1
PM
NAAQS
RIA:

Status
of
Controls
Database
and
Control
Selection
Strategies
Discussion
with
OMB
June
7,
2006
2
Overview

Controls
Database
Structure

Strategy
for
Selecting
Controls

Control
Strategy
Selection
for
the
15/
65
"
Current
Standards"
Scenario
3
Structure
of
Controls
Database

Control
are
divided
into
three
categories:


"
Known"
controls

Database
of
well­
demonstrated
controls
that
can
be
applied
to
emissions
sources
today
(
AirControlNET)


Applicable
for
analysis
of
point
and
area
sources

"
Developmental"
controls

Includes
controls
not
already
contained
in
the
ACN,
as
well
as
newer
innovative
controls
that
could
be
applied
in
future
years

"
Unidentified"
controls

Determination
of
a
reasonable
control
efficiency
and
cost
estimate
for
remaining
tons
contributing
to
non­
attainment
that
are
not
captured
with
Known
or
Developmental
controls

Mobile
sources
and
Regional
EGU
SO2
controls
are
developed
by
OTAQ
and
CAMD

Used
as
input
to
Known
and
Developmental
controls
in
the
attainment
strategy
4
Control
Measures
Added
Since
the
Proposal
RIA

Direct
PM
from
EGU
sources:
upgrade
in
control
efficiency
on
existing
ESPs
(
electrostatic
precipitators),
only
applicable
to
coalfired
EGUs

Agricultural
ammonia:


California:
San
Joaquin
Valley
Dairy
Manure
Technologies
(
6
technologies)


Ohio
Valley:
Environmentally
superior
waste
management
technologies
for
hog
operations
based
on
NC
Smithfield
agreement
analysis

Area
Sources:


Substitution
of
chipping
for
burning
(
household
and
open
burning)


Fireplace
inserts

Fuel
switching
(
high
sulfur
to
low
sulfur)


NonEGU
point
sources

Fuel
switching
(
high
sulfur
to
low
sulfur)


Diesel
particulate
filters
5
Control
Measures
Added
Since
the
Proposal
RIA
(
continued)


Mobile
Sources:


National
rules

Diesel
Locomotives

Diesel
Marine
Vessels

Ocean
Going
Vessels

Residual
Fuel
in
Ocean
Going
Vessels

Small
Nonroad
Gasoline
Engines

Voluntary/
local
measures

Diesel
Retrofits
and
Retirement

Eliminate
Long
Duration
Idling

Intermodal
­
Shift
from
Trucks
to
Rail

Best
Workplaces
for
Commuters
(
BWC)


State
programs

California
ports
control
initiative
(
ships
and
harborcraft)
6
Strategy
for
Selecting
Controls

Strive
to
attain
the
15/
65
standards
using
local
control
measures

"
Local"
is
defined
as
the
MSA
that
contains
the
nonattainment
county
(
multiple
counties)


If
cannot
attain
via
local
controls,
we
considered
control
available
in
neighboring
counties
to
the
MSA

Least
cost
controls
were
applied

If
we
did
not
reach
attainment
within
the
MSA,
we
considered
further
controls
in
3
subregions:


Ohio
Valley/
Great
Lakes
subregion,


California
subregion,
and

Northeast
subregion
(
not
needed
for
15/
65
scenario)
7
Subregions
for
15/
65
Analysis
8
Strategy
for
Selecting
Controls
(
Cont.)


Apply
the
least­
cost
and
most
efficient
controls
first

We
calculated
$
cost/
ug
reduced
for
each
pollutant/
source
combination
for
each
county
analyzed

Pollutants:
Direct
PM
(
carbon),
NOx,
SO2,
NH3

Sources:
Point
(
EGU
and
Non­
EGU),
Area,
Mobile

Select
controls
until
the
pollutant/
source
category
reaches
cost/
ton
=
benefits/
ton
for
the
county
analyzed

$
ben/
ton
is
calculated
for
each
pollutant/
source
category
in
each
of
the
areas
assessed
in
detail
with
the
Response
Surface
Model
at
proposal.


Once
the
pollutant/
source
category
reaches
a
$
cost/
ton
that
equals
the
$
ben/
ton,
then
we
switched
to
the
next
pollutant/
source
category
with
the
next
most
efficient
pollutant/
source
to
achieve
ug
reductions
(
i.
e.,
the
next
lowest
$
cost/
ug
reduced).
9
Strategy
for
Selecting
Controls
(
cont.)


