Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
1
Analysis
of
non­
EGU
sources
considers
the
application
of
controls
at
the
source
category
level
up
to
a
specified
average
cost
per
ton
cutoff.

8­
1
Chapter
8.
RESULTS
OF
COST,
EMISSIONS
REDUCTIONS,
AND
ECONOMIC
IMPACT
ANALYSES
FOR
NON­
ELECTRICITY
GENERATING
UNITS
This
chapter
presents
the
results
of
the
cost
analyses
for
the
non­
EGU
sources
in
BART
source
categories
covered
in
these
analyses.
The
cost
analyses
evaluate
the
potential
impacts
associated
with
the
final
BART
rule,
based
on
assumptions
about
how
the
States
may
implement
controls
for
non­
EGU
sources.
As
mentioned
in
Chapter
3,
there
are
25
non­
EGU
source
categories
that
are
to
be
considered
for
controls
associated
with
the
BART
program.
Section
8.1
presents
a
short
summary
of
the
results
of
the
impact
analyses.
Section
8.2
presents
a
description
of
the
methodological
approach
for
these
cost
analyses,
the
options
that
are
analyzed,
and
important
assumptions
and
details
that
underlie
the
costs
and
emission
reductions
for
each
option.
Section
8.3
mentions
the
control
technologies
that
are
applied
to
the
non­
EGU
source
categories
in
this
analysis.
Section
8.4
provides
a
list
of
the
source
categories
affected
and
summaries
of
analysis
results
by
BART
source
category.
Section
8.5
provides
summaries
of
the
results
of
these
analyses
across
sources
categories.
Section
8.6
presents
a
listing
of
caveats
and
limitations
associated
with
the
cost
analyses.
More
detailed
results
for
the
other
options
considered
are
provided
in
the
technical
support
document
for
these
analyses
(
E.
H.
Pechan,
2005).
Finally,
references
for
the
chapter
are
provided
in
Section
8.7.

8.1
Results
in
Brief
The
results
for
applying
the
options
examined
for
control
of
2015
SO2
and
NOx
emissions
at
non­
EGU
BART­
eligible
units
range
from
83,778
tons
to
378,169
tons
of
SO2
and
165,634
tons
to
391,101
tons
of
NOx
nationwide
for
costs
annualized
at
a
7
percent
interest
rate.
For
costs
annualized
at
a
3
percent
interest
rate,
the
reduction
of
SO2
emissions
in
2015
range
from
132,279
tons
to
373,797
tons
and
the
reduction
of
NOx
emissions
in
2015
range
from
246,607
tons
to
393,349
tons.
Annualized
costs
associated
with
these
reductions
in
2015
range
from
$
151.43
million
to
$
2.24
billion
(
1999$)
for
costs
estimated
at
a
7
percent
interest
rate
and
from
$
272.23
million
to
$
1,770.21
million
(
1999$)
for
costs
estimated
at
a
3
percent
interest
rate.
The
capital
costs
associated
with
these
reductions
in
2015
ranges
from
$
655.70
million
to
$
14.75
billion
for
costs
estimated
at
a
7
percent
interest
rate
and
from
$
1,881.70
million
to
$
12.73
billion.

8.2
Costs
and
Analysis
Approach
In
this
RIA
chapter,
three
illustrative
regulatory
options
are
applied
to
non­
EGU
BART­
eligible
sources.
Costs
and
emissions
reductions
for
these
sources
are
estimated
for
these
annualized
cost
per
ton
options
for
reducing
SO2
and
NOx
at
varying
levels
of
stringency:
$
1,000,
$
4,000,
and
$
10,000.1
The
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
2
For
more
information
on
the
emissions
and
control
measures
within
AirControlNET,
go
to
www.
epa.
gov/
ttn/
ecas/
AirControlNET.
htm.
Documentation
for
emissions
data
and
control
measures
can
be
found
at
this
Web
site.

8­
2
$
1,000/
ton
alternative
is
called
the
"
least
stringent"
option,
the
$
4,000/
ton
alternative
is
the
"
medium
stringent"
option,
and
the
$
10,000/
ton
alternative
is
the
"
most
stringent"
option.
These
options
are
applied
nationwide.
For
purposes
of
consistency
with
the
descriptions
for
the
EGU
options,
the
"
least
stringent"
option
is
called
Option
1,
the
"
medium
stringent"
option
is
called
Option
2,
and
the
"
most
stringent"
option
is
called
Option
3.
These
options
are
meant
to
be
illustrative
of
the
potential
control
options
that
may
be
available
to
States
as
they
consider
what
scenarios
to
include
in
their
State
Implementation
Plans
(
SIPs)
for
non­
EGU
sources.
These
options
are
also
compliance
with
the
requirement
in
OMB
Circular
A­
4
to
examine
alternative
levels
of
stringency
as
part
of
an
RIA.

The
potential
costs
of
complying
with
the
BART
rule
estimated
in
this
chapter
are
those
from
installation,
operation,
and
maintenance
of
control
device
that
may
be
applied
in
response
to
the
provisions
of
SIP)
that
may
require
controls
of
these
non­
EGU
sources.
In
addition
to
these
analyses,
results
from
analyses
in
which
important
components
of
the
costs
such
as
interest
rates,
labor
rates,
and
energy
rates
are
varied
to
determine
the
sensitivity
of
the
costs
to
such
variation.
We
present
such
results
in
Appendix
B.
Costs
from
monitoring,
recordkeeping,
and
reporting
are
not
included
in
this
cost
analysis
since
these
costs
are
accounted
for
in
the
Regional
Haze
ICR.

Two
types
of
costs
will
be
incurred
in
association
with
the
addition
of
control
technologies:
a
onetime
capital
cost
for
new
equipment
installation,
and
increased
annual
operating
and
maintenance
costs.
In
general,
economies
of
scale
exist
for
pollution
control
technologies
for
both
capital
costs
and
operating
and
maintenance
costs.
Thus,
the
size
of
the
unit
to
which
controls
are
applied
will
determine,
in
part,
the
cost
of
implementing
the
pollution
control(
s).

For
each
affected
source
category,
EPA's
estimates
of
emissions
reductions
and
costs
reflect
the
application
of
controls
within
AirControlNET,
the
Agency's
tool
for
estimating
impacts
from
control
strategies
applied
to
non­
EGU
criteria
pollutant
sources.
AirControlNET
can
estimate
costs
and
emission
reductions
from
control
strategies
for
various
average
cost­
effectiveness
levels
and
for
varying
geographic
scales
(
nationally,
regionally,
locally).
2
For
this
analysis,
we
applied
in
AirControlNET
control
measures
up
to
the
given
average
annualized
cost
per
ton
cutoff
for
SO2
and
NOx
to
the
BART­
eligible
units
within
the
non­
EGU
dataset
described
in
Chapter
3.
These
analyses
are
calculated
for
control
measures
applied
to
the
2015
emissions
inventory
which
is
a
product
of
growing
the
emissions
from
the
non­
EGU
dataset,
a
database
with
2001emissions
in
it.
The
procedure
for
growing
the
emissions
in
that
database
to
2015
is
also
described
in
Chapter
3.

Costs
presented
in
this
chapter
are
estimated
at
a
7
percent
and
also
a
3
percent
interest
rate
for
purposes
of
annualization
of
capital
costs.
Incorporating
a
7
percent
interest
rate
is
consistent
with
OMB
Circular
A­
94,
issued
on
October
29,
1992.
The
use
of
a
3
percent
interest
rate
allows
for
a
comparison
of
the
costs
with
the
discount
rate
that
underlies
the
benefits
estimates
for
purposes
of
social
cost
and
benefit
comparison.
Equipment
lives
and
control
efficiencies
for
each
control
technology
are
taken
from
the
AirControlNET
control
measures
documentation
report.
Annual
costs
are
estimated
in
1999
dollars.
All
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
3
The
terms
"
ICI
boiler"
and
"
industrial
boiler"
are
used
interchangeably
in
this
RIA.

8­
3
costs
are
converted
from
the
original
source
year
to
1999
dollars
using
the
Gross
Domestic
Product
(
GDP)
price
deflator.

8.3
Types
of
Emissions
Control
Technologies
Employed
in
These
Analyses
These
are
a
number
of
technologies
commonly
employed
to
reduce
SO2
and
NOx
emissions
from
the
non­
EGU
source
categories.
This
section
of
the
chapter
covers
many
of
the
technologies
employed
in
reducing
these
pollutants.

8.3.1
SO2
Emissions
Control
Technologies
This
section
describes
available
technologies
for
controlling
emissions
of
SO2
for
industrial,
commercial
and
institutional
(
ICI)
boilers3
as
well
as
other
non­
EGU
source
categories.

In
general,
Flue
Gas
Desulfurization
(
FGD)
scrubbers
are
applied
most
commonly
as
the
control
technology
for
industrial
boilers
and
many
other
non­
EGU
sources
due
to
its
possible
application
to
most
any
industrial
boiler
and
other
combustion
source
application.
Other
issues
involved
in
choosing
a
control
technology
include
ease
of
retrofit
and
reduction
performance.
While
all
controls
presented
in
this
analysis
are
considered
generally
technically­
feasible
for
each
class
of
sources,
source­
specific
cases
may
exist
where
a
control
technology
is
in
fact
not
technically­
feasible.
In
their
response
to
the
BART
rule,
States
may
wish
to
consider
case­
specific
feasibility
when
establishing
control
requirements.

8.3.1.1
SO2
Control
Technology
for
Non­
EGU
Sources
For
industrial
boilers,
FGD
scrubbers
are
the
only
technology
available
in
our
data.
This
is
not
to
say
that
other
technologies
are
not
available
or
that
a
technique
such
as
switching
from
high­
sulfur
coal
(
e.
g.,
3
percent
sulfur
content
by
weight)
to
lower­
sulfur
coal
(
e.
g.,
1
percent
sulfur
content
by
weight)
could
not
employed
to
achieve
SO2
reductions,
but
data
for
such
technologies
or
technique
was
not
available
for
this
analysis.
FGD
scrubbers
are
also
used
on
units
at
petroleum
refineries,
kraft
pulp
mills,
and
portland
cement
kilns.
For
other
BART
source
categories,
there
are
other
types
of
control
technologies
available
that
are
more
specific
to
the
sources
controlled.
Table
8­
1
lists
these
technologies.
For
more
information
on
these
technologies,
please
refer
to
the
AirControlNET
4.0
control
measures
documentation
report.

