations
in urban areas are mainly due to area source influence,and are
relatively less sensitive to the point source impacts.
Use of observed annual average concentrations to quantify the
area source influence is therefore reasonable.
15
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TABLE 4
COMPARISON OF ESTIMATED AVERAGE ONE-HOUR N02
CONCENTRATION DUE TO AREA SOURCES ALONE (FOR ALL MODELED
RECEPTORS) WITH THE HIGHEST OBSERVED ANNUAL AVERAGE
IN THE CHICAGO AQCR
(yg/m3)
Case
Worst Case
- Point
Source
Intermediate
Case
Estimated
One-Hour
Average N0~*
111
174
Highest
Observed
Annual NO **
109
109
Ratio
1.0
1.5
*Data from Table 2.
**0bserved annual average value is assumed to include the in-
fluence of natural background, 1975 annual average value at
the Chicago Camp Station.
16
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Changes in area source emissions were considered indirectly.
A 20 percent reduction in area source background levels was
introduced to account for a one percent annual increase in travel
and a 30 percent decrease in composite mobile source emission
factors by 1982 due to new exhaust standards.
2. Area Source Modelling
a. General Approach
The point source analysis represents a situation where the
total NO- concentrations from the combined impacts of point and
area sources are at a maximum. The meteorological conditions in
this situation tend to maximize the point source influence more
than that of the area sources. Therefore, the orientation in
the point source analysis is toward point sources as the cause
of, and the sole means to prevent, violations of a short-term
standard. However, there are other meteorological situations
under which the area source impact is enhanced to a level where
they alone may cause a violation of an N02 standard.
As one way to capture the maximum impact of area source
emissions directly, a simple rollback modelling analysis was
made of monitored NO- concentrations and current NO emission
<£ 2C
levels in those AQCR's whihy may experience future short-term
problems.* As noted in Volume I, the monitoring networks in
*A totally comparable approach to the point source assessment
would be based on area source dispersion modelling in every
AQCR. However, this is impossible without detailed knowledge
of the spatial variations in area source emission levels with-
in each AQCR. Even if this were possible, dispersion model-
ling may not capture the worst case impact of area source
emissions due to the generalization of emission levels over
space (i.e., the spreading of emission evenly over a geo-
graphic area).
17
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most AQCR's are believed to reflect the impact of area, as op-
posed to point, source emissions. Annual average concentrations
tend to show relatively little variation among stations, and
most continuous monitors show peak (second highest hourly
values) to mean, (annual average) ratios of 6:1 or less. Using
ambient air quality data to analyze short-term NO- pollution from
area sources would thus appear reasonable. However, where point
sources do contribute significantly to peak NO- levels at moni-
tors which would qualify under the above definition as area
source-dominated, the burden of meeting a short-term NO- standard
would fall on both point and area sources; to the extent that
point sources may be more amenable to control, the area source
control requirements estimated by this method would be over-
stated.
b. Model Description
Rollback is based on a simple proportional relationship be-
tween emissions and ambient air quality:
Allowable NO = N02 standard x 1975 N0 Emissions
Emissions x
No background NO- level was assumed in the analysis since the
overall approach (i.e., totally ignoring point sources) may some-
what overstate the need for area source controls.
The basic procedure involved calculating allowable emission
levels for each AQCR and comparing them to current and future
emission levels. The percent control needed to meet the standard
was then obtained directly from these estimates.
18
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c. Current Air Quality and Emissions
The sample of AQCR's on which the analysis is based in-
cludes all those estimated by SRI ' to have current one-hour NO-
3
concentrations above 200 yg/m . These include 150 out of a pos-
sible 243 AQCR's. The area source emission patterns for these
AQCR's are shown in Table 5. In over three-fourths of the
sample, area sources account for at least 50 percent of all NO
X.
emissions. Highway vehicles vary appreciably in their contribu-
tion, but in most regions, the emissions are above 20 percent
(and in over one-fourth, above 50 percent) of total NO loadings.
A.
External combustion sources (residential, commercial, and insti-
tutional space heating; space and process heating in small in-
dustrial plants) comprise the other major category, but are much
less important. The remaining, area sources are solid waste in-
cineration, internal combustion engines (e.g., gas turbines used
to generate electricity), the residual mobile sources (off-high-
way vehicles), and miscellaneous sources such as forest fires.
Current one-hour ambient NO- concentrations for each AQCR
were set equal to the higher of (a) the second highest hourly con-
centrations recorded for all continuous monitors with peak to
mean ratios of 6:1 or less; or (b) six times the highest annual
average for any 24-hour monitor in the AQCR. This procedure was
designed to eliminate point source influences while capturing
the worst area source NO- problem in each AQCR.
d. Change in Emissions and Impact on Attainment
Those AQCR's which currently would be unable to attain one
of the short-term NO- standards under consideration could only
achieve it at some future point if controls placed on area
sources brought sufficient net reductions in NO emissions.
X
Conversely, growth within those AQCR's which currently attain the
19
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TABLE 5
CONTRIBUTION OF AREA SOURCES TO TOTAL NOX LOADING
IN THE AQCR's ANALYZED
(1975)'
Emissions Of NOX
(Percent Contribution To Total Emissions)
A OCR
No.
2
3
•1
5
7
12
13
14
15
17
18
19
20
21
22
24
25
23
29
30
31
33
36
38
41
42
43
44
45
46
47
49
50
52
53
54
55
56
- 58
59
64.
f,r)
ttfi
67
t>8
69
70
71
72
73
Total
Area
Sources
99
100
46
5-1
86
52
20
28
77
99
50
51
71
97
55
75
63
95
77
30
75
18
65
43
78
74
61
94 -
56
53
71
43
51
50
56
45
48
65
39
78
95
1.8
7U
50
39
35
32
52
12
65
External
Combustion
Area Sources
08
07
04
06
04
04 '
01
02
07
14
02
07
07
11
05
07
04
05
06
07
05
01
06
03
07
12
14
08
08
03
07
01
01
01
03
02
02
04
02
03
09
02
06
08
03
03
03
04
01
07
Light Duty
Highway
Vehicles
46
52
21
25
45
30
13
15
41
39
25
22
30
43
27
37
36
56
43
42
41
11
31
20
54
45
31
66
26
19
41
23
23
29
32
24
27
33
20
45
34
08
37
22
15
15
17
26
05
30
Heavy Duty
Highway
Vehicles
20
19
09
09
16
17
04
04
13
20
10
07
11
14
07
11
09
14
12
14
11
02
12
08
08
08
07
10
11 '
20
10
09
09
09
09
08
08
11
07
12
1C
0'.!
08
08
07
06
06
05
02
09
a/
These are the AQCR's which have recorded or estimated second highest
one-hour N02 concentrations equal to or greater than 200 ug/m^.
SOURCE: EPA's NEDS file, January 9. 1978_access.