Mobile
sources

The
National
Rules
are
applied
first
to
all
nonattainment
areas
(
local
MSA
counties
only),
then
apply
local
control
measures
where
we
do
not
attain
(
and
using
the
$/
ug
data
to
determine
cost
effectiveness)


EGU's

No
EGU
controls
for
SO2
considered
for
sources
located
in
the
CAIR
region
for
15/
65

EGU
controls
for
direct
PM
were
considered
when
the
$/
ug
was
lower
in
cost
than
other
"
Known"
controls
for
point
sources
10
Results
of
Control
Strategy
Selection
for
15/
65

Total
cost
of
the
15/
65
scenario
in
2020
is
less
than
$
1
billion
(
annualized
costs
are
presented
throughout
the
following
discussion)


Attainment
achieved
with
local
controls
for
the
following
areas:


Atlanta

Birmingham

St.
Louis

Lincoln,
MT

Chicago
(
plus
neighboring
counties
to
the
MSA)


The
following
areas
require
both
local
controls
and
controls
obtained
from
a
set
of
counties
defined
for
an
Ohio
Valley/
Great
Lakes
subregion

Cleveland

Detroit

Pittsburgh

Subregional
controls
were
required
for
California
 
note
that
most
nonattainment
counties
in
CA
did
not
reach
attainment
with
available
controls.
11
Results
for
Eastern
U.
S.


Applied
controls
on
point
sources,
area
sources,
mobile
sources,

and
coal­
fired
EGUs
(
for
direct
PM
only)


Controls
mostly
directed
at
direct
PM
emissions
(
which
reduces
elemental
and
organic
carbon)


Indicated
as
the
most
effective
pollutant
to
control
in
most
cases
based
on
the
level
of
ug
reduced
per
ton
of
emissions.


NOx
and
VOC
were
less
effective
in
the
East

SOx
and
NH3
reductions
effective
in
some
areas

Applied
NH3
controls
as
an
innovative
control
measure
only
where
it
was
more
difficult
to
achieve

Total
Cost
for
the
Eastern
U.
S.
is
approximately
$
180
million

On
average,
the
cost/
ton
ranged
from
$
1,800
to
$
6,000

In
one
NA
area,
cost/
ton
reached
$
25,000,
but
benefits
per
ton
were
$
200,000
12
Results
for
Western
U.
S.


Lincoln,
MT
reaches
attainment
with
local
controls

Applied
area
source
controls
for
direct
PM
(
carbon)
and
NOx
for
a
cost
of
$
21,000.


California
consists
of
a
subregion
designed
to
include
most
of
Southern
CA

Controls
applied
to
mobile
sources,
gas­
fired
EGUs,
and
point
and
area
sources

Mobile
and
EGU
emissions
are
most
effective
to
achieve
reductions
towards
attainment

NOx,
VOC,
and
NH3
emissions
are
most
effective
in
reducing
PM

Also
applied
direct
PM
controls

Total
Cost
for
the
California
subregion
is
approximately
$
800
million

On
average,
the
cost/
ton
ranged
from
$
1,400
to
$
13,000

In
one
sector,
the
cost/
ton
reached
$
60,000,
but
benefits
per
ton
were
$
400,000
for
this
sector

Determination
of
attainment
is
more
uncertain
due
to
difficulties
in
modeling
CA
air
quality
13
14
15
16
17
Appendix
Findings
by
Non­
Attainment
Area
18
Findings
by
Non­
Attainment
Area

Atlanta

Cost
of
$
18.1
million

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
woodstoves,
commercial
cooking,
utility
and
industrial
boilers

Birmingham

Cost
of
$
12
million

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
Iron
&
Steel,
and
Mineral
Products
19
Findings
by
Non­
Attainment
Area

St.
Louis

Cost
of
$
1
million

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
Iron
&
Steel,
and
coal­
fired
EGU
(
direct
PM
only)


Lincoln,
MT

Cost
of
$
21,000

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
Industrial
Boiler,
and
woodstoves
20
Findings
by
Non­
Attainment
Area

Chicago

Cost
of
$
25
million

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
woodstoves,
commercial
cooking,
home
heating
oil,
Iron
&
Steel,
mineral
products,

chemical
manufacturing,
and
coal­
fired
EGU
(
direct
PM
only)
21
Findings
by
Non­
Attainment
Area

Ohio
subregion

Includes
the
Cleveland,
Detroit,
and
Pittsburgh
nonattainment
areas

Used
local
controls
on
direct
PM
applied
to
mobile
sources,
coal­
fired
industrial
boilers,
Iron
&
Steel,

asphalt
and
chemical
manufacturing,
and
coalfired
EGU
(
direct
PM
only)


Total
cost
for
the
subregion
is
$
129
million.