Table
8­
1
Available
SO2
Control
Technologies
for
Industrial
Boilers
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
4
and
Other
Non­
EGU
Sources
Source
Type/
Fuel
Type
Available
Control
Technology
ICI
Boilers
­
All
Fuel
Types,
Kraft
Pulp
Mills,
Portland
Cement
Plants
(
All
Fuel
Types)
FGD
scrubbers
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Increase
%
Sulfur
Conversion
to
Meet
Sulfuric
Acid
NSPS
(
99.7%
reduction)

Sulfur
Recovery
Plants
Sulfur
Recovery
and/
or
Tail
Gas
Treatment
Coke
Oven
Batteries
Vacuum
Carbonate
+
Sulfur
Recovery
Plant
Source:
AirControlNET
control
measures
documentation
report.

8.3.2
NOx
Emissions
Control
Technologies
This
section
describes
available
technologies
for
controlling
emissions
of
NOx
for
industrial,
commercial
and
institutional
(
ICI)
boilers
as
well
as
other
non­
EGU
sources.

In
general,
low­
NOx
burners
(
LNB)
is
often
applied
as
a
control
technology
for
industrial
boilers
and
many
other
non­
EGU
sources
due
to
its
possible
application
to
almost
any
industrial
boiler
and
other
combustion
source
application.
Other
issues
involved
in
choosing
a
control
technology
include
ease
of
retrofit
and
reduction
performance.
While
all
controls
presented
in
this
analysis
are
considered
generally
technically­
feasible
for
each
class
of
sources,
source­
specific
cases
may
exist
where
a
control
technology
is
in
fact
not
technically­
feasible.
In
their
response
to
the
BART
rule,
States
may
wish
to
consider
casespecific
feasibility
when
establishing
control
requirements.

8.3.2.1
NOx
Control
Technology
for
Non­
EGU
Sources
There
are
several
types
of
control
technologies
considered
for
industrial
boilers:
selective
catalytic
reduction
(
SCR);
selective
non­
catalytic
reduction
(
SNCR);
natural
gas
reburn
(
NGR),
coal
reburn,
and
low­
NOx
burners.
As
stated
above,
the
control
technology
chosen
most
often
was
LNB
due
to
its
breadth
of
application.
In
some
cases,
LNB
accompanied
by
flue
gas
reburning
(
FGR)
is
applicable;
such
as
when
fuel­
borne
NOx
emissions
are
expected
to
be
of
greater
importance
than
thermal
NOx
emissions.
When
circumstances
suggest
that
combustion
controls
do
not
make
sense
as
a
control
technology
(
e.
g.,
sintering
processes,
coke
oven
batteries,
sulfur
recovery
plants)
SNCR
or
SCR
is
an
appropriate
choice.

Table
8­
2
lists
the
control
technologies
available
for
industrial
boilers
and
other
non­
EGU
sources
and
other
by
type
of
fuel.
For
more
information
on
these
technologies,
please
refer
to
the
AirControlNET
4.0
control
measures
documentation
report.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
5
Table
8­
2
Available
NOx
Control
Technologies
for
Industrial
Boilers
Source
Type/
Fuel
Type
Available
Control
Technology
ICI
Boilers
­
Coal/
Wall
SNCR,
LNB,
SCR
ICI
Boilers
­
Coal/
FBC(
fluidized
bed
combustor)
SNCR
­
Urea
Based
ICI
Boilers
­
Coal/
Stoker
SNCR
­
Urea
Based
ICI
Boilers
­
Coal/
Cyclone
SNCR,
Coal
Reburn,
NGR,
SCR
ICI
Boilers
­
Residual
Oil
LNB,
SNCR,
LNB
+
FGR,
SCR
ICI
Boilers
­
Distillate
Oil
LNB,
SNCR,
LNB
+
FGR,
SCR
ICI
Boilers
­
Natural
Gas
LNB,
SNCR,
LNB
+
FGR,
OT
+
WI,
SCR
ICI
Boilers
­
Process
Gas
LNB,
LNB
+
FGR,
OT
+
WI,
SCR
ICI
Boilers
­
Coke
SNCR,
LNB,
SCR
ICI
Boilers
­
LPG
(
liquid
petroleum
gas)
LNB,
SNCR,
LNB
+
FGR,
SCR
Source:
AirControlNET
control
measures
documentation
report.

8.3.2.2
NOx
Control
Technology
for
Other
Non­
EGU
BART
Source
Categories
Other
non­
EGU
source
categories
covered
in
the
analysis
include
petroleum
refineries,
kraft
pulp
mills,
and
cement
kilns
among
others.
NOx
control
technology
available
for
petroleum
refineries,
particularly
process
heaters
at
these
plants,
includes
LNB,
SNCR,
FGR,
and
SCR
along
with
combinations
of
these
technologies.
NOx
control
technology
available
for
kraft
pulp
mills
includes
those
available
to
industrial
boilers,
namely:
LNB,
SCR,
SNCR,
along
with
WI.
NOx
control
technology
available
for
cement
kilns
includes
those
available
to
industrial
boilers,
namely:
LNB,
SCR,
SNCR.
In
addition,
mid­
kiln
firing
(
MKF)
and
ammonia­
based
SNCR
can
be
utilized
on
cement
kilns
where
appropriate.
Table
8­
3
lists
the
control
technologies
available
for
these
categories.
For
more
information
on
these
technologies,
please
refer
to
the
AirControlNET
4.0
control
measures
documentation
report.

Table
8­
3
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
6
Available
NOx
Control
Technologies
for
Other
Non­
EGU
Source
Categories
Other
Than
Industrial
Boilers
Source
Type/
Fuel
Type
Available
Control
Technology
Petroleum
Refineries
(
Process
Heaters
­
Process
Gas,
Distillate
Oil)
LNB
+
FGR,
SNCR,
LNB
+
SNCR,
SCR,
LNB
+
SCR
Kraft
Pulp
Mills
LNB,
SNCR,
SCR,
LNB
+
SNCR,
SCR
+
WI
Cement
Manufacturing
­
Dry
MKF,
LNB,
SNCR
­
Urea
Based,
SNCR
­
Ammonia
Based,
SCR
Cement
Manufacturing
­
Wet
MKF,
LNB,
SCR,
Biosolid
Injection
In­
Process;
Bituiminous
Coal;
Cement
Kilns
SNCR
­
Urea
based
Chemical
Process
Plants
LNB,
SNCR,
SCR,
SCR
+
WI
Lime
Kilns
SCR
Iron
and
Steel
Mills
LNB,
SNCR,
LNB
+
SNCR,
LNB
+
FGR,
SCR
Source:
AirControlNET
control
measures
documentation
report.

8.4
Listing
of
Affected
Source
Categories
and
Results
For
Each
We
present
below
results
for
each
BART
source
category
impacted
in
the
analyses.
Results
presented
here
reflect
the
use
of
7
percent
and
3
percent
interest
rates
as
part
of
the
control
strategy
analysis
for
each
option.
There
are
no
impacts
for
8
of
the
25
non­
EGU
source
categories
because
there
are
no
control
measures
available
to
reduce
SO2
and
NOx
from
these
categories
within
AirControlNET.
There
are
seven
source
categories
for
which
only
NOx
reductions
take
place
in
these
analyses
due
to
there
being
no
control
measures
available
within
AirControlNET
or
no
controls
available
at
$
10,000/
ton
(
or
Option
3)
or
below.
Finally,
there
are
10
source
categories
for
which
both
SO2
and
NOx
reductions
take
place
in
these
analyses.
The
first
10
source
categories
for
which
impacts
are
presented
those
for
which
both
SO2
and
NOx
reductions
take
place
in
these
analyses.
These
BART
source
categories
are:


industrial
boilers
(
250
mmBTU/
hr
heat
input
capacity
and
greater)


petroleum
refineries

kraft
pulp
mills

portland
cement
plants

hydrofluoric,
sulfuric,
and
nitric
acid

chemical
process
plants
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
7

iron
and
steel
mills

coke
oven
batteries

sulfur
recovery
plants

primary
aluminum
ore
reductions
There
are
seven
source
categories
for
which
are
presented
are
those
in
which
only
NOx
reductions
take
place.
These
source
categories
are:


lime
kilns

glass
fiber
processing
plants

municipal
incinerators
(
250
tons
refuse
burn
capacity
or
greater)


coal
cleaning
plants
(
thermal
dryers)


carbon
black
plants
(
furnace
process)


phosphate
rock
processing
plants

secondary
metal
production
facilities
Finally,
there
are
eight
source
categories
for
which
there
are
no
impacts
estimated
because
there
are
no
BART­
eligible
units
in
the
non­
EGU
dataset
or
no
controls
available
to
reduce
emissions
from
BART­
eligible
units.
They
are:


primary
lead
smelters

primary
copper
smelters

primary
zinc
smelters

fuel
conversion
plants

sintering
plants

taconite
ore
processing
plants

petroleum
storage
and
transfer
facilities
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
8
8.4.1
Results
for
Industrial
Boilers
Table
8­
4
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
Besides
the
standard
BART
eligibility
criteria
mentioned
in
Chapter
3,
boilers
that
are
BART­
eligible
are
those
with
heat
input
design
capacities
of
250
mmBTU/
hr
or
greater
and
are
fossilfueled
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
8
to
48
percent
given
a
7
percent
interest
rate
for
the
costs,
and
from
16
to
49
percent
for
costs
at
a
3
percent
interest
rate.