20
-------
TABLE 5 (Continued)
Emissions of N0x
(Percent Contribution of Total Emissions)
AQCR
External
Combustion
Area Sources
Light Duty
Highway
Vehicles
Heavy Duty
Highway
Vehicles
74
75
76
77
78
79
80
81
82
33
84
35
92
94
95
98
99
101
102
103
105
106
107
109
112
113
114
115
116
117
118
119
120
121
122
123
124
125
127
128
129
130
131
136
144
145
149
151
152
153
69
22
81
25
27
40
67
96
57
38
36
50
68
17
53
37
66
94
56
24
63
28
55
50
69
64
71
56
26
80
83
68
63
61
58
60
28
77
94
79
69
92
58
59
75
62
88
67
65
78
04
02
09
02
03
03
08
13
07
04
04
06
05
02
03
02
05
04
04
03
04
02
05
05
03
03
04
04
01
20
23
18
11
10
05
07
03
07
07
06
02
12
09
03
18
06
11
09
08
05
•37
11
40
11
12
21
31
44
29
19
18
19
30
07
19
15
26
51
28
10
29
10
32
32
45
41
46
33
15
43
43
33
36
37
34
34
15
44
47
37
15
33
26
30
21
22
56
34
25
35
08
03
16
04
05
07
14
18
10
07
07
12
14
04
15
07
14
18
09
03
10
04
09
09
09
09
09
08
03
09
09
08
08
08
08
09
04
11
14
12
07
18
10
13
10
15
11
12
11
' 13
21
-------
TA3LE.5 (Continued)
Emissions of NO
(Percent Contribution of Total Emissions)
Total External Light Duty Heavy Duty
AQCR Area Combustion Highway Highway
No. Sources Area Sources Vehicles Vehicles
155 58 03 27 10
158 57 08 35 06
160 38 05 24 04
161 50 06 32 05
162 60 12 34 06
165 37 02 17 07
166 58 03 28 12
167 49 02 25 10
168 79 02 20 09
169 87 03 40 18
171 59 02 21 25
173 73 06 41 11
174 58 06 31 09
175 96 07 53 13
176 ' 91 08 49 14
178 56 07 29 09
180 94 07 52 13
181 10 .01 05 01
182 64 03 38 09
183 22 02 12 03
184 80 05 37 • 25
188 51 03 ' 20 16
189 59 02 22 18
193 76 07 37 18
195 64 09 37 41
196 38 05 19 07
197 29 ' 04 14 05
198 82 03 47 12
199 36 02 19 06
200 42 •' 02 22 . 06
201 65 01 37 09
202 76 02 48 11
203 82 03 48 12
208 40 0 22 07
211 38 02 18 05
212 55 02 27 06
214 13 0 05 01
215 79 07 24 27
216 41 05 •' 16 05
217 7^ OS 32 10
218 I'J 0 09 03
220 70 16 20 10
223 58 03 30 09
225 41 03 23 07
226 '•' 53 03 32 08
229 56 05 28 09
234 20 08 08 02
237 44 o 20 07
239 62 07 28 11
243 48 06 13 06
22
-------
standard could outweigh emission reductions achieved by controls
and thus lead to future violations. Projections of future at-
tainment status are consequently sensitive to the assumed
growth rates for emission sources and the assumed effectiveness
of emission controls.
Time trends in emissions were projected separately for sta-
tionary and mobile sources. Population growth is the logical
driving force for growth in emissions from many stationary area
sources. Based on a projected annual population growth rate of
8/
0.9 percent for the entire nation, a 1.0 percent growth rate
was set as the upper bound for increases in stationary area
source emissions. Of course, some area sources such as solid
waste incineration are not expected to grow at all and could, in
fact, decrease over time. Consequently, an annual growth rate of
zero was set as the lower bound. For both growth scenarios, no
additional NO emissions control was assumed.
X
A national growth rate for mobile sources (light and heavy
duty highway vehicles) of between two and three percent per year
Q/
in vehicle miles travelled (VMT) is a reasonable expectation. '
However, due to monitor location and the dispersal and transfor-
mation characteristics of NO , recorded peak NO- concentrations
X £
may be most responsive to emissions from vehicles on the most
heavily travelled roads. VMT growth rates for these highways
(and thus, the effective growth rates) may be much lower than
growth in total VMT. We used rates of 1.0 and 3.0 in order to
bracket this average and thus test the sensitivity of the results
to this assumption. With an increase in VMT per year comes a
concomitant decrease in emission rate (gm/VMT) as .new vehicles
meet the increasingly stringent Federal emission standards and,
over time, become a larger fraction of the vehicle fleet. Com-
posite emission factors for a weighted national average of all
23
-------
highway vehicles were provided by EPA for each year between 1975
and 1990. ' The fractional reductions in emission rates were
thus combined with the fractional increase in VMT to obtain
changes in emissions between the years 1975 and 1982, and 1975
and 1990. Table 6 summarizes the results. Improvements in emis-
sion controls as mandated by the 1977 Amendments to the Clean Air
Act are seen to bring significant overall reductions between now
and 1990. However,, examination of the emission changes on a
yearly basis reveals that the lowest emission level occurs in
1989 (for an annual VMT rate of 3.0 percent) and the level turns
upward in response to increases in VMT thereafter.
The nationwide fractional changes in stationary and mobile
source emissions were then applied uniformly to all AQCR's. Im-
plicit in this procedure is the assumption that the composition
of area sources within the stationary and mobile categories is
everywhere the same. This is obviously incorrect, but is reason-
able when applied in the framework of an initial assessment and
when compared to the approximate nature of the ambient air quali-
ty estimation procedure.
C. Air Quality Modelling Results
1. Point Source Analysis
Table 7 presents the results of the modelling analysis in
terms of the following:
• Numbers of point sources requiring control
and the combustors or process facilities
(i.e., SCO's) associated with these point
sources.
• The number of AQCR's in which these facili-
ties were located.
24
-------
TABLE 6
FRACTIONAL CHANGE IN MOBILE SOURCE EMISSIONS OVER TIME
1975
1982
1990
Composite Emission Factor
(gm/VMT)
a/
4.64
3.25
2.15
Ratio of Emission Factor to
1975 Emission Factor
1.00
.70
.463
Ratio of VMT to 1975 VMT
• 1.0% annual growth
• 3.0% annual growth
1.00
1.00
1.07
1.23
1.16
1.56
Ratio of Emissions to 1975_
Emissions"'
• 1.0% annual VMT growth
• 3.0% annual VMT growth
1.00
1.00
.7.49
.862
.538
.723
a/
b/
Composite emission factors are based on the current level of Federal
tailpipe emission standards, the estimated age distribution of the
vehicle stock, the estimated national distribution of vehicle types
(weighted by annual VMT), and assumed deterioration in emission
controls. (These values were provided by EPA.)
Computed by multiplying together values in the second and third rows.
25
-------
TABLE 7
POINT SOURCE MODELLING RESULTS
(1975 Conditions)
Translation
Approach
Ambient Standard
yg/m
One-Hour Averaqe
.1 NO +0,
x 3
Case 1
Case 2
EEA's Rate Curves
Case 3
Case 4
Point Sources Required to Control
1000
750
500
250
9
25
58
732
1000
750
500
250
183
377
641
5330
6
19
66
638
1
3
10
101
18
35
79
408
SCC ' s Requiring Control
103
314
705
4774
10
65
284
1185
324
636
1113
4069
AQCR's in Violation
1000
750
500
250
4
6
14
144
4
7
18
143
1
3
6
39
6
11
30 (24*)
119 (109*)
Cases 1 and 2 Meteorological conditions correspond to point source maxi-
mization, (area source background = highest observed annual
NO average in AQCR.)
Cases 3 and 4 Intermediate meteorological conditions. (area source back-
ground = 1.5 x highest observed annual NO average in the
AQCR.)
NOTE; See Table 3 for a further description of the four cases.
*in 1982 with one percent annual growth rate in VMT and expected 20 percent
overall reduction in area source emission due to mandatory mobile source
emission reduction requirements.
26
-------
The cases refer to the matrix present in Table 3. For cases
one and two, where the (.1 NO + 07) approach was used, the
X j
results are similar. The ozone limiting component is a major
portion of the N0? concentration and is unaffected by the change
in meteorological conditions. Higher. NO levels in case one (due
». X
to higher wind speed) over-compensate for the low background
level used there and result in overall higher concentrations than
in case two.
Use of the translation curve approach showed a larger vari-
ation in the control requirements. Ground-level NO- concentra-
tions are much higher in case four (intermediate meteorological
conditions) than that in case three (worst case - point source
conditions)1. This is consistent with the results of the Chicago
case study explained previously. A much higher degree of point
source control is thus required in case four. The number of
AQCR's with modeled receptors showing one or more violations
(before point source control) of a 250 ug/m standard is 119 for
case four, as opposed to 39 for case three. Overall, the NO-
formation rate curve approach shows a high sensitivity toward the
various factors affecting the formation of NO-.
For the final cost and economic impact analysis, only point
sources estimated in case four to cause violations of the 250 and
500 yg/m standard were considered.
A total of 4,069 sources associated with 408 industries lo-
cated in about 119 AQCR's are estimated to be in violation of a
250 ug/m standard. For the 500 yg/m standard, the number of
affected sources and AQCR's reduces significantly. Seventy-nine
industries with about 1,113 process and approximately 30 AQCR's
are estimated to be in violation of the standard. A breakdown of
the types of processes (source classification codes--SCC's) and
plants (standard industrial classification—SIC) that are likely
27
-------
to be associated with violations of the 250, 500, 700, or 1,000
yg/m standards is shown in Tables 8 and 9.
