1
MEMORANDUM
TO:
Docket
No
OAR­
2002­
0058
FROM:
Jim
Eddinger,
U.
S.
Environmental
Protection
Agency,
OAQPS
(
C439­
01)

DATE:
February
2004
SUBJECT:
Estimating
Impact
on
Control
Costs
and
Emissions
Reductions
of
the
Health­
Based
Compliance
Alternatives
The
purpose
of
this
memorandum
is
to
document
the
impact
on
the
estimated
capital
and
annual
costs
and
emissions
reductions
for
the
industrial,
commercial,
and
institutional
boilers
and
process
heaters
NESHAP
if
health­
based
compliance
alternatives
are
included
in
the
final
rule.

If
the
final
rule
contains
health­
based
compliance
alternatives
establishing
eligibility
criteria
for
an
exclusion
from
the
installing
additional
controls
for
HCl
emissions
and
an
exclusion
from
including
manganese
in
the
total
selected
metals
emission
rate,
the
impacts
of
the
final
rule
will
be
reduced
from
the
impacts
estimated
at
proposal.
The
reduction
in
costs
and
environmental
impacts
associated
with
inclusion
of
the
health­
based
compliance
alternatives
are
summarized
in
the
following
sections.

1.
Estimated
Number
of
Eligible
Facilities
To
estimate
the
potential
impact
of
the
health­
based
compliance
alternatives,
we
performed
a
preliminary
"
rough"
assessment
of
the
existing
large
solid
fuel
subcategory.
The
health­
based
look­
up
tables
are
based
on
stack
height
and
fenceline
distance
for
which
we
do
not
have
information
for
each
of
the
units
in
the
database.
Therefore,
to
determine
the
health­
based
emission
level,
we
used
the
minimum
stack
height
and
fenceline
distance.
This
approach
would
tend
to
estimate
the
minimum
impacts
of
inclusion
of
the
health­
based
compliance
alternatives.
2
Based
on
the
HCl
lookup
table
and
using
the
uncontrolled
HCl
emission
factor,
facilities
with
less
than
587
million
Btu
per
hour
heat
input
of
coal
capacity
would
be
eligible
for
the
health­
based
HCl
emission
limit.
Assuming
2
boilers
per
facility,
this
would
indicate
coal­
fired
boilers
below
250
million
Btu
per
hour
would
not
incur
any
control
costs
for
HCl.
This
would
indicate
that
the
following
model
units
would
not
incur
any
control
costs:
2d,
3e,
6d,
and
7e.
The
total
number
of
coal­
fired
boilers
in
these
models
is
448.

Based
on
the
manganese
lookup
table
and
using
the
emission
factor
for
wood­
fired
units
controlled
with
cyclones,
facilities
with
less
than
84
million
Btu
per
hour
heat
input
of
wood
capacity
would
be
able
to
exclude
manganese
from
the
total
selected
metals
emission
rate.

Assuming
2
boilers
per
facility,
this
would
indicate
wood­
fired
boilers
below
45
million
Btu
per
hour
would
not
incur
any
control
costs
for
complying
with
the
total
selected
metals
limit.
This
would
indicate
that
the
following
model
units
would
not
incur
any
control
costs:
30a,
30b,
30e,

34a,
34b,
and
34d.
The
total
number
of
wood­
fired
boilers
in
these
models
is
386.

Based
on
the
results
of
this
rough
assessment,
448
coal­
fired
boilers
could
potentially
be
eligible
for
the
alternative
health­
based
HCl
limit
and
386
biomass­
fired
boilers
could
be
eligible
for
the
manganese
exclusion.
The
difference
in
costs
and
environmental
impacts
due
to
inclusion
of
the
health­
based
compliance
alternatives
are
summarized
in
the
following
paragraphs.
If
the
facility's
baseline
emissions
were
less
or
they
had
taller
stacks,
these
size
values
and
impacts
would
be
greater.

2.
Air
quality
impacts
We
estimate
that
the
total
HAP
emissions
reductions,
estimated
at
proposal,
will
decrease
by
5600
tons/
yr
due
to
facilities
becoming
eligible
for
the
health­
based
provisions.
This
estimate
is
based
on
the
summation
of
the
total
projected
HAP
reductions
for
the
models
cited
above.

Therefore,
considering
the
impact
of
facilities
becoming
eligible
for
the
health­
based
provisions,

the
total
estimated
reduction
in
HAP
emissions
of
the
final
rule
is
52,400
tons/
yr.

Including
the
health­
based
compliance
alternatives
will
affect
the
estimates
of
criteria
pollutant
reductions
as
well.
We
estimate
that
PM
and
SO2
emissions
reductions
estimates
will
3
decrease
by
17,100
and
64,000
tons/
yr,
respectively.
As
a
result,
we
estimate
that
the
total
reduction
in
PM
and
SO2
emissions
will
be
approximately
549,000
and
49,000
tons/
yr,

respectively.

3.
Cost
impacts
Facilities
that
become
eligible
for
the
health­
based
provisions
will
not
need
to
install
control
equipment
to
comply
with
the
final
rule.
Therefore,
the
high­
end
estimated
costs
of
the
final
rule
will
be
less
than
that
estimated
at
proposal
We
estimate
that
the
total
annualized
costs,

which
include
annualized
capital
costs
for
control
and
monitoring
equipment,
operation
and
maintenance
expenses,
and
recordkeeping
and
reporting
costs,
will
decrease
by
$
145
million.

This
estimate
is
based
on
the
summation
of
the
total
projected
costs
for
the
models
cited
above.

Therefore,
we
estimate
that
the
total
annualized
costs
of
the
final
rule
are
$
690
million.