Table
8­
4
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
Industrial
Boilersa
Illustrative
Regulatory
Optionsb
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
420,782
7%
388,569
32,213
420,782
3%
354,999
65,783
Option
2
420,782
7%
269,395
151,387
420,782
3%
256,344
164,438
Option
3
420,782
7%
220,474
200,308
420,782
3%
216,565
204,217
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
5
presents
the
NOx
baseline
emissions
and
reductions
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
32
percent
to
60
percent
for
costs
at
a
7
percent
interest
rate,
and
from
52
to
60
percent
for
costs
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
9
Table
8­
5
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
Industrial
Boilers
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
217,063
7%
149,738
67,325
217,063
3%
105,124
111,939
Option
2
217,063
7%
86,607
130,456
217,063
3%
86,639
130,424
Option
3
217,063
7%
86,541
130,522
217,063
3%
86,558
130,505
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
6
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
SO2
control.
The
annualized
control
costs
range
from
$
26
million
to
$
610
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
48
million
to
$
505
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
average
annualized
cost­
effectiveness
results
range
from
$
807
to
$
3,047
per
ton
with
costs
at
a
7
percent
rate
and
from
$
727
to
$
2,471
per
ton
with
costs
at
a
3
percent
rate.
In
addition,
the
marginal
costs
range
from
$
2,250
to
$
6,463
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
2,202
to
6,023
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
FGD
scrubbers
applied
to
all
of
these
units.
The
average
and
marginal
costs
rise
as
a
result
of
FGD
scrubbers
being
applied
to
more
coal­
fired
units
with
lower
sulfur
contents
and
to
oil­
fired
units
that
have
lower
sulfur
contents
than
coal­
fired
units.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
10
Table
8­
6
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Industrial
Boilers
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
26.0
$
807
­­­­­­­­­­­­­­­­­

3%
$
47.8
$
727
­­­­­­­­­­­­­­­­­

Option
2
7%
294.1
1,943
$
2,250
3%
265.0
1,612
2,202
Option
3
7%
610.3
3,047
$
6,463
3%
504.6
2,471
6,023
Table
8­
7
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
48.6
million
to
$
235.1
million
with
costs
at
a
7
percent
rate,
and
from
$
87.2
million
to
$
138.7
million
with
costs
at
a
3
percent
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
722
to
$
1,801
per
ton
with
costs
at
a
7
percent
rate,
and
from
$
779
to
$
1,063
per
ton
with
costs
at
a
3
percent
rate.
In
addition,
the
marginal
costs
range
from
$
2,929
to
$
24,242
per
ton
with
costs
at
a
7
percent
rate,
and
from
$
2,684
to
$
22,840
per
ton
with
costs
at
a
3
percent
rate.

The
average
and
marginal
costs
increase
as
the
options
become
more
stringent
due
to
additional
application
of
SCR.
SCR
is
the
most
expensive
NOx
control
device
available
to
industrial
boilers
in
our
analysis,
though
they
also
have
a
high
control
level
(
80
percent).
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
11
Table
8­
7
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
BART­
eligible
Industrial
Boilers
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
48.6
$
722
­­­­­­­­­­­­

3%
$
87.2
$
779
­­­­­­­­­­­

Option
2
7%
233.5
1,790
$
2,929
3%
136.8
1,049
2,684
Option
3
7%
235.1
1,801
24,242
3%
138.7
1,063
22,840
Table
8­
8
shows
the
total
annualized
costs
for
each
illustrative
regulatory
option
for
control
of
both
SO2
and
NOx.

Table
8­
8
2015
Cost
Results
for
SO2
and
NOx
Control
at
BART­
Eligible
Industrial
Boilers
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
74.6
3%
$
135.0
Option
2
7%
527.6
3%
401.8
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
12
Option
3
7%
845.4
3%
643.3
8.4.2
Results
for
Petroleum
Refineries
Table
8­
9
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
1
percent
to
28
percent
for
costs
estimated
at
a
7
percent
interest
rate,
and
from
9
percent
to
29
percent
for
costs
estimated
at
a
3
percent
interest
rate.

Table
8­
9
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineriesa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
199,483
7%
191,386
2,097
199,483
3%
182,450
17,033
Option
2
199,483
7%
168,164
31,319
199,483
3%
157,572
41,911
Option
3
199,483
7%
143,021
56,462
199,483
3%
140,958
58,525
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
10
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
5
to
59
percent
for
costs
estimated
at
a
7
percent
interest
rate,
and
from
6
to
60
percent
for
costs
estimated
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
13
Table
8­
10
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineriesa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
86,566
7%
82,531
4,035
3%
81,987
4,579
Option
2
86,566
7%
39,010
47,556
3%
35,307
51,259
Option
3
86,566
7%
35,250
51,316
3%
33,561
53,005
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled
Table
8­
11
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
from
$
1.9
million
to
$
223.5
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
12.5
million
to
$
167.3
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
906
to
$
3,958
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
736
to
$
2,858
per
ton
with
costs
at
a
3
percent
interest
rate
.
In
addition,
the
marginal
costs
range
from
$
1,783
to
$
6,741
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
2,417
to
$
5,692
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
FGD
scrubbers
applied
to
all
of
these
units.
The
average
and
marginal
costs
rise
as
a
result
of
FGD
scrubbers
being
applied
to
units
such
as
fluid
catalytic
cracking
units
(
FCCUs)
with
lower
sulfur
contents.
As
sulfur
content
of
the
fuel
for
a
units
decreases,
the
cost
per
ton
of
control
increases
and
vice
versa.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
14
Table
8­
11
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
1.9
$
906
­­­­­­­­­­­­

3%
$
12.5
$
736
­­­­­­­­­­­­

Option
2
7%
54.0
1,724
$
1,783
3%
72.7
1,734
2,417
Option
3
7%
223.5
3,958
6,741
3%
167.3
2,858
5,692
Table
8­
12
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
regulatory
option,
and
marginal
costs
between
each
option
for
NOx
control.
The
annualized
control
costs
range
from
$
2.3
million
to
$
205.1
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
2.7
million
to
$
227.6
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
costeffectiveness
results
range
from
$
570
to
$
3,997
per
ton
with
costs
at
7
percent
interest
rate,
and
from
$
595
to
$
4,294
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
range
from
$
2,917
to
$
20,984
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
2,986
to
$
48,969
per
ton
with
costs
at
a
3
percent
interest
rate.

The
average
and
marginal
costs
rise
as
a
result
of
additional
process
heaters
having
to
apply
LNB
+
SNCR.
In
most
cases,
the
average
cost
per
ton
of
control
is
between
$
4,000
and
$
5,000
per
ton.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
15
Table
8­
12
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
2.3
$
570
­­­­­­­­­­­­

3%
$
2.7
$
595
­­­­­­­­­­­­

Option
2
7%
126.2
2,654
$
2,917
3%
142.1
2,772
2,986
Option
3
7%
205.1
3,997
20,984
3%
227.6
4,294
48,969
Table
8­
13
shows
the
total
annualized
costs
for
control
of
both
SO2
and
NOx.

Table
8­
13
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
4.2
3%
$
15.3
Option
2
7%
180.2
3%
214.8
Option
3
7%
428.6
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
16
3%
394.8
8.4.3
Kraft
Pulp
Mills
Table
8­
14
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
24
percent
for
costs
at
a
7
percent
interest
rate,
and
from
0
to
12
percent
for
costs
at
a
3
percent
interest
rate.

Table
8­
14
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Kraft
Pulp
Millsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
119,818
7%
119,818
0
119,818
3%
119,818
0
Option
2
119,818
7%
109,005
10,814
119,818
3%
116,820
3,196
Option
3
119,818
7%
91,488
28,330
119,818
3%
105,208
14,610
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
15
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
34
percent
to
63
percent
for
costs
at
a
7
percent
interest
rate,
and
from
52
to
63
percent
for
costs
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
17
Table
8­
15
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Kraft
Pulp
Millsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
103,614
7%
68,365
35,249
103,614
3%
49,885
53,729
Option
2
103,614
7%
42,196
61,418
103,614
3%
37,822
65,792
Option
3
103,614
7%
37,838
65,776
103,614
3%
37,827
65,797
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
16
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
from
$
0
million
to
$
161.5
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
million
to
$
69.0
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
5,691
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
to
$
4,720
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
range
from
$
3,098
to
$
7,287
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
2,189
to
$
5,432
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
FGD
scrubbers
applied
to
all
of
these
units.
The
average
and
marginal
costs
rise
as
a
result
of
FGD
scrubbers
being
applied
to
units
for
which
the
application
is
more
expensive
($
6,000
to
$
10,000
per
ton).
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
18
Table
8­
16
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Kraft
Pulp
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
33.5
3,098
$
3,098
3%
7.0
2,189
2,189
Option
3
7%
161.5
5,691
7,287
3%
69.0
4,720
5,432
Table
8­
17
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
20.7
million
to
$
151.8
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
45.6
million
to
$
99.8
million
with
costs
at
a
3
percent
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
587
to
$
2,308
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
849
to
$
1,512
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
range
from
$
3,344
to
$
10,005
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
4,452
to
$
35,800
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
greater
applications
of
SCR
as
the
cost
per
ton
cap
rises,
particularly
for
sulfite
pulping
recovery
furnaces.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
19
Table
8­
17
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Kraft
Pulp
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Cost
($/
ton)

Option
1
7%
$
20.7
$
587
­­­­­­­­­­­­

3%
$
45.6
$
849
­­­­­­­­­­­­

Option
2
7%
108.2
1,762
$
3,344
3%
99.3
1,510
4,452
Option
3
7%
151.8
2,308
10,005
3%
99.5
1,512
35,800
Table
8­
18
shows
the
total
annualized
costs
of
each
illustrative
regulatory
option
for
control
of
both
SO2
and
NOx.

Table
8­
18
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Kraft
Pulp
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
AnnualizedCosts
(
million
1999$)

Option
1
7%
$
20.7
3%
$
45.6
Option
2
7%
141.7
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
20
3%
106.3
Option
3
7%
313.3
3%
168.5
8.4.4
Results
for
Portland
Cement
Plants
Table
8­
19
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
percent
to
23
percent
for
costs
at
a
7
percent
interest
rate,
and
from
0
to
26
percent
for
costs
at
a
3
percent
interest
rate.

Table
8­
19
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Portland
Cement
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
116,835
7%
116,835
0
116,835
3%
116,835
0
Option
2
116,835
7%
103,452
13,383
116,835
3%
98,509
18,326
Option
3
116,835
7%
90,119
26,716
116,835
3%
86,145
30,690
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
20
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
16
percent
to
60
percent
for
costs
at
a
7
percent
interest
rate,
and
from
26
to
60
percent
for
costs
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
21
Table
8­
20
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Portland
Cement
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
120,567
7%
101,289
19,276
120,567
3%
89,664
30,903
Option
2
120,567
7%
65,966
54,601
120,567
3%
48,646
71,921
Option
3
120,567
7%
48,646
71,921
120,567
3%
48,646
71,921
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
21
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
SO2
control.
The
annualized
control
costs
range
from
$
0
to
$
134.4
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
to
$
126.8
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
5,031
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
to
$
4,131
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
range
from
$
3,250
to
$
6,818
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
2,710
to
$
6,816
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
FGD
scrubbers
applied
to
all
of
these
units.
The
average
and
marginal
costs
rise
as
a
result
of
FGD
scrubbers
being
applied
to
more
units
with
lower
sulfur
content
fuels.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
22
Table
8­
21
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Portland
Cement
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
43.5
3,250
$
3,250
3%
49.7
2,710
2,710
Option
3
7%
134.4
5,031
6,818
3%
126.8
4,131
6,816
Table
8­
22
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
2.9
million
to
$
275.1
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
20.8
million
to
$
219.3
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
150
to
$
3,825
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
674
to
$
3,050
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
range
from
$
3,632
to
$
7,731
per
ton
with
costs
at
a
7
percent
interest
rate,
and
$
4,893
per
ton
with
costs
at
a
3
percent
interest
rate
between
the
$
1,000/
ton
and
the
$
4,000/
ton
option.
There
is
no
marginal
costs
between
the
$
4,000/
ton
and
$
10,000/
ton
options
with
costs
at
the
3
percent
interest
rate
since
there
is
no
difference
in
the
impacts
of
the
options.