2. Area Source Analysis
Table 10 summarizes the results of two growth scenarios
(low: 0 percent stationary and 1.0 percent mobile source emis-
sion growth rate; high: 1.0 percent stationary source and 3.0
percent mobile source emission growth rate), assuming mobile
source emission standards will remain as currently mandated.
Except for the 250 yg/m standard, only a few AQCR's are esti-
mated to be in nonattainment status due to area source emissions.
For the 250 yg/m standard, the current Federal motor vehicle
control program is seen to effect a considerable improvement in
attainment status over time, though almost 70 AQCR's may still
experience violations in 1990.
3. Point and Area Source Analyses Together
Table 11 lists the number of AQCR's estimated to be in non-
attainment in the two analyses. (The data are taken from Tables
7, 10/ and 25.) The estimates are not directly comparable. The
two analyses represent two separate air quality situations.
Furthermore, the analytical approaches used in the analyses are
considerably different. As noted earlier, the point source
analysis is designed to capture the maximum influence of both the
point and area source together, which is not adequately reflected
by the existing monitoring networks in most urban areas. How-
ever, the control of point sources alone does not assure at-
tainment of the various standards under all meteorological con-
ditions (though, control of point sources alone is estimated to
attain the standards under the conditions used in the point
source analysis) in all AQCR's.
28
-------
TABLE 8
TYPE OF SOURCES LIKELY TO EXCEED SPECIFIED
N02 LEVELS*
NO., Levels (yg/m )
Source Category
Utility Boilers - Coal
Utility Boilers - Oil
and Gas
Industrial Boilers -
Coal
Industrial Boilers -
Oil and Gas
Gas Turbines
Reciprocating 1C Engines
Industrial-Combustion
Processes
Nitric Acid
Municipal and Industrial
Incinerators
250
350
599
300
742
268
698
1,045
61
11
500
42
7
72
207
19
516
235
19
1
750
15 •
0
10
108
10
376
114
3
0
1000
0
0
0
21
5
278.
17
3
0
TOTAL
4,069
1,113
636
324
*Case 4 analysis.
29
-------
TABLE 9
TYPE OF PLANTS LIKELY TO EXCEED SPECIFIED ONE-HOUR N02 LEVELS*
MO,
Utility
Boilers
Internal Combustion - Reciprocating
Industrial - In Process Fuel Use
Gas & Oil Pipe Lines (I.C. Engines)
Refineries
Steel
Metal Melting
Asphalt
Lime Kiln
Glass
Cement
Food
Automotive
Waste Water Treatment
Miscellaneous
Non-Combustion
Chemical
(Nitric Acid, etc.)
Total
250
136
26
48
37
23
15
10
4
4
3
4
4
3
67
24
408
f,
500
6
14
33
8
5
2
I
0
-
-
-
-
-
10
6
79
750 1000
2 0
7 4
17 9
5 3
2 0
0 0
0 0
-
-
-
-
-
-
-
1 1
34 17
*Case 4 analysis.
30
-------
TABLE 10
CHANGES IN AREA SOURCE EMISSIONS FOR 150 AQCR's AND AQCR ATTAINMENT STATUS FOR ALTERNATIVE
GROWTH RATES AND ONE-HOUR NO2 STANDARDS3/
1982
1990
Area Source Emissions Summed
For All 150 AQCR's
(tons x 106/year)
• Mobile Sources
• Stationary
Total
1975
6.3
3.2
9.5
High
Growth
b/
5.6
3.4
9.0
Low
Growthb/
4.9
3.2
'8.1
High
Growth
4.9
3.7
8.6
Low
Growth
3.6
3.2
6.8
Number of AQCR's Not
Attaining the Standard
• loop
• 250
• 500
• 250
yg/m
yg/m
yg/m
3
yg/m
0
2
17
94
0
2
10
84 "
0
0
4
68
0
0
7
73
0
0
2
45
a/
b/
Based on 150 AQCR's recording (or estimated to exhibit) second highest one-hour NO levels of
200 yg/m3 or more in 1975.
"Low growth" assumes a 1.0 percent annual growth rate for VMT and a zero percent annual growth
rate for stationary area sources. "High growth" assumes a 3.0 and 1.0 percent annual growth rate
for VMT and stationary area sources, respectively. Statutory mobile source emission standards
are also assumed.
-------
U)
NJ
TABLE 11
NUMBER OF AQCR'S ESTIMATED TO BE IN NONATTAINMENT IN THE AREA SOURCE
AND THE POINT SOURCE ANALYSES (NO ADDITIONAL SOURCE CONTROLS ASSUMED)
One-Hour Standard Area Source Analysis . Point Source Analysis.,^,
^ C' • 1975 1982 '
(yg/nT) 1975 1982 ±212. i£2£
1000 00 6
750 20 11 —
500 17 4 30 24
250 94 68 119 109
Represents a situation where meteorological conditions can maximize the area source
impact to result in violations of the standards due to area source emissions alone.
Represent a situation where meteorological conditions result in maximum concentrations,
but tend to maximize the point source influence more than that of the area sources.
c/ ; •'•'•• ' •
Low growth assumption for mobile and stationary area sources point source emissions
ignored.
Low growth assumptions for mobile sources. No growth considered for point sources.
-------
Under certain other extreme meteorological conditions,
the area source impact alone (even though not as severe as the
combined point and area source impacts) may exceed the various
standards. The area source analysis attempts to capture this
possibility.
It would appear that about 120 or more AQCR's would current-
ly be in violation of a 250 yg/m standard if sufficient monitors
were available to record them. And if these 120 did not include
all 94 estimated in the area source analysis, the number would be
higher. However, based on the existing monitors, less than 100
AQCR's would be in nonattainment.*
By 1982, and without additional emission controls, the num-
bers would be as few as 66 (current monitor placement) or 109
(ideal monitor placement). Taking AQCR overlap into account,
the estimate of nonattainment AQCR's for a 250 yg/m standard
is 127 for 1982.
D. Control Options and Cost Analysis
1. Point Source Control Options and Unit Costs
Each plant identified as having a potential to exceed any
of the alternative standards was analyzed to determine the per-
cent reduction required to reach each level with the types of
control available. Tables 12 through 18 show the kinds of con-
trol available for each source type. Controls and efficiencies
are taken from the latest draft of Control Techniques for
Nitrogen Oxides. These tables also show the date of availability,
*This assumes, of course, that the method used to estimate hour-
ly peaks from annual averages (multiplication by 6) is accur-
ate .
33
-------
TABLE 12
COST AND EFFECTIVENESS OF NOX CONTROLS FOR UTILITY BOILERS - COAL-FIRED
Differential Control Costs
Control Techniques
LEA
LEA + OSC
Retrofit: Low
NOX Burner
Retrofit: Dry
SCR (only NOX)
Control
Potential
11%
22%
40%
90%
Earliest
Year
Available
Present
Present
1980
1985
Initial Investment
(102$/106Btu/hr.)
0.60
1.25
2.00
60.00
Annual
Costc
(*/106Btu)b/
0.2
0.5
0.8
26.0
Effect On
Fuel
Consumption
.5% Decrease
0.5% Increase
0
3.0% Increase
a/
LEA = Low Excess Air
OSC = Off-Stoichiometric Combustion
SCR = Selective Catalytic Reduction
b/
Annual Cost = Initial investment annualized at 16 percent plus operation and maintenance costs.
6 4
l
-------
TABLE 13
COST AND EFFECTIVENESS OF NO CONTROLS FOR UTILITY BOILERS - GAS-5 OIL-FIRED
Differential Control Costs
Ul
a/
Control Techniques
LEA
LEA + OSC
LEA + OSC + FGR
LEA + OSC + NH3
Injection
Retrofit: Dry SCR
(NOX only)
Earliest Annual Effect On
Control Year Initial Investment Cost Fuel
Potential Available: (102$/106Btu/hr.) (<£/106Btu)b/ Consumption
17% Present 0.3
40% Present 0.8
59% Present 9.0
70% 1981 8.0
90% 1982 60.0
Neg. 0.5%
0.28 1%
2.8 1%
14.0 1%
26.0 3%
Decrease
Increase
Increase
Increase
Increase
a/
FGR = Flue Gas Recirculation
SCR = Selective Catalytic Reduction
b/l{/106Btu annual heat input = 0.54 $/kW for 5,400 hours of operation @ 10 Btu = 1 kW hr.
