LADCO Evaluation of Candidate Control Measures

1. LADCO Evaluation of Candidate Control Measures Regional Air Quality Workshop November 17, 2004 Presented By: Edward Sabo MACTEC Federal Programs ejsabo@mactec.com

2. Project Overview • Candidate Control Measures • Identify potential emission reduction measures • Conduct technical and cost analysis • Fresh assessment of RACT for VOC and NOx • BART Regional Engineering Analysis • Prioritize non-EGU source categories • Identify potential emission reduction measures • Recommend approach for BART analysis • Implement BART approach for specific sources

3. Preliminary Estimates of Reductions from Candidate Control Measures • Databases Used • EPA’s Preliminary NEI 2002 • EPA’s 2010 Projections from CAIR Rule • Candidate Control Measures from Literature • NOTE: Inventories are being updated • Revised 2002 inventories from States • Revised 2009 inventory from EH Pechan • Doesn’t include results from SEMCOG study

4. Control Strategy Scenarios • On-the-Books (OTB) • State/local regs to meet 1-hour ozone NAAQS • Heavy Duty Diesel Engines/Low Sulfur Fuel • Federal Locomotive/Commercial Marine Vessel • Tier 2 Tailpipe/Low Sulfur Fuel • Title IV for Phase I and II EGUs • MACT standards with post-2002 compliance date • On-the-Way (Proposed, not Final) • Clean Air Interstate Rule (EGUs) • Nonattainment requirements for 8-hour ozone/PM2.5 (NOT yet defined – not accounted for here) • Candidate Control Measures • Initial set of possible measures selected by States, NOT a complete universe of all potential measures

5. SO2 Emissions By Sector for LADCO Region

6. SO2 Candidate Control Measures • Beyond CAIR reductions for EGUs • More stringent emission caps • CAIR 50% reduction from 2002 • Candidate measures 60 to 85% reduction from 2002 • Accelerated schedule for meeting caps • Industrial Fuel Combustion • Boilers • Process Heaters • Industrial Processes

7. Disclaimer • “The candidate control measures identified in this presentation represent an initial set of possible measures. The Midwest RPO States have not yet determined which measures will be necessary to meet the requirements of the Clean Air Act. As such, the inclusion of a particular measure here should not be interpreted as a commitment or decision by any State to adopt that measure. Other measures will be examined in the near future. Evaluation of additional potential control measures will be likely”.

8. NOx Emissions By Sector for LADCO Region

9. NOx Candidate Control Measures • Beyond CAIR/NOx SIP Call reductions for EGUs • More stringent emission caps • CAIR 60% reduction from 2002 • Candidate measures 60 to 80% reduction from 2002 • Accelerated schedule for meeting caps • Industrial Fuel Combustion • Beyond NOx SIP Call limits (80% vs. 60% control) • Lower size threshold (100 mmBtu/hr vs. 250 mmBtu/hr) • Highway Vehicle Inspection/Maintenance • Onroad/offroad Diesel

10. IM Program Enhancements/Alternatives • OBD II Only • Gross Polluter Annual Tailpipe Test • High Mileage Vehicle Annual Tailpipe Test • Model Year Exemptions • Self Certification - fleets • Wireless OBD- Kiosks, GPS • In use Vehicle Monitoring - NetWork Car concept • MERC’s- Vehicle Retirement, Repair Assistance, catalytic converter replacement

11. Onroad and Offroad Diesels • Fleet Retrofit Programs • Clean School Bus • Diesel Idling Restrictions • Fuels • Locomotives, Aircraft, Commercial Vessels • Low priority for now, may need to revisit

12. VOC Emissions By Sector for LADCO Region

13. VOC Candidate Control Measures – Fuel Evaporation • IM Enhancements/Alternatives • Alternative Fuels • Stage I Vapor Recovery • Increase stringency (98% vs 90% control) • Increase geographic coverage • Stage II • On-board canisters penetrate over time • Vapor recovery nozzles • Portable Fuel Containers

14. VOC Candidate Control Measures – Area Sources • Architectural, Industrial Maintenace, and Traffic Marking Coatings • Adopt OTC Model Rule (31% reduction beyond Federal AIM Rule • Consumer Commercial Products • Adopt OTC Model Rule (14% reduction beyond Federal rule) • Cutback Asphalt • Promotion of Low-VOC Emulsion Asphalt

15. VOC Candidate Control Measures – Industrial Sources • Degreasing Operations • Adopt OTC Model Rule (66% overall control) • Improved RACT • Tighten RACT requirements based on more stringent State/District rules and MACT standards • Example – 100% capture permanent total enclosures • Expanded RACT Geographic Coverage • RACT in new 8-hour nonattainment areas • Possibly surrounding counties?

16. PM2.5 Emissions By Sector for LADCO Region (does not include fugitive dust sectors)

17. PM2.5 Candidate Control Measures • Few Measures Identified to Date • Revised PM limits for Steel Mills • Bulk of PM2.5 Primary Emissions in Low-priority categories • Agricultural crop tilling • Paved/unpaved road dust • Constructions Activities • Fireplaces, woodstoves • Open burning

18. Summary of Preliminary Reductions • SO2 • On-the-Way controls 37% reduction from 2002 • Candidate controls additional 54% reduction • NOx • On-the-Way controls 33% reduction from 2002 • Candidate controls additional 13% reduction • VOC • On-the-Way controls 17% reduction from 2002 • Candidate controls additional 7% reduction

19. First Drafts Utility Fuel Combustion Architectural Industrial Maintenance Coatings Other Priority Categories Industrial Fuel Combustion Steel Mill PM Petroleum Refineries Surface Coating RACT Portable Fuel Containers Stage I and Stage II Consumer Products Degreasing IM enhancement/alternatives Diesel retrofit/idling Next Step – White Papers

20. Format for White Papers • Source Category Description • Regulatory History • Description of Candidate Control Measures • Expected Emission Reductions • Cost Effectiveness and Basis • Geographic/seasonal Applicability • Time Frame for Implementation • Regulatory Implementation Issues • Other Impacts • References

21. Update on Fresh Assessment of RACT • Review basis for current RACT rules • Based on guidance from mid-1990s or earlier • Compare relative stringency of LADCO state RACT rules to other agencies • South Coast, Bay Area, NJ, MD, MA • Provide recommendations for tightening RACT

22. Update on Non-EGU BART Regional Engineering Analysis • BART-eligible sources identified by LADCO States • Data QA’d for location information • Distance to Class I areas calculated using GIS • Class I areas included: Isle Royale, Seney, Boundary Waters, Mammoth Cave, Mingo, Dolly Sods • Final selection of categories was based on emissions, number of facilities in each category, commonality of facilities between States and Q/D values • Q/D values calculated using both SO2 emissions and sum of NOx and SO2 emissions • Sources with Q/D values >=10 were included in list of potential sources to evaluate for BART

23. Non-EGU BART Priority Categories • Category 22 (fossil fuel fired boilers) • Category 11 (petroleum refineries) • Category 4 (cement plants) • Category 6 (iron/steel mill plants) • Category 21(chemical plants)

24. Next Steps • Candidate Control Measures • Early December - Draft White Papers for priority categories • January 2005 - Final White Papers for priority categories • February 2005 - Data (control factor) file for select measures • RACT Assessment • December - Draft tables/report • January 2005 – Final recommendations • Non-EGU BART Analysis • December - Identification of potential control measures • January 2005 – Approach for Regional Engineering Analysis • Winter 2005 - application to specific sources