The
average
and
marginal
costs
of
control
increase
as
more
SCR
applications
take
place
as
the
cost
per
ton
cap
rises.
These
applications
take
the
place
of
less
expensive
but
less
effective
controls
such
as
mid­
kiln
firing.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
23
Table
8­
22
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Portland
Cement
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Cost
($/
ton)

Option
1
7%
$
2.9
$
150
­­­­­­­­­­­­

3%
$
20.8
$
674
­­­­­­­­­­­­

Option
2
7%
131.2
2,403
$
3,632
3%
219.3
3,050
4,839
Option
3
7%
275.1
3,825
7,731
3%
219.3
3,050
N/
A
Table
8­
23
shows
the
total
annualized
costs
of
each
illustrative
regulatory
option
for
control
of
both
SO2
and
NOx.

Table
8­
23
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
PortlandCement
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
2.9
3%
$
20.8
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
24
Option
2
7%
174.8
3%
269.0
Option
3
7%
409.5
3%
346.1
8.3.5
Results
for
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Table
8­
24
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
35
to
38
percent
for
costs
at
a
7
percent
interest
rate,
and
the
same
for
costs
at
a
3
percent
interest
rate.

Table
8­
24
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
96,741
7%
62,601
34,140
96,741
3%
62,601
34,140
Option
2
96,741
7%
60,188
36,753
96,741
3%
60,188
36,753
Option
3
96,741
7%
60,188
36,753
96,741
3%
60,188
36,753
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
25
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
of
about
66%.
The
degree
of
impact
varies
little
between
regulatory
options
and
the
interest
rate
of
the
costs.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
25
Table
8­
25
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
17,059
7%
5,783
11,276
17,059
3%
5,783
11,276
Option
2
17,059
7%
5,776
11,283
17,059
3%
5,776
11,283
Option
3
17,059
7%
5,776
11,283
17,059
3%
5,776
11,283
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
26
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
from
$
9.8
million
to
$
15.2
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
9.1
million
to
$
14.1
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
287
to
$
413
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
268
to
$
385
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
are
$
2,067
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,914
per
ton
with
costs
at
a
3
percent
interest
rate.
In
this
case,
there
are
no
controls
between
$
4,000/
ton
and
$
10,000/
ton,
thus
there
are
no
marginal
costs
between
these
two
options.

The
costs
and
emission
reductions
are
flat
between
the
options
because
there
is
only
one
control
technique
available
to
reduce
SO2
emissions
from
these
sources
­
increase
sulfur
conversion
to
meet
the
sulfuric
acid
NSPS
(
99.7
percent
control).
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
26
Table
8­
26
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
9.8
$
287
­­­­­­­­­­­­

3%
$
9.1
$
268
­­­­­­­­­­­­

Option
2
7%
15.2
413
$
2,067
3%
14.1
385
1,914
Option
3
7%
15.2
413
N/
A
3%
14.1
385
N/
A
Table
8­
27
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
8.19
to
$
8.21
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
7.29
to
$
7.30
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
726
to
$
728
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
646
to
$
647
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
are
$
2,067/
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,914/
ton
with
costs
at
a
3
percent
interest
rate.
In
this
case,
there
are
no
controls
between
$
4,000/
ton
and
$
10,000/
ton,
thus
there
are
no
marginal
costs
between
these
two
options.

The
costs
and
emission
reductions
are
flat
between
the
options
because
there
is
only
one
control
technique
available
to
reduce
NOx
emissions
from
these
sources
­
SNCR
applied
to
nitric
acid
manufacturing
sources.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
27
Table
8­
27
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
8.2
$
726
­­­­­­­­­­­­

3%
$
7.3
$
646
­­­­­­­­­­­­

Option
2
7%
8.2
728
$
4,428
3%
7.3
647
2,157
Option
3
7%
8.2
728
N/
A
3%
7.3
647
N/
A
Table
8­
28
shows
the
total
annualized
costs
of
each
illustrative
regulatory
option
for
control
of
both
SO2
and
NOx.

Table
8­
28
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
18.0
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
28
3%
$
16.4
Option
2
7%
23.4
3%
21.4
Option
3
7%
23.4
3%
21.4
8.4.6
Results
for
Chemical
Process
Plants
Table
8­
29
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illlustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
percent
to
7
percent
for
costs
at
either
a
7
or
a
3
percent
interest
rate.

Table
8­
29
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Chemical
Process
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
47,700
7%
47,700
0
47,700
3%
47,700
0
Option
2
47,700
7%
45,324
2,376
47,700
3%
45,324
2,376
Option
3
47,700
7%
44,129
3,571
47,700
3%
44,129
3,571
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
30
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
33
percent
to
48
percent
for
costs
at
a
7
percent
interest
rate,
and
from
37
to
48
percent
for
costs
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
29
Table
8­
30
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Chemical
Process
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
72,577
7%
48,607
23,970
72,577
3%
45,435
27,142
Option
2
72,577
7%
37,941
34,636
72,577
3%
37,776
34,801
Option
3
72,577
7%
37,776
34,801
72,577
3%
37,385
35,192
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
31
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
SO2
control.
The
annualized
control
costs
range
from
$
0
to
$
13.7
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
to
$
10.2
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
3,836
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
0
to
$
2,850
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
range
from
$
1,052
to
$
9,372/
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
1,013
to
$
6,527
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
a
major
difference
in
the
impacts
between
the
two
available
control
techniques:
increase
sulfur
percent
conversion
to
meet
the
sulfuric
acid
NSPS
(
99.7
percent
control)
and
FGD
scrubbers.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
30
Table
8­
31
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Chemical
Process
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
2.5
1,052
$
1,052
3%
2.4
1,013
1,013
Option
3
7%
13.7
3,836
9,372
3%
10.2
2,850
6,527
Table
8­
32
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
14.4
million
to
$
74.1
million
with
costs
at
a
7
percent
interest
rate,
and
from
$
21.1
million
to
$
77.1
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
601
to
$
2,129
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
776
to
$
2,191
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
of
the
options
ranges
from
$
5,030
to
$
35,758
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
4,348
to
$
58,082
per
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
the
application
of
many
different
types
of
NOx
controls.
The
reason
for
the
large
increase
in
marginal
costs
associated
with
the
$
10,000/
ton
option
is
the
applications
of
LNB
+
SNCR
or
SCR
that
would
take
place
at
units
within
these
plants
according
to
our
analysis.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
31
Table
8­
32
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Chemical
Process
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
14.4
$
601
­­­­­­­­­­­­

3%
$
21.1
$
776
­­­­­­­­­­­­

Option
2
7%
68.2
1,969
$
5,030
3%
54.4
1,563
4,348
Option
3
7%
74.1
2,129
35,758
3%
77.1
2,191
58,082
Table
8­
33
shows
the
total
annualized
costs
of
each
illustrative
regulatory
option
for
control
of
both
SO2
and
NOx.
Table
8­
33
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Chemical
Process
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
32
Option
1
7%
$
14.4
3%
$
21.1
Option
2
7%
70.8
3%
56.8
Option
3
7%
87.8
3%
87.3
8.4.7
Results
for
Iron
and
Steel
Mills
Table
8­
34
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
12
percent
for
costs
at
either
a
7
or
3
percent
interest
rate.

Table
8­
34
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Millsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
23,541
7%
23,541
0
23,541
3%
23,541
0
Option
2
23,541
7%
20,627
2,914
23,541
3%
20,627
2,914
Option
3
23,541
7%
20,627
2,914
23,541
3%
20,627
2,914
aThe
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
35
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
5
to
41
percent
at
costs
of
either
7
or
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
33
Table
8­
35
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Millsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
20,963
7%
19,927
1,036
20,963
3%
19,927
1,036
Option
2
20,963
7%
13,966
6,997
20,963
3%
12,463
8,500
Option
3
20,963
7%
12,456
8,507
20,963
3%
12,290
8,673
aThe
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
36
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
SO2
control.
The
annualized
control
costs
range
from
$
0
million
to
$
5.3
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
3.4
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
1,819
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
1,165
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
are
$
1,819/
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,165
/
ton
with
costs
at
a
3
percent
interest
rate.
In
this
case,
there
are
no
controls
between
$
4,000/
ton
and
$
10,000/
ton,
thus
there
are
no
marginal
costs
between
these
two
options.

The
costs
and
emission
reductions
are
flat
between
the
options
because
the
two
controls
available
both
have
similar
average
cost
per
ton
estimates
below
$
4,000­
sulfuric
acid
plant
and
increase
sulfur
conversion
to
meet
the
sulfuric
acid
NSPS
(
99.7
percent
control).
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
34
Table
8­
36
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
5.3
1,819
1,819
3%
3.4
1,165
1,165
Option
3
7%
5.3
1,819
N/
A
3%
3.4
1,165
N/
A
Table
8­
37
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
regulatory
option,
and
marginal
costs
between
each
illustrative
regulatory
option
for
NOx
control.
The
annualized
control
costs
range
from
$
0.6
million
to
$
27.9
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.4
million
to
$
29.0
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
579
to
$
3,280
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
431
to
$
3,343
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
range
from
$
2,953
to
$
6,424/
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
2,532
to
$
56,052/
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
a
rise
in
the
costs
of
control
due
to
additional
applications
of
LNB
+
either
SNCR
or
SCR.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
35
Table
8­
37
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.6
$
579
­­­­­­­­­­­­

3%
$
0.4
$
431
­­­­­­­­­­­

Option
2
7%
18.2
2,601
$
2,953
3%
19.3
2,271
2,532
Option
3
7%
27.9
3,280
6,424
3%
29.0
3,343
56,052
Table
8­
38
shows
the
total
annualized
costs
for
control
of
both
SO2
and
NOx.

Table
8­
38
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Mills
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
36
Option
1
7%
$
0.6
3%
$
0.4
Option
2
7%
23.5
3%
22.7
Option
3
7%
33.2
3%
32.4
8.4.8
Results
for
Coke
Oven
Batteries
Table
8­
39
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
62
percent
for
costs
at
a
7
percent
interest
rate,
and
from
0
to
57
percent
for
costs
at
a
3
percent
interest
rate.