=0.1 mil/kWh
-------
TABLE 14
COST AND EFFECTIVENESS OF NOX CONTROLS FOR INDUSTRIAL BOILERS - COAL-FIRED
Differential Control Costs
CJ
CTl
Earliest
Control Year
Control Techniques Potential Available
LEA 10% Present
LEA + OSC 20% Present
Retrofit: Low NOX
Burner 50% 1985
Retrofit: Dry SCR
(NOX Only) . 90% 1985
Annual Effect On
Initial Investment Cost . Fuel
(102$/106Btu/hr.) (t/106Btu)V Consumption
0.7 0.29 1% Decrease
1.8 0.66 1% Increase
3.0 1.10 0
50.0 23.0 3% Increase
l«t/10 Btu annual heat input = 0.17 $/KG/hr. steam @ 1,400 Btu/lb of steam and 5,400 hours of operation.
-------
TABLE 15
COST AND EFFECTIVENESS OF N0x CONTROLS FOR INDUSTRIAL BOILERS - GAS-5 OIL-FIRED
u>
Differential Control Costs
Control Techniques
LEA
LEA + OSC
Control
Potential
10%
16%
Earliest
Year
Available
Present
Present
Initial Investment
(!02$/l06Btu/hr.)
0.7
1.4
Annual
Cost
(
-------
TABLE 17
COST AND EFFECTIVENESS OF NOX CONTROLS FOR INDUSTRIAL PROCESS FURNACES
Differential Control Costs
Earliest
Annual Effect On
Control Year Initial Investment Cost Fuel
Control Techniques Potential Available (102$/106Btu/hr. ) a/ (
-------
TABLE 18
COST AND EFFECTIVENESS OF NOX CONTROLS FOR NITRIC ACID MANUFACTURING
Earliest Differential Control Coats Effect On
Control Year Initial Investment Annual Cost Fuel
Control Techniques Potential Available 103$/Ton/clay*1/ $/Tonf/ Consumption
Wet Chemical Scrubbing
Chilled Absorption 90% Present 2.0 2.0 0
Selective Catalytic
Reduction
a/
.300 Tons/day - Plant capacity = 8,000 hours/year operation.
-------
capital and annual costs (expressed as $/MMBtu), and the effect
on fuel consumption. (Annualized costs are in 1976 dollars and
assume a capital recovery factor of 16 percent.)
For each source category, up to five levels of control were
established:
c • Low Excess Air (LEA)--Operation, of the source
burner at close to theoretical air. This is
the easiest and least costly control techno-
logy and can provide a 10 to 17 percent re-
duction in uncontrolled NO emissions.
x
e Low Excess Air Plus Off Stoichiometric
Combustion (LEA & OSC)--This includes any
of a series of combustion modifications
which reduce peak flame temperature and
supress NO formation. This technique is
X
applicable to most source types, is imme-
diately available, and provides an estimated
20 to 40 percent reduction in NO emissions.
X
In addition to LEA and OSC, Flue Gas Recir-
culation (FGR) can be used to 'provide an
extra 20 percent reduction in NO emissions
J\.
for gas- and oil-fired sources.
c Advanced Burner Designs — Special burners
designed to operate at very low excess air
and use advanced combustion techniques are
being developed by EPA and industry. If
these programs are successful, they offer
about a 50 percent reduction in WO r emis-
y^.
sions. For this study, it has been assumed
that the burners will be developed and will
41
-------
be available for new and existing sources.
Retrofit costs are assumed to be considerably
higher than new installations.
e Selective Catalytic Reduction (SCR)--The
reduction of ammonia and NO over -a catalyst
x J
can be used to reduce NO emissions by up to
x
90 percent. SCR systems are operating on
several large oil- and gas-fired boilers, but
have not yet been demonstrated on U.S. boilers.
In this study, it has been assumed that SCR
will be developed and available for use in
1982. Costs for SCR were taken from EPA
studies and adjusted to allow for retrofit
(including installation of a flue gas heater).
The above control techniques were assumed to be applicable
to boilers and industrial furnaces. Specific techniques such
as water injection, fine tuning, and molecular sieves were as-
sumed for gas turbines, internal combustion engines, and nitric
acid plants.
Costs and effectiveness of each control type are reasonably
well-established for boilers and process sources, but limited
investigation of NO reduction has been carried out for furnaces
JC
such as cement kilns, petroleum heaters, and glass melting
furnaces. Based on AP-67 and communications from Aerotherm,
we have assumed that combustion modifications and FGR are as
effective for these sources as for boilers.
It should be noted that, due to time and data constraints,
all control costs are assumed to be linear with size (i.e., a
constant cost per unit size regardless of capacity). This will
introduce some error in the costing. The overall significance
42
-------
and magnitude of the error introduced is not clear since the
linear assumption will tend to overstate some costs while un-
derstating others.
2. Point Source Cost Analysis Procedure '
Each plant identified as being capable of causing an NO-
concentration greater than one of the specified levels was
evaluated individually to determine the type of control required
and the cost and energy penalty of control. The procedure fol-
lowed is outlined below:
• The concentration from each point in the plant
was summed to determine the total concentration
of NO-. This concentration was then compared
to each of the specified levels (250 to 1,000
yg/m ) to determine the percent reduction in
'NO emissions required.
A
* The type of control used by each source to
meet each specified level was determined
based on the least-cost combination of controls
which would achieve the levels. For each pro-
cess, each applicable control technology was
considered. Combinations of sources and tech-
nology were ranked by annual cost of reducing
the plant's air qualtiy impact by 1 ug/m .
This measure ($/yg/m ) was used since it com-
bines the air quality impact of the source
with the cost of controlling its emissions.
Control technologies were selected one by
one, starting with the lowest cost (highest
cost-effectiveness) option until the air
quality goal was met.
-------
e After technologies were selected for each
source within a plant, the capital costs and
the effect on source and plant fuel consump-
tion were computed.
3. Point Source Control Costs
-i
Control costs only for standards of 250 and 500 yg/mJ are
presented here. For levels above 500 yg/m , the costs were in-
significant. As noted in section B.l.e, a conservative but rea-
listic set of meteorological conditions and a theoretically more
justifiable approach used for estimating the NO- concentrations
form the basis for selecting case four for the final economic
impact analysis. But for the purpose of comparison, the capital
and annualized costs for all four cases are presented in Table
19.
The capital cost of point source control to meet a 250
yg/m could range anywhere from 589 to 3,073 million dollars,
depending on the estimation approach. For the 500 yg/m stan-
dard, the capital control cost reduces significantly and is in a
relatively narrow range of 14 to 46 million dollars. The an-
nualized cost for both the 250 and 500 yg/m standard are signi-
ficantly affected by the impact on energy consumption. Frequent
use of combustion modification results in a net savings in the
fuel cost in almost all cases. The savings in some cases is
substantial enough to completely balance the annual cost of
control. The variation in the fuel impact among the different
scenarios is dependent on the severity of the air quality impact
in each case and the level to which individual sources have to be
controlled.
Table 20 lists further details of the case four analysis.
The plants and combustors shown are those which the costing
-------
TABLE 19
POINT SOURCE CONTROL COSTS FOR DIFFERENT CASES
Case Number
and Description
CASE 1: Worst Case - Point
Source (low background)
.1 NO + O_
x 3
CASE 2 : Intermediate Case
(high background)
.1 NO + O.,
x 3
CASE 3 : Worst Case - Point
Source (low background)
EEA's Translation Curves
•CASE 4: Intermediate Case
(high background)
EEA's Translation Curves
250 iag/m Standard
Capital Cost*
(106 dollars)
3,073
2,169
589
1,496
Annual Cost**
(106 dollars)
630
480
-66
363
500 Ug/m Standard
Capital Cost*
(106 dollars)
37
14
4
46
Annual Cost**
(106 dollars)
11
-1
-1
-1
Ul
*1976 dollar basis.
