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PREFACE
This report is a modification of a preliminary analysis
entitled "Preliminary Assessment of Economic Impact of Visibility
Regulations" completed in May 1980 for the U.S. EPA. The reassess-
ment is in response to numerous public comments received on the
proposed visibility regulations, and additional information received
by the Agency.
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ASSESSMENT OF ECONOMIC IMPACTS OF VISIBILITY REGULATIONS
INTRODUCTION
In support of the proposed visibility regulations EPA through its
contractor, ICF, Inc., prepared a draft report "Preliminary Assessment
of Economic Impact of Visibility Regulations," dated May 1980. That
draft assessment was prepared during the period of regulatory development
and was based on a general knowledge of the concepts of the regulations
and not on specific regulatory language.
Based upon public comments EPA reassessed the impact of the regulations
and found that the preliminary assessment over estimated the impact of
the regulations.
PRELIMINARY ASSESSMENT
The Preliminary Assessment evaluated those existing stationary
facilities which met the Best Available Retrofit Technology (BART) age
and size requirements as specified in S169A of the Act for their potential
effect on visual range and discoloration, two parameters identified as
characterizing visibility impairment.
For purposes of this initial analysis, four alternative scenarios
were evaluated. This consisted of two separate criteria for identifying
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those sources potentially affected by visibility regulations and two
separate criteria for identifying the level of control required of those
sources.
To identify those sources potentially affected, EPA proposed criteria
which provided both a minimum distance from the mandatory Class 1 Federal
This report is available through U.S. Environmental Protection Agency,
Control Programs Development Division, MD-15, Research Triangle Park,
M.C. 27711.
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area and a de minimus emissions requirement. To be conservative in
identifying potential sources, another criteria was applied which used
Environmental Research and Technology, Inc. (ERT) screening curves, or
2
models, consisting of a minimum distance requirement plus estimates of
visual range reduction and discoloration based on current annual emissions.
The level of control required was evaluated for the two types of
visibility impairment-visual range reduction and discoloration. Values
of 5% and 13% were used for visual range reduction'and for discoloration,
threshold blue-red ratios of .95 and .90 were used. Emissions of particulates
and sulfur dioxide were used to estimate visual range reduction. Emissions
of NO were used for evaluating discoloration. EPA's National Emissions
X
Data System (NEDS) provided the emissions data used in this initial
analysis.
The four scenarios identified five power plants as having to reduce
emissions to meet a 5% visual range reduction value and one power plant
having to reduce emissions to meet a 13% value. Seven power plants were
shown as having to reduce NO emissions in order to achieve a blue-red
A
ratio of either .95 or .90. No existing industrial sources were identified
as being potentially affected by visibility regulations.
The total capital cost estimated in the Preliminary Assessment of
retrofitting 10 power plants (two power plants appeared on both lists) to
meet the above stated levels of control was approximately $500 million
(1980 dollars). $350 million of this can be attributed to control of
particulate and S02 emissions for visual range and $168 million can be
attributed to control of NO emissions for discoloration.
A
2
Screening curves were provided by ERT, Inc. from a working draft report
submitted to the Office of Environment, Policy Analysis Division,
Department of Energy.
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Several important qualifications and limitations to this analysis
were pointed out in the Preliminary Assessment. The key elements were
1) the reliance on NEDS to identify the sources evaluated, and 2) screening
curves measuring the impact of emissions on visibility developed by ERT,
Inc. In response to these limitations, and other deficiencies pointed
out by many of the public comments received on the proposed regulations,
EPA has reassessed the report.
Reassessment
Based on public comments, EPA reevaluated the assumption upon which
the preliminary analysis was based. EPA determined that:
(1) S02 emissions are generally associated with regional haze and
are not to be addressed in the visibility regulations promulgated under
the initial phases (Phase 1) of the EPA program. No major sources are
expected to have to install SOp controls.
(2) NO emissions, at the present time, cannot be reduced to
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achieve a substantial improvement in visibility. Therefore, EPA is
^
planning to delay imposition of NO controls "until such time as more ,
J\
effective with respect to visibility, controls are available."
(3) Particulate emissions are expected to impact visibility with
respect to Phase I concerns only in a single case. The emissions from
this source are expected to be reduced as required by current applicable
State Implementation Plan provisions to an acceptable level.
Walter Barber, EPA, to George Eads, Council on Wage and Price Stability,
September 17, 1980.
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Based upon an examination of the potentially effected sources, only
one existing power plant in the U.S. would be identified as potentially
having to reduce current particulate emissions to meet a threshold value
for visual range reduction of either five or 13 percent. This power plant,
the Four Corners plant located in New Mexico near the Mesa Verde Class I
area, has particulate emissions which, when using the ERT screening
curves, would imply an impact on visual range in excess of five percent.
However, consistent with requirements of the New Mexico State
Implementation Plan, the utilities who own and operate Four Corners have
agreed to install baghouse collectors on Units 4 and 5 to comply with an
emission limit of 0.05 Ibs. of particulate per million Btu by 1983.
Once installed, the estimated impact of particulate emissions from this
power plant, again using the ERT screening curves, is well below either
threshold limit.
Therefore, no existing sources have been identified as potentially
affected by the initial phase of EPA's regulatory program for visibility.
This finding is of course subject to the limitations and caveats of the
approach and assumptions used in this analysis.
It should be emphasized that the estimates for this analysis are
not intended to be a detailed site-specific analysis which can only be
accomplished by the State performing a BART analysis.
This analysis was to address only the retrofit of existing sources
related to near-field visibility impairment. Issues such as the effects
(a) of State long-term strategies, (b) of new sources review requirements,
and (c) of regional haze considerations were explicitly excluded.
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