Table
8­
39
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Coke
Oven
Batteries
Ilustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
9,815
7%
9,815
0
9,815
3%
9,815
0
Option
2
9,815
7%
5,727
4,088
9,815
3%
6,091
3,724
Option
3
9,815
7%
3,708
6,107
9,815
3%
4,251
5,564
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
40
shows
the
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option
for
NOx
control.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
56
percent
for
costs
at
a
7
or
3
percent
interest
rate.

Table
8­
40
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Coke
Oven
Batteriesa
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
37
Illustrative
Regulatory
Option
2015
Baseline
Emissions
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
10,389
10,389
0
10,389
10,389
0
Option
2
10,389
4,621
5,768
10,389
4,621
5,768
Option
3
10,389
4,621
5,768
10,389
4,621
5,768
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
41
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
from
$
0
million
to
$
21.3
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0
million
to
$
14.1
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
3,488
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
2,529
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
range
from
$
1,517
to
$
7,479/
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
1,074/
ton
to
$
5,489/
ton
with
costs
at
a
3
percent
interest
rate.

The
costs
and
emission
reductions
reflect
application
of
only
one
control
­
vacuum
carbonate
plus
a
sulfur
recovery
plant
but
also
differing
SO2
emissions
levels
at
the
affected
coke
oven
batteries.

Table
8­
41
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Coke
Oven
Batteries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1990$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
38
Option
2
7%
6.2
1,517
$
1,517
3%
4.0
1,074
1,074
Option
3
7%
21.3
3,488
7,479
3%
14.1
2,529
5,489
Table
8­
42
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
regulatory
option,
and
marginal
costs
between
each
option
for
NOx
control.
The
annualized
control
costs
range
from
$
0
million
to
$
12.5
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
10.9
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
0
to
$
2,167
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
1,898
per
ton
with
costs
at
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
are
$
2,167
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,898
per
ton
at
a
3
percent
interest
rate.
In
this
case,
there
are
no
controls
available
between
$
4,000/
ton
and
$
10,000/
ton,
thus
there
are
no
marginal
costs
between
these
two
options.

The
costs
and
emission
reductions
are
flat
between
the
options
because
there
is
only
one
NOx
control
available
for
these
sources
­
SNCR.

Table
8­
42
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Coke
Oven
Batteries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­

Option
2
7%
12.5
2,167
$
2,167
3%
10.9
1,898
1,898
Option
3
7%
12.5
2,167
N/
A
3%
10.9
1,898
N/
A
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
39
Table
8­
43
shows
the
total
annualized
costs
for
control
of
both
SO2
and
NOx.

Table
8­
43
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Coke
Oven
Batteries
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
0.0
3%
$
0.0
Option
2
7%
18.7
3%
14.9
Option
3
7%
33.8
3%
25.0
8.4.9
Results
for
Sulfur
Recovery
Plants
Table
8­
44
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
of
23
percent
for
costs
at
a
7
or
a
3
percent
interest
rate.
The
emission
reductions
are
the
same
for
each
option
because
of
the
few
controls
available
between
$
1,000
and
$
10,000
per
ton
average
cost.

Table
8­
44
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Sulfur
Recovery
Plantsa
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
40
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
59,766
7%
46,069
13,697
59,766
3%
46,073
13,693
Option
2
59,766
7%
46,069
13,697
59,766
3%
46,073
13,693
Option
3
59,766
7%
46,069
13,697
59,766
3%
46,073
13,693
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled
Table
8­
45
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
21
to
22
percent
for
costs
at
a
7
or
a
3
percent
interest
rate.
For
this
source
category,
the
reductions
vary
little
between
options
due
to
the
limited
number
of
emission
controls
between
$
1,000
and
$
10,000
per
ton.

Table
8­
45
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Sulfur
Recovery
Plantsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
651
7%
516
135
651
3%
516
135
Option
2
651
7%
510
141
651
3%
510
141
Option
3
651
7%
510
141
651
3%
510
141
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
41
Table
8­
46
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
are
$
11.6
million
with
costs
at
a
7
or
a
3
percent
interest
rate
.
The
accompanying
annualized
average
cost­
effectiveness
results
are
$
847
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
849
per
ton
with
costs
at
a
3
percent
interest
rate,
and
the
marginal
costs
are
$
847
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
849
per
ton
at
a
3
percent
interest
rate.
There
are
no
available
controls
between
$
4,000/
ton
and
$
10,000/
ton,
so
there
are
no
other
marginal
costs.

The
costs
and
emission
reductions
are
flat
between
the
options
because
there
is
only
one
control
technique
available
to
reduce
SO2
emissions
from
these
sources
­
sulfur
recovery
and/
or
tail
gas
treatment.

Table
8­
46
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Sulfur
Recovery
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
11.6
$
847
­­­­­­­­­­­­

3%
$
11.6
$
849
­­­­­­­­­­­­

Option
2
7%
11.6
847
$
847
3%
11.6
849
849
Option
3
7%
11.6
847
N/
A
3%
11.6
849
N/
A
Table
8­
47
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
NOx
control.
The
annualized
control
costs
range
from
$
0.07
million
to
$
0.52
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.05
million
to
$
0.47
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
519
to
$
3,652
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
400
to
$
3,315
per
ton
with
costs
a
3
percent
interest
rate.
In
addition,
the
marginal
costs
are
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
42
$
74,167/
ton
with
costs
at
a
7
percent
interest
rate
and
$
68,833/
ton
with
costs
at
a
3
percent
interest
rate.
There
are
no
available
controls
between
$
4,000/
ton
and
$
10,000/
ton,
so
there
are
no
other
marginal
costs.

The
average
and
marginal
costs
rise
between
the
options
due
to
applications
of
SCR,
a
high
cost/
ton
control
for
this
type
of
source.

Table
8­
47
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Sulfur
Recovery
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.1
$
519
­­­­­­­­­­­­

3%
$
0.1
$
400
­­­­­­­­­­­­

Option
2
7%
0.5
3,652
$
74,167
3%
0.5
3,315
68,833
Option
3
7%
0.5
3,652
N/
A
3%
0.5
3,315
N/
A
Table
8­
48
shows
the
total
annualized
costs
for
control
of
both
SO2
and
NOx.

Table
8­
48
2015
Cost
Results
for
SO2
and
NOx
Control
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
43
at
non­
EGU
BART­
Eligible
Units
at
Sulfur
Recovery
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
11.7
3%
$
11.7
Option
2
7%
12.1
3%
12.1
Option
3
7%
12.1
3%
12.1
8.4.10
Results
for
Primary
Aluminum
Ore
Reduction
Plants
Table
8­
49
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
3
to
7
percent
for
costs
at
a
7
or
3
percent
interest
rate.

Table
8­
49
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Primary
Aluminum
Ore
Reduction
Plantsa
Illustrative
Regulatory
Option
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
47,552
7%
45,922
1,630
47,552
3%
45,922
1,630
Option
2
47,552
7%
44,292
3,260
47,552
3%
44,292
3,260
Option
3
47,552
7%
44,292
3,260
47,552
3%
44,292
3,260
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
50
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
3
to
15
percent
with
costs
at
a
7
or
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
44
Table
8­
50
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Primary
Aluminum
Ore
Reduction
Plantsa
Illustrative
Regulatory
Option
2015
Baseline
Emissions
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
1,676
1,626
50
1,676
1,626
50
Option
2
1,676
1,423
253
1,676
1,421
255
Option
3
1,676
1,421
255
1,676
1,421
255
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
51
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
illustrative
regulatory
option,
and
marginal
costs
between
each
option
for
SO2
control.
The
annualized
control
costs
range
from
$
1.6
million
to
$
7.2
million
with
costs
at
a
7
percent
interest
rate
and
from
$
1.0
million
to
$
4.5
million
with
costs
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
costeffectiveness
results
range
from
$
982
to
$
2,209
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
590
to
$
1,383
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
are
$
3,436
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,383
per
ton
with
costs
at
a
3
percent
interest
rate.
There
are
no
available
controls
between
$
4,000/
ton
and
$
10,000/
ton,
so
there
are
no
other
marginal
costs.

The
costs
and
emission
reductions
are
flat
between
the
options
because
there
is
only
one
control
technique
available
to
reduce
SO2
emissions
from
these
sources
­
a
sulfuric
acid
plant.

Table
8­
51
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Primary
Aluminum
Ore
Reduction
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

$
1,000/
ton
7%
$
1.6
$
982
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
45
3%
$
1.0
$
590
­­­­­­­­­­­­

$
4,000/
ton
7%
7.2
2,209
$
3,436
3%
4.5
1,383
1,383
$
10,000/
ton
7%
7.2
2,209
N/
A
3%
4.5
1,383
N/
A
Table
8­
52
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
for
each
regulatory
option,
and
marginal
costs
between
each
option
for
NOx
control.
The
annualized
control
costs
range
from
$
0.04
million
to
$
0.7
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.04
to
$
0.4
million
with
cost
at
a
3
percent
interest
rate.
The
accompanying
annualized
average
cost­
effectiveness
results
range
from
$
740
to
$
2,639
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
509
to
$
1,764
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
range
from
$
2,823
to
$
30,500
per
ton
with
costs
at
a
7
percent
interest
rate.
With
costs
at
a
3
percent
interest
rate,
the
marginal
costs
are
$
1,764
per
ton
between
the
$
1,000/
ton
and
$
4,000/
ton
options,
but
there
is
no
marginal
cost
between
the
$
4,000/
ton
and
$
10,000/
ton
options
since
the
impacts
are
the
same.

The
costs
and
NOx
emission
reductions
reflect
LNB
applications
also
with
LNB
+
SNCR
in
a
very
few
cases.
It
is
the
application
of
LNB
+
SNCR
that
leads
to
the
high
marginal
cost
for
the
$
10,000/
ton
option
at
the
7
percent
interest
rate.

Table
8­
52
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Primary
Aluminum
Ore
Reduction
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
740
­­­­­­­­­­­­­­

3%
$
0.0
$
509
­­­­­­­­­­­­­­

Option
2
7%
0.6
2,411
$
2,823
3%
0.4
1,764
1,764
Option
3
7%
0.7
2,639
30,500
3%
0.4
1,764
N/
A
Table
8­
53
shows
the
total
annualized
costs
for
control
of
both
SO2
and
NOx.

Table
8­
53
2015
Cost
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Primary
Aluminum
Ore
Reduction
Plants
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
46
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)

Option
1
7%
$
1.7
3%
$
1.0
Option
2
7%
7.8
3%
5.0
Option
3
7%
7.8a
3%
5.0
a
The
annual
costs
for
Option
3
are
actually
$
61,000
higher
than
for
Option
2.