**Annual Cost = capital cost annualized <
and hours of operation + fuel penalty.
16 percent + operation and maintenance cost based on capacity
-------
TABLE 20
DETAILS OF POINT SOURCE CONTROL COST ANALYSIS FOR CASE 4
NO Standard
(One-Hour Average)
yg/m3
500
250
Number of
Plants
79
408
Number of
Combustors .
Controlled
794
3,628
Approximate
Capital Costs
(106 dollars)
46
1,496
Approximate
Annual Cost
(106 dollars )b/
-1
363
Approximate
Fuel Penalty
(Barrels of
oil/day
Equivalent
-2,331
-4,096
a/
Including some process sources.
b/
Including fuel with coal assumed at $1.60/MMBtu and oil and gas at $2.60/MMBtu.
-------
TABLE 2 l^
^^ ..u.a/m . STANDARD3'
Source Category 1
-NUMBER' OF USES
EMISSIONS REDUCED(GXS)
INITIAL COST (1000'SS)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
~ 1
12
524.
1826.
-1776.
-1329.
Source Category 2
"~ '~ T""
NUMBER OF USES 2
EMISSIONS REDUCED(G/S> 75.
INITIAL COST (1000'SS) 149.
ANNUAL COST (1000'SS) -514.
FUEL COST (10E+9BTU) -207.
__Source ..Category. -3_
NUMBER OF USES
EMISSIONS REDUCEB(GXS)
INITIAL COST (1000'S$)
ANNUAL COST (1000'SS)
FUEL COST (10E+9BTU)
.Source. Category _.4.
NUMBER PF USES
EMISSIONS REDUCED(G/S)
INITIAL COST (1000'SS)
ANNUAL COST (1000'SS)
FUEL COST (10E+9BTU)
_Squrce_Cate_gpry 5
NUMBER OF USES
EMISSIONS REDUCED
-------
TABLE 22 . - COST RY..nOMRr.TSTnR TYPE- FOR ATTAINING A 250_yq/m STANDARD
._S.ource_.Category_l
a/
NUMBER OF USES
EMISSIONS REDUCEB(GXS)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source Category^ 2
NUMBER OF USES
EMISSIONS REHUCED(G/S>
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
. _So.uree_ Category,_3
NUMBER OF USES
EMISSIONS RE0UCED(G/S>
INITIAL COST <1000'S$)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source Category 4
NUMBER OF USES
EMISSIONS REDUCED(G/S)
INITIAL COST (1000'SS)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source"Category 5
NUMBER OF USES
EMISSIONS REDUCED(G/S)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source Catecrory 6
"NUMBER OF USES
EMISSIONS REDUCEB(G/S)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S$)
FUEL COST (10E+9BTU)
Source" Category 7
NUMBER OF USES
EMISSIONS REDUCED(GXS)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source "Category "8
NUMBER OF USES
EMISSIONS REDUCED(G/S)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
Source Category 9~
NUMBER OF USES
EMISSIONS REDUCED(G/S)
INITIAL COST (1000'S*)
ANNUAL COST (1000'S*)
FUEL COST (10E+9BTU)
1
275
3438.
7084.
-21886.
-8854.
1
159
636.
4478.
-6390.
-4685.
1
467
573.
8743.
24569.
10195.
1
132
1622.
79311.
24472.
3863.
1
40
342.
0.
5051.
1804.
1
490
6921.
45468.
-79221.
-34530.
580.
15072.
3966.
0.
TECHNOLOGY
2
12
569.
2586.
1771.
730.
2
26
705.
1591.
.3531.
1233.
2
7
64.
349.
315.
150.
2 .
2
9.
196.
372.
122.
2
0
0.
0.
0.
0.
2
566
4219.
29445.
12254.
712.
2
13
76.
1263.
434.
83.
2
0
0.
0.
0.
0.
^
0
0.
0.
0.
0.
3
104
5549.
4
65
5595.
21611. 281676.
5213.
0.
TECHNOLOGY
3
163
3670.
64147.
23885.
4990.
TECHNOLOGY
3
61
1003.
5578.
1165.
0.
TECHNOLOGY
3
27
133.
92835.
11023.
4
20
641.
8212.
5277.
279.
4
58 •
1213.
65355.
23175.
2935.
4
218
2607.
1523. 139190.
300.
0.
TECHNOLOGY
3
0
0.
0.
0.
0.
TECHNOLOGY
3
0
0.
0.
0.
0.
TECHNOLOGY
3
78
1030.
55444.
6220.
4
0
0.
0.
0.
0.
4
0
0.
0.- —
0.
0,
4
366
1766.
16152. 110010.
2626.
0.
TECHNOLOGY
3
0
0.
0.
0.
0.
TECHNOLOGY
3
0
0.
0.
0.
0.
34869.
3321.
4
0
0.
0.
0.
0.
4
0
0.
0.
0.
0.
5
0
• 0.
0.
0.
0.
5
75
7006.
525564.
198040.
21366.
5
0
0.
0.
0.
0.
-
5
0
0.
0.
0.
0.
5
0
0.
0.
0.
0.
5
0
0.
0.
0.
0.
5 .
0
0.
0.
0.
0.
5
0
0.
0.
0.
0.
5
0
0.
0.
0.
0.
TOTAL
320
14926.
320815.
86476.
1642.
TOTAL
559
15460.
606597.
208847.
19014.
TOTAL
285
2916.
75759.
18264.
-1600.
TOTAL
714
3322.
149652.
31547.
-3853.
TOTAL
132
1622.
79311.
24472.
3863.
TOTAL
606
4561.
29445.
17305.
2516.
TOTAL
947
9792.
172893.
-41293.
-31125.
TOTAL
42
580.
15072.
3966.
0.
TOTAL
3
20.
0.
0.
0.
a/
See Table for legend
48
-------
TABLE 2 3
LEGEND FOR TABLES ..21 AND ..22
Technology
Source
Category
1
2
3
4
5
6
r Description
Utility Boiler
(coal)
Utility Boiler
(oil and gas)
Industrial Boilers
(coal)
Industrial Boilers
(oil and gas)
Gas Turbines
1C Engines
,
—
LEA
LEA
LEA
LEA
Water
Inject
Engine
2 3
*• -J
LEA+OSC LOW N0x
Burner
LEA+OSC LEA+OSC
+FGR
LEA+OSC Low N0x
Burner
LEA+OSC LEA+OSC
+FGR
N/A N/A
SCR N/A
4
T
SCR
LEA+OSC
+NH3
Injection
SCR
SCR
N/A
N/A
—
-
SCR
— "
— ,
—
—
Modifications
7 Industrial Pro-
cess Combustion
8 • Nitric Acid
Municipal
Incinerators
LEA
Chilled
Absorption
LEA+FGR Low N0}
Burner
N/A
N/A
•no control possible-
SCR
N/A
NOTE: LEA = Low Excess Air
OSC = Off Stoichiometric Combustion
FGR = Flue Gas Recirculation
SCR = Dry Selective Catalytic Reduction
49
-------
algorithm selected as being least costly to control. The number
of combustors is smaller than shown in Table 8 because not all
combustors within a plant have to be controlled in order to
achieve the necessary emission reduction.
Tables 21 and 22 show a breakdown by source type of capital
and annual costs (case four) for the 250 and 500 ug/m stan-
dards. Table.23 provides a legend for this table.
4. Impact of Growth on Point Source Control Costs
No attempt has been made at this point in the cost analysis
to account for the impact of emission changes over time. As
noted in the methodology section, a proper treatment of growth
would consider both point and area sources and both emission-
increasing and emission-reducing factors. Factors which may lead
to reductions in emission levels include increasingly stringent
emission requirements for mobile sources and the displacement of
fossil fuel by electricity for space heating purposes. Both of
these factors should lead to a decrease in NO emissions from
X
mobile and stationary area sources.