The
next
seven
BART
source
categories
only
have
NOx
controls
applied
to
their
affected
units.
This
is
because
there
are
no
SO2
emissions
from
BART­
eligible
units
in
these
source
categories
that
can
be
controlled
at
under
$
10,000/
ton
(
1999$).
Hence,
all
the
reductions
and
costs
for
the
remaining
source
categories
are
only
for
NOx,
not
SO2.

8.4.11
Results
for
Lime
Kilns
Table
8­
54
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
21
to
56
percent
for
costs
at
a
7
or
3
percent
interest
rate.

Table
8­
54
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Lime
Kilns
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
12,849
7%
10,166
2,683
12,849
3%
8,378
4,471
Option
2
12,849
7%
8,378
4,471
12,849
3%
5,696
7,153
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
47
Option
3
12,849
7%
5,696
7,153
12,849
3%
5,696
7,153
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
this
source
category,
both
controlled
and
uncontrolled.

Table
8­
55
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
2
million
to
$
31.8
million
with
costs
at
a
7
percent
interest
rate
and
$
4.3
million
to
$
25.4
million
with
costs
at
a
3
percent
interest
rate..
The
annualized
average
cost
effectiveness
ranges
from
$
745
to
$
4,446
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
to
$
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
are
$
1,678/
ton
for
reaching
the
$
4,000/
ton
option
and
are
$
9,993/
ton
between
the
$
4,000/
ton
and
$
10,000/
ton
options
with
costs
at
a
7
percent
interest
rate.
The
marginal
costs
are
$
8,858/
ton
for
reaching
the
$
4,000/
ton
option,
and
there
are
no
marginal
costs
for
reaching
the
$
10,000/
ton
option
from
the
$
4,000/
ton
option
since
the
impacts
are
the
same.
These
impacts
reflect
applications
of
LNB
at
$
1,000/
ton,
SNCR
at
$
4,000/
ton,
and
SCR
at
$
10,000/
ton.

Table
8­
55
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Lime
Kilns
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
2.0
$
745
­­­­­­­­

3%
$
4.3
$
953
­­­­­­­­­

Option
2
7%
5.0
$
1,118
$
1,678
3%
25.4
$
3,552
8,858
Option
3
7%
31.8
4,446
9,993
3%
25.4
3,552
N/
A
8.4.12
Results
for
Glass
Fiber
Processing
Plants
Table
8­
56
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
options.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
9
to
33
percent
for
costs
at
a
7
percent
interest
rate
and
from
12
to
33
percent
for
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
48
costs
at
a
3
percent
interest
rate.

Table
8­
56
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Units
at
Glass
Fiber
Processing
Plants
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
6,677
7%
6,109
568
6,677
3%
5,902
775
Option
2
6,677
7%
4,561
2,116
6,677
3%
4,561
2,116
Option
3
6,677
7%
4,479
2,198
6,677
3%
4,479
2,198
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
sources
in
this
source
category,
both
controlled
and
uncontrolled.

Table
8­
57
shows
the
annualized
cost,
resulting
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0.5
million
to
$
7.8
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.7
million
to
$
6.8
million
with
costs
at
a
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
ranges
from
$
937
to
$
3,549
per
ton
with
costs
at
a
7
percent
interest
rate,
and
from
$
880
to
$
3,108
per
ton
with
costs
at
a
3
percent
interest
rate.
Marginal
costs
are
$
3,101/
ton
for
reaching
the
$
4,000/
ton
option
and
$
30,488/
ton
between
the
$
4,000/
ton
and
$
10,000/
ton
options
with
costs
at
a
7
percent
interest
rate,
and
$
3,057/
ton
for
reaching
the
$
4,000/
ton
option
and
$
25,402/
ton
between
the
$
4,000/
ton
and
$
10,000/
ton
options
with
costs
at
a
3
percent
interest
rate.
The
impacts
reflect
application
of
LNB
at
$
1,000/
ton
and
$
4,000/
ton,
and
then
oxygen­
firing
under
the
$
10,000/
ton
option.

Table
8­
57
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Units
at
Glass
Fiber
Processing
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.5
$
937
­­­­­­­­­­­­­

3%
$
0.7
$
880
­­­­­­­­­

Option
2
7%
5.3
2,505
3,101
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
49
3%
4.8
2,244
3,057
Option
3
7%
7.8
3,549
30,488
3%
6.8
3,108
25,402
8.4.13
Results
for
Municipal
Incinerators
The
analysis
of
municipal
incinerators
(
>
250
tons
per
day
burn
refuse
capacity)
shows
the
results
for
each
illustrative
regulatory
option.
Table
8­
58
shows
the
NOx
emissions
reductions
achieved
in
the
analysis
for
each
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
45
percent
for
costs
at
a
7
or
3
percent
interest
rate.

Table
8­
58
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Municipal
Incineratorsa
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
1,656
7%
1,656
0
1,656
3%
1,656
0
Option
2
1,656
7%
912
744
1,656
3%
912
744
Option
3
1,656
7%
912
744
1,656
3%
912
744
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
sources
in
this
source
category,
both
controlled
and
uncontrolled.

Table
8­
59
shows
the
annualized
costs,
annualized
average
cost­
effectiveness,
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0
to
$
1.1
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
0.9
million
with
costs
at
a
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
is
$
1,478
per
ton
with
costs
at
a
7
percent
interest
rate
and
is
$
1,207
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
are
$
1,478/
ton
for
reaching
the
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
50
$
4,000/
ton
option
with
costs
at
the
7
percent
interest
rate
and
$
1,207/
ton
at
the
3
percent
interest
rate.
Since
there
are
no
other
controls
between
$
4,000/
ton
and
$
10,000/
ton,
there
are
no
additional
reductions
and
hence
no
marginal
costs
between
these
two
options.
The
only
available
control
measure
for
this
source
is
SNCR.
Table
8­
59
2007
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Municipal
Incinerators
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­

3%
$
0.0
$
0
Option
2
7%
1.1
1,478
1,478
3%
0.9
1,207
1,207
Option
3
7%
1.1
1,478
N/
A
3%
0.9
1,207
N/
A
8.4.14
Results
for
Coal
Cleaning
Plants
Table
8­
60
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
46
percent
for
costs
at
a
7
or
a
3
percent
interest
rate.

Table
8­
60
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Units
at
Coal
Cleaning
Plants
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
1,110
7%
1,110
0
1,110
3%
1,110
0
Option
2
1,110
7%
599
511
1,110
3%
599
511
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
51
Option
3
1,110
7%
599
511
1,110
3%
599
511
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
sources
in
this
source
category,
both
controlled
and
uncontrolled.

Table
8­
61
shows
the
annualized
costs,
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0
to
$
1
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
0.8
million
with
costs
at
a
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
is
$
1,900
per
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,534
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
are
$
1,900/
ton
for
reaching
the
$
4,000/
ton
option
with
costs
at
a
7
percent
interest
rate
and
$
1,534/
ton
with
costs
at
a
3
percent
interest
rate.
Since
there
are
no
other
controls
between
$
4,000/
ton
and
$
10,000/
ton,
there
are
no
additional
reductions
and
hence
no
marginal
costs
between
these
two
options.
Controls
available
to
these
sources
are
LNB
and
SNCR.

Table
8­
61
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Units
at
Coal
Cleaning
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­

Option
2
7%
1.0
1,900
1,900
3%
0.8
1,534
1,534
Option
3
7%
1.0
1,900
N/
A
3%
0.8
1,534
N/
A
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
52
8.4.15
Results
for
Carbon
Black
Plants
Table
8­
62
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
options
from
the
2015
baseline
ranging
from
0.2
to
2
percent
for
costs
at
a
7
or
a
3
percent
interest
rate.

Table
8­
59
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Units
at
Carbon
Black
Plants
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
4,645
7%
4,638
7
4,645
3%
4,638
7
Option
2
4,645
7%
4,525
120
4,645
3%
4,525
120
Option
3
4,645
7%
4,525
120
4,645
3%
4,525
120
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
sources
in
this
source
category,
both
controlled
and
uncontrolled
Table
8­
63
shows
the
annualized
cost,
resulting
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0.1
million
to$
0.2
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.006
million
to
$
0.15
million
with
costs
at
a
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
ranges
from
$
957
to
$
1,608
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
830
to
$
1,237
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
between
the
$
1,000/
ton
and
the
$
4,000/
ton
option
are
$
1,646/
ton
with
costs
at
a
7
percent
interest
rate
and
$
1,237/
ton
with
costs
at
a
3
percent
interest
rate.
Since
there
are
no
other
controls
between
$
4,000/
ton
and
$
10,000/
ton,
there
are
no
additional
reductions
and
hence
no
marginal
costs
between
these
two
options.
NOx
controls
available
to
these
sources
are
SNCR
and
SCR
and
the
cost
per
ton
for
these
controls
is
fairly
similar
for
these
sources
in
this
analysis.

Table
8­
63
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Units
at
Carbon
Black
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
53
Option
1
7%
$
0.1
$
957
­­­­­­­­­­

3%
$
0.0
$
830
­­­­­­­­­­

Option
2
7%
0.2
1,608
1,646
3%
0.1
1,237
1,237
Option
3
7%
0.2
1,608
N/
A
3%
0.1
1,237
N/
A
8.4.16
Results
for
Phosphate
Rock
Processing
Plants
Table
8­
64
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
option.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
0
to
7
percent
for
costs
at
either
7
or
3
percent
interest
rate.

Table
8­
64
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Units
at
Phosphate
Rock
Processing
Plants
Illustrative
Regulatory
Options
2015
Baseline
Emissions
2015
Post­
Control
Emissions
2015
Emission
Reductions
Option
1
719
719
0
719
719
0
Option
2
719
674
45
719
671
48
Option
3
719
671
48
719
671
48
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
sources
in
this
source
category,
both
controlled
and
uncontrolled
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
54
Table
8­
65
shows
the
annualized
cost,
resulting
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0
to
$
0.2
million
with
costs
at
a
7
or
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
ranges
from
$
1,978
to
$
4,646
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
0
to
$
3,221
per
ton
with
costs
at
a
3
percent
interest
rate.
The
marginal
costs
between
the
$
1,000/
ton
and
the
$
4,000/
ton
option
are
$
1,978/
ton
while
the
marginal
costs
between
the
$
4,000/
ton
and
the
$
10,000/
ton
options
are
$
44,667/
ton
with
costs
at
a
7
percent
interest
rate.
With
costs
at
a
3
percent
interest
rate,
the
marginal
costs
between
the
$
1,000/
ton
and
the
$
4,000/
ton
option
are
$
3,221/
ton,
and
there
is
no
marginal
cost
between
the
$
4,000/
ton
and
the
$
10,000/
ton
option
since
the
impacts
are
the
same
for
each
option.
The
only
available
NOx
control
for
this
source
is
LNB
+
SNCR.