On the other hand, increases in electrical demand, a shift
to coal away from oil and gas in major fuel burning installa-
tions, and the requirement for continuous SO- emission control
systems on new fossil fuel-fired facilities will all lead to in-
creased emissions from point sources. Emission factors for coal-
fired equipment run two to four times higher than gas-fired
equipment, and one to two times higher than oil. The continuous
SO- emission control requirement issue is more complicated. The
Clean Air Act Amendment of 1977 required that all new fossil
fuel-fired equipment will be required to meet fixed emission
removal standards. In the case of SO-/ this requirement is
generally assumed to mean scrubber technology. If scrubbers are
50
-------
required, it will adversely affect the dispersion characteristics
of the plume resulting in higher ground-level concentrations of
NO . To the extent that N09 and NO concentrations are related,
.X ^ ^C
the requirement of fixed emission removal systems for coal-,
oil-, and gas-fired equipment will aggrevate any NO- attainment
problem.
Since the methodology used for the national assessment could
not account for interaction among point sources, and since the
major new sources of NO are adequately regulated by new source
A
performance standards, growth in point source emissions was not
considered. However, the impact of mandated mobile source con-
trols (perhaps the most obvious factor impacting future NO
X
emissions) was considered. Based on the average expected mix of
vehicles in the nation by 1982, and a conservative annual growth
rate of one percent in vehicle miles traveled, an approximate 30
percent reduction in mobile source NO emissions over the 1975
X
level is expected by 1982. This amounts to an average reduction
of about 20 percent in the total area source emissions- (and .
ambient contributions) in each AQCR, assuming that mobile sources
account for about 75 percent of area source emissions during
rush-hour periods. The results of this analysis are compared to
the no-growth case in Table 24.
The reduction in'the number of plants required to control
and the AQCR's in violation are not reduced significantly by
1982. However, due to a drop in the area source background
levels, the degree of point source control needed in 1982 is
lowered. Advanced NO control technologies are required on fewer
X
processes and the costs of point source controls are almost
halved. Economic benefit of the mobile source emission control
program in terms of much lower point source control costs in 1982
could be significant provided there is no growth in the point
51
-------
TABLE 24 '
IMPACT OF MANDATORY MOBILE SOURCE EMISSION REDUCTIONS ON THE SHORT-TERM
NOPROBLEM IN 1982*
Standard
Mg/m
500
250
1975 Point
No. of
Plants
Required
to Control
79
408
No. of
Combustors
(SCC's)
to Control
794
3,628
and Area Source Emission Base
AQCR's
in
Violation
30
119
Capital Cost
of Point
Source Control
do6 $)
46
1,496
Annual Cost
of Point
Source Control
do6 $)
•x, 1
363
1975 Point and Stationary Area Source Emissions,
1982 Mobile Source Emissions
No. of
Plants
Required
to Control
68
343
No. of
Combustors
(SCC's)
to Control
700
3,092
AQCR's
in
Violation
24
109
Capital Cost
of point
Source Control
do6 $)
34
809
Annual Cost
of Point
Source Control
(106 ?)
^ 1
124
cn
N)
•Air quality estimates in the above comparison are for case 4.
-------
source NO emissions. The latter, however, is imminent due to
JC
several factors discussed earlier in the section, but difficult
to accomodate in the analysis.
5. Area Source Control Options and Costs
a. Stationary Sources
Current available techniques for the reduction of emissions
from space heating units are: (1) tuning—the best adjustment in
terms of the smoke-CO- relationship that can be achieved by
normal clean up, nozzle replacement, and simple scaling and
adjustment with the benefit of field instruments; (2) burner re-
placment--installation of a new low emission burner; and (3) unit
replacement—installation of new advanced low NO unit.
X
Burner maintenance of replacement typically has a beneficial
impact on all pollutants except NO . Therefore, new furances
5C
with advanced design or low NO emissions hold the most promise
X
for the control of NO from residential/commercial space heating.
X
These advanced designs are based on one, or a combination of,
combustion modification techniques described briefly under the
point source section. Low NO systems for installation in new
X
homes and stores are available at a cost of ten percent or more
above conventional systems. Unfortunately, replacement of exist-
ing furnaces is cost prohibitive. The NO emission reduction
X
potential of these new systems is up to 80 percent, and the
increase in operating efficiency is about ten percent.
Small gas- and oil-fired firetube boilers are used to heat
some commercial/institutional and many relatively small indus-
trial buildings. Existing units can be retrofitted at an an-
nualized cost of about $.04 per KW of steam output, while new
53
-------
boilers with improved burners would cost about $.014 KW per year
more than conventional boilers.*
b. Mobile Sources
The Clean Air Act Amendments of 1977 mandate an emissions
standard of 1.0 g of NO per VMT for light duty vehicles (LDV's)
X
by 1981, which we have assumed extends through 1990 in the base-
line projections. The next step in a schedule of increasingly
stringent NO standards is 0.4 g/VMT. Based on information in
x 127
the "Three-Agency Report," ' this could be achieved for light
weight cars by installing a three-way catalyst, together with an
oxygen sensor in the exhaust stream, a mechanical fuel injection
system, and an upgraded electronic control unit. These would
replace the improved fuel metering, air injection, start cata-
lyst, and oxidation catalyst facilities. For heavy autos (great-
er than 3,000 pounds), the incremental control package includes
electronic spark contro'l, mechanical fuel injectors, a switched ,
air aspirator, a switched-start catalyst, and an upgraded elec-
tronic control unit. (A three-way catalyst is required, but is
also needed to meet the 1.0 g/mile standard.) These replace a
less exacting package of fuel, ignition, and exhaust controls
necessitated by the less stringent standard. Though these speci-
fications apply, strictly speaking, only to autos, we will assume
they apply to all LDV's (i.e., to all vehicles less than 6,000
pounds).
Additional initial costs are estimated to be approximately
$80 in 1985 (in 1977 dollars) for the control configuration which
is fuel-optimal. (The less expensive "cost-optimum" configura-
tion would incur substantially more in lifetime fuel costs than
*Based on a 16 percent capital recovery factor.
54
-------
the initial savings.) Lifetime maintenance expenses are esti-
mated at $30. Though these are rough approximations of costs
for unproven technologies, they serve as useful initial esti-
mates.
Inspection and maintenance programs in individual AQCR's
could be instituted or expanded to cover NO' emission controls.
X
Since I&M programs for NO currently do not exist, it is impos-
X
sible to accurately guage their costs and effectiveness. Cost
estimates for hydrocarbon and carbon monoxide I&M programs which
employ a dynamometer (a necessary ingredient for NO emission
X
tests) suggest that the inspection costs are approximately $5 per
test. Repair costs may also be incurred by vehicle owners.
However, in the absence of information on the size of these costs
or on the possible fuel savings which may be generated as a side
benefit, repair costs will be assumed to be perfectly offset by
fuel savings.
Initial, first order estimates of the effectiveness of an
147
I&M program for NO have been made by EPA. A very optimistic
A
assessment is that all failures and maladjustments could be
detected and corrected for all autos manufactured after 1981.
EPA's mobile source emission model was run with the corresponding
adjustments to the deterioration factors, and the results inputed
to the area source model used here. A 28 percent reduction in
mobile source emissions is produced in 1990.
6. Area Source Costing Procedure and Results
Based on the relative share of total emissions and the unit
costs of control, mobile sources appear to be much more.attrac-
tive candidates to focus on in strategies for achieving alterna-
tive short-term N02 standards. Stationary area sources emit a
small fraction of total area source NO (see Table 5) and are
55
-------
difficult to retrofit. Replacing all existing residential, com-
mercial, institutional, and small industrial boilers and furnaces
with low NO units would seem to be the only way to extract a
X
sizable reduction from these sources. The costs are likely to
run into the tens of billions of dollars, and even then, only a
relatively small overall reduction in total area source NO
X
emissions is likely to be achieved.
Consequently, the focus here is on mobile sources. . Projec-
tions of the effectiveness of mobile source controls are gener-
ated by changing the composite mobile source emission factor
input to the rollback model, as noted before. Control cost
estimates are made separately.
The total additional cost of introducing a 0.4 g/mi. emis-
sion schedule in 1990 over the lifetime of those cars purchased
between 1985 and 1990 can be estimated from the unit cost fig-
ures. Assuming for purposes of this report that the California
and Federal regulations are identical (and thus, a 0.4 g/mi.
standard would impose additional costs on California as well),
the total number of LDV's purchased between 1985 and 1990 can be
projected knowing (a) the total VMT for each year during this
period of time; (b) the fraction of this total driven by newly
purchased LDV's during this period; and (c) the average miles
driven per year by new LDV's.
Estimates of annual VMT in 1985 to 1990 come from the as-.
sumed annual growth rates (1.0 and 3.0 percent) applied to the
1975 base year total: 1.17x10 ' miles for light duty vehicles. '
Using EPA's estimates of .106 for the fraction of total annual
VMT accounted for by new LDV's, and EPA's estimate of 15,900
miles for the average VMT per new LDV, total, new LDV's were
estimates for each year between 1985 and 1990:
56
/
-------
(1) VMT-igp5 1990 = VMT1975 x (comP°un(3ed annual growth rate)
(2) (LDVs Purchased) = VMT1985_1J)9(J x
(New LDV VMT -as a fraction of total VMT
(Average VMT per new LDV)
Table 25 summarizes the results. The total costs for the
additional NO control over this six-year time period may be
around six or seven billion dollars. Again, these numbers
should be viewed as rough, first approximations only. Since
lifetime vehicle costs are assumed to be incurred entirely in the
1985 to 1990 period, costs are overstated. Most significantly,
the uncertainty attached to the unit cost estimates is high.
The estimate of aggregate control costs for inspection and
maintenance programs is straightforward. The number of autos
currently registered (projected to 1990) can be used to set on
upper bound to these costs. The 1990 projection is in the neigh-
borhood of 150 million cars.* At about $5 per auto, this is $750
million. Thus, the actual annual costs for vehicle owners in
those AQCR's not attaining the standard will be less than $1
billion.
Projection of the effectiveness of mobile source control
programs and the total costs of control appear in Table 26. It
is readily apparent that going to a .4 g/mi. emission standard
for new light duty vehicles is extremely cost ineffective.
Whereas the present mobile source control schedule will effect
major reduction in fleet-averaged emissions (emission factors for
early 1970 model years were greater than 5.0 g/VMT), the change
from a 1.0 to a 0.4 g/VMT standard brings but a small additional
*There were 106 million registered autos in 1975. '
57
-------
TABLE 25.
AGGREGATE COST .ESTIMATES FOR A MORE STRINGENT MOBILE SOURCE EMISSION STANDARD
Annual VMTa' For All Vehicles
(miles x 1Q12)
LDVsb// Purchased (106)
a/
b/
Vehicles miles traveled.
Total Costs (1977$ x 1Q9)C/
Year
1985
1986
1987
1988
ui 1989
00
1990
Total
Low Growth01/
1.
1.
1.
1.
1.
1.
7.
29
31
32
33
34
35
90
High
1
1
1
1
1
1
10
Growth
-------
TABLE 26
THE IMPACT OF ADDITIONAL MOBILE SOURCE NO CONTROLS ON THE
NUMBER OF NONATTAINMENT AQCR'S FOR ALTERNATIVE ONE-HOUR
N02 STANDARDS AND THE COST FOR APPLYING THE CONTROLS
(High Growth Assumption)
250 yg/m Standard
Strategy
Baseline
New Exhaust
Standard (.4g/mi.)
New Exhaust
Standard plus I&M
AQCR's Not
Attaining in 1990
73
68
49
Control Cost
(billions of $)
Capital
7
7
Annual
1
1-2
500 yg/m Standard
Strategy
Baseline
New Exhaust
Standard (.4g/mi.)
New Exhaust
Standard plus I&M
I&M Alone
AQCR's Not
Attaining in 1990
0
0
Control Cost
(billions of $)
Capital
7
7
Annual
1
1-2
59
-------
levies a heavy cost burden on all vehicle owners. An I&M program
for NO is seen to be much more cost effective, though the cost
estimates are only rough estimates.
Even with both control programs in effect, perhaps as many
as 50 AQCR's will be unable to achieve a 250 yg/m. standard in
1990. Again, this assumes a high growth rate for area sources,
that area sources are primarily responsible for the violation,
and that hourly peaks are at least six times the recorded annual
average NO- level in all AQCR's. In these AQCR's, point source
controls beyond those required as per the point source analysis
would likely be necessary. The effectiveness of these additional
controls cannot be estimated in this analysis. For a 500 yg/m
standard, only an I&M program in fewer than ten AQCR's would be
needed.
E. Comparison of the Nationwide Cost Analysis With the Chicago
Case Study
1. Multiple Point Source Interaction
Point sources were modeled individually in the nationwide
analysis. Further, the estimated maximum concentrations due to
all source's in a plant were considered additive irrespective of
the location of their maximas. The locations could vary due to
the differences in the operating and stack characteristics among
i
sources located at the same plant. The first simplification
results in an underestimation of the short-term N0_ problem where
multiple plants are located within distances that interaction
among them could be significant. The second simplification
should result in an overestimation in all'cases. The two oppo-
site errors tend to compensate each other to some extent where
multiple plants are involved. But the degree of over- or under-
estimation is a multi-variate function of the relative location
60
-------
of different plants and sources within a plant. An adjustment of
the results on a uniform basis to compensate for the errors due
to multiple point sources thus would have been unreasonable.
As noted previously for the Chicago case study, an inter-
active point source model was used. A direct comparison of the
modelling results from the two approaches (Chicago versus Nation-
wide) on a source or receptor basis was not possible because of
several significant differences summarized in Table 27. Instead,
a gross comparison was made between the costs of point source
controls in Chicago's AQCR as obtained in the two studies. Table
28 shows a comparison of the point source control costs to a-
chieve the 250 yg/m standard for the 1982 growth case.
The results are very similar, even though there are signifi-
cant differences in the analytical approaches and the data bases
used. Positive and negative errors seem to have balanced out.
It may, therefore, be fair to say that the point source costs
estimated on a nationwide basis are not seriously biased by the
simplification employed in the analysis.
F. Economic Impact
1. General Comments
A detailed assessment of economic impacts is beyond the
scope of this analysis. The nationwide scope of the study and
the diverse nature of affected sources precludes an investigation
of impacts on product prices and financial conditions within
specific industries. Instead, a qualitative discussion of likely
impacts is drawn from the cost analysis.
61
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TABLE 27
MAJOR DIFFERENCES IN THE TWO STUDIES
National Study
Chicago Case Study
1. Maximum concentrations from all
sources in a plant were summed,
2. NEDS Point Source File was used.
3. No interaction due to other point
sources in the region was assumed.
4. Area source background was estimated
from highest observed annual aver-
age concentration.
5. EEA's version of PTMAX was used
with no mixing height limit.
Only the actual concentrations from
all sources in the region at a
receptor were added.
Updated point source file was used.
(Source: NEDS, Radian, Illinois, EPA.)
Interaction was modeled for all point
sources in the region.
Area source interaction at all receptors
was modeled.
EPA1s interactive model "RAM" was used
with a mixing height limit.
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TABLE 28
COMPARISON OF THE CHICAGO AQCR RESULTS OBTAINED IN THE
NATIONAL AND CHICAGO CASE STUDY ANALYSES
Standard 250 ug/m
National
Capital
Cost
106 $
123
Analysis3'
Annual
Cost
106 $
34'
Chicago Case
Study Analysis '
Capital Annual
Cost Cost
106 $ 106 $
131 21
a/
b/
Case 4 with a 20 percent reduction in area source
emissions.
Results are for the case with a 20 percent reduction in
area source emissions.
63
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2. Point Sources
It would appear from the preceding discussion that the
expense of additional NO emission control needed to meet a
J^
short-term NO- standard will be borne by a variety of sources.
Table 29 shows a distribution of control costs by industry for
the 250 ug/m standard. At this level, plants in 14 different
categories have to institute NO controls. However, over one-
X
third of all plants are utilities. More importantly, required
controls at power plants account for almost 75 percent of total
control costs. This results from the large size of utility
boilers and the fact that several must be controlled to advanced
levels (i.e., retrofit of low NO burners or the use of dry SCR).