Table
8­
65
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Units
at
Phosphate
Rock
Processing
Plants
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
0.1
1,978
1,978
3%
0.2
3,221
3,221
Option
3
7%
0.2
4,646
44,667
3%
0.2
3,221
N/
A
8.4.17
Results
for
Secondary
Metal
Production
Facilities
Table
8­
66
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
options.
The
table
indicates
that
the
options
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
2
to
3
percent
for
costs
at
either
a
7
or
3
percent
interest
rate.

Table
8­
66
2015
NOx
Emission
Reductions
(
in
tons)
for
BART­
eligible
Units
at
Secondary
Metal
Production
Facilities
Illustrative
Regulatory
Options
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
55
Option
1
1,377
7%
1,352
25
1,377
3%
1,352
25
Option
2
1,377
7%
1,343
34
1,377
3%
1,342
35
Option
3
1,377
7%
1,342
35
1,377
3%
1,342
35
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
this
source
category,
both
controlled
and
uncontrolled.

Table
8­
67
shows
the
annualized
cost,
resulting
annualized
average
cost­
effectiveness
and
marginal
costs
for
each
illustrative
regulatory
option.
The
total
annualized
costs
for
these
options
ranges
from
$
0.01
million
to
$
0.12
million
with
costs
at
a
7
percent
interest
rate
and
from
$
0.01
to
$
0.04
million
with
costs
at
a
3
percent
interest
rate.
The
annualized
average
cost
effectiveness
ranges
from
$
760
to
$
1,800
per
ton
with
costs
at
a
7
percent
interest
rate
and
from
$
511
to
$
1,247
per
ton
with
costs
at
a
3
percent
interest
rate.
With
costs
at
a
7
percent
interest
rate,
the
marginal
costs
between
the
$
1,000/
ton
and
the
$
4,000/
ton
options
are
$
2,000/
ton
and
$
9,000/
ton
between
the
$
4,000/
ton
and
the
$
10,000/
ton
options.
With
costs
at
a
3
percent
interest
rate,
the
marginal
costs
between
the
$
1,000/
ton
and
the
$
4,000/
ton
options
are
$
3,100/
ton
and
there
are
no
marginal
costs
between
the
$
4,000/
ton
and
the
$
10,000/
ton
options
since
the
impacts
are
the
same.
Available
NOx
controls
are
LNB
and
the
more
expensive
LNB
+
SNCR.

Table
8­
67
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Units
at
Secondary
Metal
Processing
Facilities
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Cost
($/
ton)

Option
1
7%
$
0.0
$
760
­­­­­­­­­­

3%
$
0.0
$
511
­­­­­­­­­­

Option
2
7%
0.0
1,088
2,000
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
56
3%
0.0
1,247
3,100
Option
3
7%
0.1
1,800
9,000
3%
0.0
1,247
N/
A
8.5
Summary
of
Results
for
Non­
Electricity
Generating
Sources
Below
are
several
summary
tables
in
which
the
emission
reductions
and
costs
for
the
3
non­
EGU
illustrative
regulatory
options
applied
are
shown
by
source
category
and
also
by
the
interest
rate
for
the
annualized
costs.
Table
8­
68
summarizes
the
SO2
emission
reductions
for
the
analyses
to
the
BART
non­
EGU
source
categories
using
an
interest
rate
of
7
percent
and
also
showing
results
using
an
interest
rate
of
3
percent.
In
total,
the
3
options
applied
in
this
analysis
lead
to
nationwide
SO2
emission
reductions
ranging
from
83,778
tons
to
378,169
tons
with
costs
at
a
7
percent
interest
rate.
These
options
lead
to
SO2
emission
reductions
ranging
from
132,280
to
373,798
tons
with
costs
at
a
3
percent
rate.
These
represent
a
reduction
of
11
to
30
percent
from
the
2015
baseline.
For
Option
2,
the
SO2
emission
reduction
estimate
is
269,992
tons
or
a
22
percent
reduction
from
the
2015
baseline
with
costs
at
a
7
percent
interest
rate,
and
290,591
tons
or
a
24
percent
reduction
from
the
2015
baseline
with
costs
at
a
3
percent
interest
rate.

Table
8­
69
summarizes
the
NOx
emission
reductions.
The
nationwide
NOx
emission
reductions
from
applying
these
3
illustrative
regulatory
options
range
from
165,634
tons
to
391,101
tons
with
costs
at
a
7
percent
interest
rate.
These
represent
a
reduction
of
24
to
57
percent
from
the
2015
baseline.
These
options
lead
to
NOx
emission
reductions
ranging
from
246,067
to
393,349
tons
with
costs
at
a
3
percent
rate.
These
represent
a
reduction
of
36
to
58
percent
from
the
2015
baseline.
For
Option
2,
the
NOx
emission
reduction
estimate
is
361,152
tons
or
a
53
percent
reduction
from
the
2015
baseline
with
costs
at
a
7
percent
interest
rate,
and
390,871
tons
or
a
57
percent
reduction
from
the
2015
baseline
with
costs
at
a
3
percent
interest
rate.

Table
8­
70
summarizes
the
annualized
costs
associated
with
the
3
non­
EGU
illustrative
regulatory
options.
In
total,
the
3
options
applied
in
this
analysis
have
annualized
costs
of
$
151.43
million
to
$
2,237.24
million
(
1999$)
with
costs
at
a
7
percent
interest
rate
and
$
272.34
million
to
$
1,770.27
million
(
1999$)
with
costs
at
a
3
percent
interest
rate.
The
capital
costs
for
these
3
illustrative
regulatory
options
range
from
$
655.70
million
to
$
14.75
billion
for
costs
estimated
at
a
7
percent
interest
rate
and
from
$
1,881.70
million
to
$
12.73
billion
for
costs
estimated
at
a
3
percent
interest
rate.
More
detailed
capital
cost
information
for
these
illustrative
options
can
be
found
in
Appendix
B.
In
addition,
sensitivity
analyses
that
provide
capital
cost
estimates
in
which
a
10
percent
rate
for
annualizing
costs
are
shown
along
with
variation
in
labor
and
energy
rates
in
that
Appendix.
Finally,
information
on
the
number
of
affected
BARTeligible
units
by
option,
pollutant,
and
source
category
are
available
in
Appendix
B.

Given
the
highly
capital
intensive
nature
of
the
control
measures
included
in
these
analyses,
it
is
not
unreasonable
that
a
lower
interest
rate
would
lead
to
more
application
of
these
measures
to
reduce
SO2
and
NOx
and
vice
versa.
More
sources
would
be
controlled
that
may
not
be
able
to
control
if
they
face
relatively
high
interest
rates
for
capital
outlays
in
pollution
control
equipment.
At
Option
1,
the
annualized
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
57
costs
and
emission
reductions
are
higher
with
a
3
percent
interest
rate
than
a
7
percent
interest
rate
since
the
lower
interest
rate
leads
to
more
sources
having
available
controls
under
that
option.
At
Option
2,
the
annualized
costs
and
reductions
are
relatively
close
since
the
controls
available
to
sources
are
about
the
same.
At
Option
3,
the
available
controls
are
about
identical
regardless
of
the
interest
rate,
but
the
costs
are
lower
for
the
3
percent
interest
rate
due
to
the
lower
capital
costs
overall.

Table
8­
68
SO2
Emissions
and
Emission
Reductions
for
BART
Source
Categories
in
2015
BART
Source
Category
Baseline
Emissions
(
tons)
Interest
Rate
Illustrative
Regulatory
Options
­
Reductions
(
tons)

Option
1
Option
2
Option
3
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
58
Industrial
Boilers
420,782
7%
32,213
151,387
200,308
420,782
3%
65,783
164,438
204,217
Petroleum
Refineries
199,483
7%
2,097
31,319
56,462
199,483
3%
17,033
41,911
58,525
Kraft
Pulp
Mills
119,818
7%
0
10,814
28,380
119,818
3%
0
3,196
14,610
Portland
Cement
Plants
116,835
7%
0
13,383
26,716
116,835
3%
0
18,326
30,690
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
96,741
7%
34,140
36,753
36,753
96,741
3%
34,140
36,753
36,753
Chemical
Process
Plants
47,700
7%
0
2,376
3,571
47,700
3%
0
2,376
3,571
Iron
and
Steel
Mills
23,541
7%
0
2,914
2,914
23,541
3%
0
2,914
2,914
Coke
Oven
Batteries
9,815
7%
0
4,088
6,107
9,815
3%
0
3,724
5,564
Sulfur
Recovery
Plants
59,766
7%
13,697
13,697
13,697
59,766
3%
13,693
13,693
13,693
Draft
BART
RIA
Chapter
­
4/
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05
­
Deliberative
8­
59
Primary
Aluminum
Ore
Reduction
Plants
47,552
7%
1,630
3,260
3,260
47,552
3%
1,630
3,260
3,260
Lime
Kilns
9,373
7%
0
0
0
9,373
3%
0
0
0
Glass
Fiber
Processing
Plants
2,170
7%
0
0
0
2,170
3%
0
0
0
Municipal
Incinerators
284
7%
0
0
0
284
3%
0
0
0
Coal
Cleaning
Plants
1,530
7%
0
0
0
1,530
3%
0
0
0
Carbon
Black
Plants
41,853
7%
0
0
0
41,853
3%
0
0
0
Phosphate
Rock
Processing
Plants
21
7%
0
0
0
21
3%
0
0
0
Secondary
Metal
Production
Facilities
9,988
7%
0
0
0
9,988
3%
0
0
0
TOTALS:
1,208,088
7%
83,778
236,992
378,169
1,208,088
3%
132,279
290,591
373,797
Draft
BART
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Chapter
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­
Deliberative
8­
60
Table
8­
69
NOx
Emissions
and
Emission
Reductions
for
BART
Source
Categories
in
2015
BART
Source
Category
Baseline
Emissions
(
tons)
Interest
Rate
Illustrative
Regulatory
Options
Option
1
Option
2
Option
3
Draft
BART
RIA
Chapter
­
4/
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­
Deliberative
8­
61
Industrial
Boilers
217,063
7%
67,325
130,456
130,522
217,063
3%
111,939
130,424
130,505
Petroleum
Refineries
86,566
7%
4,035
47,556
51,316
86,566
3%
4,579
51,259
53,005
Kraft
Pulp
Mills
103,614
7%
35,249
61,418
65,776
103,614
3%
53,729
65,792
65,797
Portland
Cement
Plants
120,567
7%
19,276
54,601
71,921
120,567
3%
30,903
71,921
71,921
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
17,059
7%
11,276
11,283
11,283
17,059
3%
11,276
11,283
11,283
Chemical
Process
Plants
72,577
7%
23,970
34,636
34,801
72,577
3%
27,142
34,801
34,801
Iron
and
Steel
Mills
20,963
7%
1,036
6,997
8,507
20,963
3%
1,036
8,500
8,673
Coke
Oven
Batteries
10,389
7%
0
5,768
5,768
10,389
3%
0
5,768
5,768
Sulfur
Recovery
Plants
651
7%
135
141
141
651
3%
135
141
141
Draft
BART
RIA
Chapter
­
4/
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Deliberative
8­
62
Primary
Aluminum
Ore
Reduction
Plants
1,676
7%
50
253
255
1,676
3%
50
253
255
Lime
Kilns
12,849
7%
2,683
4,471
7,153
12,849
3%
4,471
7,153
7,153
Glass
Fiber
Processing
Plants
6,677
7%
568
2,116
2,198
6,677
3%
775
2,116
2,198
Municipal
Incinerators
1,656
7%
0
744
744
1,656
3%
0
744
744
Coal
Cleaning
Plants
1,110
7%
0
511
511
1,110
3%
0
511
511
Carbon
Black
Plants
4,645
7%
7
120
120
4,645
3%
7
120
120
Phosphate
Rock
Processing
Plants
719
7%
0
45
48
719
3%
0
48
48
Secondary
Metal
Production
Facilities
1,377
7%
25
34
35
1,377
3%
25
34
35
TOTALS:
681,765
7%
165,634
361,152
391,101
Draft
BART
RIA
Chapter
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63
681,765
3%
246,067
390,871
393,349
Table
8­
70
Total
Annualized
Costs
of
Control
for
BART
Source
Categories
in
2015
(
million
1999$)

BART
Source
Category
Interest
Rate
Illustrative
Regulatory
Options
Option
1
Option
2
Option
3
Draft
BART
RIA
Chapter
­
4/
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Deliberative
8­
64
Industrial
Boilers
7%
$
74.6
527.6
845.4
3%
135.0
401.8
643.3
Petroleum
Refineries
7%
4.2
180.2
428.6
3%
15.3
214.8
394.8
Kraft
Pulp
Mills
7%
20.7
141.7
313.3
3%
45.6
106.3
168.5
Portland
Cement
Plants
7%
2.9
174.8
409.5
3%
20.8
269.0
346.1
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
7%
18.0
23.4
23.4
3%
16.4
21.4
21.4
Chemical
Process
Plants
7%
14.4
70.8
87.8
3%
21.1
54.4
77.1
Iron
and
Steel
Mills
7%
0.6
23.5
33.2
3%
0.4
22.7
32.4
Coke
Oven
Batteries
7%
0.0
18.7
33.8
3%
0.0
14.9
25.0
Sulfur
Recovery
Plants
7%
11.7
12.1
12.1
3%
11.7
12.1
12.1
Draft
BART
RIA
Chapter
­
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Deliberative
8­
65
Primary
Aluminum
Ore
Reduction
Plants
7%
1.7
7.76
7.82
3%
1.0
5.0
5.0
Lime
Kilns
7%
2.0
5.0
31.8
3%
4.3
25.4
25.4
Glass
Fiber
Processing
Plants
7%
0.5
5.3
7.8
3%
0.7
4.8
6.8
Municipal
Incinerators
7%
0.0
1.1
1.1
3%
0.0
0.9
0.9
Coal
Cleaning
Plants
7%
0.0
1.0
1.0
3%
0.0
0.8
0.8
Carbon
Black
Plants
7%
0.01
0.2
0.2
3%
0.005
0.1
0.1
Phosphate
Rock
Processing
Plants
7%
0.0
0.1
0.2
3%
0.0
0.2
0.2
Secondary
Metal
Production
Facilities
7%
0.02
0.04
0.1
3%
0.0
0.0
0.0
TOTALS:
7%
$
151.43
$
1,193.24
$
2,237.24
3%
$
272.34
$
1,157.09
$
1,770.21
Draft
BART
RIA
Chapter
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66
8.6
Caveats
and
Limitations
of
the
Analyses
There
are
a
number
of
caveats
and
limitations
associated
with
these
analyses.
They
are:


The
technologies
applied
in
these
analyses
do
not
reflect
emerging
control
devices
that
could
be
available
in
future
years
to
meet
any
BART
requirements
in
SIPs
or
upgrades
to
current
devices
that
may
serve
to
increase
control
levels.
For
example,
there
is
increasing
use
of
SCR/
SNCR
hybrid
technologies
that
can
serve
to
lower
the
expected
capital
cost
and
lead
to
NOx
control
at
high
levels
(
90%).


Fuel
switching
is
not
considered
as
a
way
for
BART­
eligible
units,
especially
industrial
boilers,
to
meet
potential
BART
requirements
in
SIPs.
Fuel
switching
can
consist
of
coalfired
sources
switching
from
high
to
low­
sulfur
coals
(
e.
g.,
Powder
River
Basin
coals).
This
technique
has
been
used
by
many
power
plants
to
meet
SO2
requirements
imposed
by
the
Acid
Rain
Program
and
by
various
regulations,
but
has
been
less
used
by
industrial
sources.


There
is
a
considerable
range
of
equipment
lives
for
the
control
devices
applied
in
these
analyses.
For
example,
the
equipment
life
for
SCR
can
range
from
10
to
40
years.
We
chose
a
middle
point
from
this
range
to
use
in
these
analyses.
To
the
extent
that
we
underestimate
the
actual
equipment
life
from
use
of
these
devices,
we
overestimate
the
annual
costs
of
these
controls
and
vice
versa.


Labor
and
energy
rates
and
other
parameters
to
the
cost
estimates
are
estimated
based
on
nationwide
rates
instead
of
regional
and
local
rates.
Using
nationwide
parameter
estimates
introduces
some
uncertainty
in
these
estimates
at
a
source­
specific
level.


The
emission
reductions
and
controls
that
will
be
imposed
on
petroleum
refineries
as
a
result
of
various
New
Source
Review
settlements
are
not
included
in
our
regulatory
baseline.
Thus,
this
analysis
is
likely
to
overestimate
costs
of
BART
compliance
to
many
BART­
eligible
units
at
petroleum
refineries.


As
noted
above
in
Section
8.4,
there
are
a
large
number
of
non­
EGU
BART
source
categories
for
which
no
SO2
or
NOx
controls
exist.
There
are
no
impacts
for
8
of
the
25
non­
EGU
source
categories
because
there
are
no
control
measures
available
to
reduce
SO2
and
NOx
from
these
categories
within
AirControlNET
or
any
other
documentation
that
has
been
found
in
the
course
of
completing
this
analysis.
There
are
seven
source
categories
for
which
only
NOx
reductions
take
place
in
these
analyses
due
to
there
being
no
control
measures
available
within
AirControlNET
or
no
controls
available
at
$
10,000/
ton
or
below.
Finally,
there
are
a
total
10
source
categories
for
which
both
SO2
and
NOx
reductions
take
place
in
these
analyses.


Control
programs
implemented
as
command­
and­
control
regulation,
as
this
analysis
models
controls
to
affected
non­
EGU
sources,
will
lead
to
less
induced
technological
innovation
Draft
BART
RIA
Chapter
­
4/
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05
­
Deliberative
8­
67
when
compared
to
a
market
incentives­
based
approach
(
e.
g.,
a
cap­
and­
trade
program).


There
are
some
unquantified
costs
that
EPA
wants
to
identify
as
limits
to
its
analysis.
These
costs
include
the
costs
of
State
administration
of
the
program,
which
we
believe
are
modest.
There
also
may
be
unquantified
costs
of
transitioning
to
BART,
such
as
the
costs
associated
with
the
possible
retirement
of
smaller
or
less
efficient
non­
EGU
units,
and
employment
shifts
as
workers
are
retrained
at
the
same
company
or
re­
employed
elsewhere
in
the
economy.


Recent
research
suggests
that
the
total
social
costs
of
a
new
regulation
may
be
affected
by
interactions
between
the
new
regulation
and
pre­
existing
distortions
in
the
economy,
such
as
taxes.
In
particular,
if
cost
increases
due
to
a
regulation
are
reflected
in
a
general
increase
in
the
price
level,
the
real
wage
received
by
workers
may
be
reduced,
leading
to
a
small
fall
in
the
total
amount
of
labor
supplied.
This
"
tax
interaction
effect"
may
result
in
an
increase
in
deadweight
loss
in
the
labor
market
and
an
increase
in
total
social
costs.
Although
there
is
a
good
case
for
the
existence
of
the
tax
interaction
effect,
recent
research
also
argues
for
caution
in
making
prior
assumptions
about
its
magnitude.
However,
there
are
currently
no
government­
wide
economic
analytical
guidelines
which
discuss
the
tax
interaction
effect
and
its
potential
relevance
for
estimation
of
federal
program
costs
and
benefits.
The
limited
empirical
data
available
to
support
quantification
of
any
such
effect
leads
to
this
qualitative
identification
of
the
costs.

8.7
References
E.
H.
Pechan
and
Associates.
AirControlNET
Version
4.0
Control
Measure
Documentation
Report.
Prepared
for
the
U.
S.
Environmental
Protection
Agency.
March
2005.

E.
H.
Pechan
and
Associates.
BART
Non­
EGU
Control
Strategy
Analysis
Technical
Support
Document.
Prepared
for
the
U.
S.
Environmental
Protection
Agency.
April
2005.

U.
S.
Office
of
Management
and
Budget.
Circular
A­
4.
"
New
Guidelines
for
the
Conduct
of
Regulatory
Analysis."
September
17,
2003.
Found
on
the
Internet
at
http://
www.
whitehouse.
gov/
omb/
circulars/
a004/
a­
4.
html.

U.
S.
Office
of
Management
and
Budget.
Circular
A­
94.
"
Guidelines
and
Discount
Rates
for
Benefit­
Cost
Analysis
of
Federal
Programs."
October
29,
1992.
Found
on
the
Internet
at
http://
www.
whitehouse.
gov/
omb/
circulars/
a094/
a094.
html.