A
This unequal distribution of costs combined with the low expen-
diture total for all point sources indicates that utilities are
the only category of point sources likely to be economically
impacted.
A closer look at the total cost burddn accruing to utilities
indicates that the estimated cost levels are indeed modest. The
$1 billion plus capital cost will be spread over approximately
150 plants, making the per plant cost less than $10 million on
the average. To put the total cost in perspective, the estimated
capital expenditure for NO controls on existing sources is less
X
than five percent of the estimated capital expenditures between
1976 and 1990 to meet the NSPS for SO- now under consideration,
and about 0 . 1 percent of the total estimated capital expenditures
by utilities for the same period.
We can conclude, with some confidence, that the economic im-
pacts are unlikely to be. large.
64
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. TABLE 2-9
COST OF NO CONTROL BY INDUSTRY FOR A 250
Vig/m3 NO 2 STANDARD
Capital
No. of Cost
Plants (106 $)
Utility
Boilers
Internal Combustion - Reciprocating
Industrial - In Process Fuel Use
Gas & Oil Pipe Lines (I.e. Engines)
Refineries
Steel
Metal Melting
Asphalt
Lime Kiln
Glass
Cement
Food
Automotive
Wastewater Treatment
Miscellaneous
Non- Combust ion
Chemical (nitric acid, etc.)
Total
136 1065
• 26 14
18 12
37 91
23 142
15 13
10
4
4
3
4
4
3
67 11.4
24 45
408 . 1,496
Annual
Cost
(106 $)
334
3
6
-13
16
1
-
-
-
-
-
-
-
10
6
363
65
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3. Area Sources
The cost analysis for area source controls points to a much
more significant level of expenditure to meet a 250 yg/m
standard (approximately $7 billion capital—1985 to 1990,
and $1 to $2 billion annual for a 0.4 g/mi. exhaust level
and I&M program). In addition, the impacts are likely to be
experienced only within one industry (auto and light duty
truck manufacturing) and directly by consumers.
It seems likely that the cost of additional control equip-
ment needed to meet a 0.4 g/mi. exhaust standard (about $80)
would be passed along in total to auto and truck purchasers.
(Car prices would rise less than five percent.) This cost plus
the estimated $30 lifetime maintenance cost and $5 annual in-
spection fee may discourage some, potential buyers, thus depress-
ing sales industry-wide. More likely, the cost of producing the
necessary control equipment or engine modifications may vary
among manufacturers, especially between domestic and foreign
companies. To the extent that these lifetime cost differentials
are substantial, certain companies may be disadvantaged. Beyond
this cursory assessment, little more can be said at this time.
G. Summary and Conclusions
• " Either point or area sources alone can cause
violations of a 250 yg/m short-term NO-
standard. Short-term concentrations greater
than 500 yg/m are normally a result of
their combined impacts. Of the four standards
tested, only a 250 yg/m one-hour level would
be difficult to attain. Perhaps as many as
50 AQCR's would be in nonattainment in 1990
after area and point source controls were
in place. .
66
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• The-point sources with multiple short
stacks seem to behave similarly to the
area sources in terms of the meteorological
conditions which lead to maximum impact.
Their combined effects seem to be the
cause of high short-term NO- concentra-
tions in urban areas.
• The point sources with high effective dis-
charge heights do not seem to present a sub-
stantial problem taken alone. But in the
presence of other point sources and/or area
sources, their contribution is significant
enough to require some degree of NO con-
3 x
trols. However, for a 250 yg/m NO- stan-
dard, the cost of controlling these point
sources constitutes a large portion of the
total point source control costs due pri-
marily to the large size of their combus-
tors (boilers)»
• Emissions from point and area sources to-
gether (under conditions that result in
peak NO,,, concentrations overall) may lead
3
to violations of a 250 ug/m standard in
about 120 AQCR's. Under these conditions,
control of point sources alone can result
in attainment of the standard at a capital
and annualized cost of about $1.6 billion
and $340 million, respectively.
9 Area sources alone under meteorological
conditions that maximize their impacts may
61
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lead to current violations of the 250 yg/m
standard in about 95 AQCR's. Additional con-
trol on area sources will, therefore, be re-
quired.
Mobile source controls beyond the mandated
exhaust standards can bring 10 to 20 AQCR's
into attainment of a 250 yg/m standard by
1990, beyond the 20 to 30 which may reach
attainment through the turnover of the
vehicle stock. Inspection and maintenance
programs (less than $1 billion annual cost)
appear to be much more cost-effective than
a .4 g/mi. exhaust standard (about $7 bil-
lion capital and $1 billion annual).
For short-term NO- levels of 500 yg/m and
above, the magnitude of the problem is
diminished significantly. Controls on
point sources alone should bring attain-
ment of the standard at all times in most
AQCR's. The capital costs of point source
control to attain a 500 yg/m level are
about $46 million, while annual costs are
close to zero due to fuel savings. Between
five and ten AQCR's may still be in viola-
tion of this standard in 1990 due to area
source emissions. These could be brought
into attainment if an aggresive I&M program
were instituted in each AQCR at an annual
cost of a few hundred million dollars.
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VOLUME II REFERENCES
1. Memorandum from Joseph A. Tikvart (EPA Source-Receptor
Analysis Branch) to Edward J. Lillis (EPA Air Management
Technology Branch), February 16, 1978.
2. John Trijonis, Empirical Relationships Between Atmospheric
Nitrogen Dioxide and its Precursors, EPA-600/3-78-018, EPA,
Office of Research and Development, Research Triangle Park,
North Carolina, February 1978.
3. Control Techniques for Nitrogen Oxide Emissions From Sta-
tionary Sources—Revised Draft Second Edition, Aerotherm
Report TR-77-87, December 1977.
4. Control of Oxides of Nitrogen From Stationary Sources in
the South Coast Air Basin, California Air Resources Board
ARE 2-1471, September 1974.
5. Compilation of Air Pollutant Emission Factors, EPA AP-42,
5th Edition, 1976.
6. Impact of Point Source Control Strategies on N02 levels,
Discussion Draft prepared for EPA, Radian Corporation,
February 1978.
7. Thuillier, R.W.., W. Viezee, Air Quality Analysis in Support
of a Short-Term Nitrogen Dioxide Standard, Discussion Draft
prepared for EPA, SRI International, December 1977.
8. Bureau of Economic Analysis, U.S. Department of Commerce,
Tracking the BEA State Economic Projections, April 1976.
This is also the growth rate adopted by EPA.
9. Personal communication with Paul Stolpman, Environmental
Protection Agency, Office of Policy Analysis.
10. The estimates of future emission factors were computed by
Paul Stolpman using EPA;s mobile source emission model.
11. Air Pollution Engineering Manual, Second Edition, U.S. EPA,
AP-67, May 1973.
69
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Volume II References (Continued)
12. U.S. Department of Transportation, U.S. Environmental Pro-
tection Agency, U.S. Federal Energy Administration (now
the Department of Energy), An Analysis of Alternative Motor
Vehicle Emissions Standards, May 10, '1977, as revised on
April 13, 1977, Tables A-7 and A-8.
13. B.F. Kincannon and A.H. Castoline, Information Document on
Automobile Emissions Inspection and Maintenance Programs,
EPA, Washington, D.C., February 1978.
14. Personal communications from Paul Stolpman, EPA,' Office of
Policy Analysis.
15. Bhatt, K., M. Beasely, K. Neels, Analysis of Road Expendi-
tures and Payments by Vehicle Class, 1956-1975, The Urban
Institute/ Washington, D.C., March 1977. The future for
total VMT by LDV's in 1975 (1.17xl012 miles) was approxi-
mated from reported VMT.for autos and trucks up to 12,000
pounds registered weight, the latter adjusted by the percent
of registered truckes accounted for by the 0-8,000 pound
registered weight class. (This corresponds approximately
to the 0-6,000 pound chasis weight class.)
16. Motor Vehicle Manufacturers' Association, MVMA Motor Vehicle
Guide, Facts and Figures 1977.
17. Personal communication from Richard Jenkins, EPA, Office of
Air Quality Planning and Standards, Data on S02 scrubber
costs come from Paul Lashotopf Temple, Barker and Sloan.
70
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