WordPerfect
Document
Compare
Summary
Original
document:
E:\
OLD
D
DRIVE\
Saved\
PM\
BARTnonEGUchapterimpactsRIA.
wpd
Revised
document:
E:\
OLD
D
DRIVE\
Saved\
PM\
nonEGUBARTchapterRIAfinalpril12.
wpd
Deletions
are
shown
with
the
following
attributes
and
color:
Strikeout,
Blue
RGB(
0,0,255).
Deleted
text
is
shown
as
full
text.
Insertions
are
shown
with
the
following
attributes
and
color:
Double
Underline,
Redline,
Red
RGB(
255,0,0).

The
document
was
marked
with
804
Deletions,
857
Insertions,
0
Moves.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
2
Chapter
8.
RESULTS
OF
COST,
EMISSIONS
REDUCTIONS,
AND
ECONOMIC
IMPACT
ANALYSES
FOR
NON­
ELECTRICITY
GENERATING
UNITS
This
chapter
presents
the
results
of
the
cost
and
economic
impact
analyses
for
the
non­
EGU
sources
in
BART
source
categories
covered
in
these
analyses.
The
cost
and
economic
impact
analyses
(
including
potential
impacts
to
small
entities
and
public
sector
entities)
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
the
average
costeffectiveness
of
controls
applied
for
these
sourcesa
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
8.2
presents
the
marginal
cost­
effectiveness4
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
alternatives
analyzed.
Section
8.3
describes
the
potential
economic
impacts
of
the
preferred
option
and
selected
other
options,
and
Section
8.4
analyzes
the
potential
impacts
on
small
entities
in
particular.
The
economic
impact
sections
focus
on
detailed
results
for
the
medium
strigency
option
and
provides
a
brief
comparison
with
the
range
of
results
for
other
options
considered.
cost
analyses.
More
detailed
results
for
the
other
options
considered
are
provided
in
the
economic
impacttechnical
support
document
for
these
analysies
report
(
RTI(
E.
H.
Pechan,
2005).)
Finally,
references
for
the
chapter
are
provided
in
Section
8.57.

8.1
Results
in
Brief
The
results
for
applying
the
alternativesoptions
examined
for
control
of
2015
SO2SO2
and
NoOx
emissions
at
non­
EGU
BART­
eligible
units
range
from
83,778
tons
to
378,169
tons
of
SO2
toSO2
and
165,634
tons
to
391,101
tons
of
NOx
nationwide.
Annual
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$).

8.2
Compliance
Costs
and
Cost­
Effectiveness
In
this
RIA,
three
regulatory
alternatives
are
analyzed
for
non­
EGU
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
1
Analysis
of
sources
in
the
trading
program
consider
trading
occuring
across
the
entire
SIP
call
region.
Analysis
of
non­
EGU
sources
considers
at
the
source­
level
the
application
of
controls
at
the
source
category
level
up
to
a
specified
average
cost
per
ton
cutoff.

8­
3
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
annualannualized
cost
per
ton
alternativesoptions
for
reducing
SO2SO2
and
NoOx
at
varying
levels
of
stringency:
$
1,000,
$
4,000,
and
$
10,000.1
The
$
1,000/
ton
alternative
is
called
the
"
low""
least
stringency
alternativet"
option,
the
$
4,000/
ton
alternative
is
the
"
medium"
stringency
alternativet"
option,
and
the
$
10,000/
ton
alternative
is
the
"
high""
most
stringency
onet"
option.
These
alternativesoptions
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
have
two
elements:
implementation
(
the
cost
of
emissions
control),
and
administration
(
the
cost
of
monitoring
emissions,
and
the
associated
administrative
costs
ofestimated
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.)
The
calculation
of
administration
costs
is
presented
later
in
Section
8­_
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
compliance
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
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.

3
The
terms
"
ICI
boiler"
and
"
industrial
boiler"
are
used
interchangeably
in
this
RIA.

8­
4
geographic
scales
(
nationally,
regionally,
locally).
2
For
this
analysis,
we
applied
in
AirControlNET
applied
control
measures
up
to
the
given
average
annualized
cost
per
ton
cutoff
for
SO2SO2
and
NoOx
to
the
BART­
eligible
units
within
the
non­
EGU
dataset
described
in
Chapter
3.
These
analyses
are
calculated
for
control
measures
applied
to
2015
emissions.

Presented
below
are
results
for
eachthe
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
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
5
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
category
impacted
in
the
analysescategories,
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
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
case­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
6
specific
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.

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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
7
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
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
SO2SO2
and
NoOx
from
these
categories
within
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
8
AirControlNET.

8.1There
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

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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
9

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
8.4.1
Results
for
Industrial
Boilers
Table
8­
14
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
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
and
are
fossil
­
fueled.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
1
2015
SO28
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
10
Illustrative
Regulatory
AlternativebOpti
onsb
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
tonOption
1
420,782
7%
388,569
32,213
$
4,000/
ton
420,782
3%
354,999
65,783
Option
2
420,782
7%
269,395
151,387
$
10,000/
ton
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.

Table
8­
25
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
Industrial
Boilersa
Illustrative
Regulatory
AlternativebOpti
ons
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
11
$
1,000/
tonOption
1
217,063
7%
149,738
67,325
$
4,000/
ton
217,063
3%
105,124
111,939
Option
2
217,063
7%
86,607
130,456
$
10,000/
ton
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
36
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeillustrative
regulatory
option
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million$
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
$
1,243$
807
to
$
23,140
per
ton.

Table
8­
3047
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
12
Table
8­
6
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Industrial
Boilers
Illustrative
Regulatory
AlternativeO
ptions
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrativ
e
Costs
(
million
1999$)
Interes
t
Rate
Total
AnnualAnnualized
Costs
(
million
1999$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAn
nualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Costs
($/
ton)

Option
1
7%
$
26.0
$
807
­­­­­­­­­­­­­­­­­­­­­­­­­­­­­

3%
$
4,000/
ton$
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
$
106,000/
ton023
Table
8­
47
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
illustrative
regulatory
alternative3option,
and
marginal
costs
between
each
alternative.

Table
8­
4illustrative
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
13
analysis,
though
they
also
have
a
high
control
level
(
80
percent).

Table
8­
7
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
BART­
eligible
Industrial
Boilers
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1990$)
Annu
al
Monitoring
and
Administrati
ve
Costs
(
million
1990$)
Intere
st
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAn
nualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMargi
nal
Costs
($/
ton)

Option
1
7%
$
86.9$
48.6
$
12.4$
99.3$
1,203$
722
­­­­­­­­­­­­

$
4,000/
ton
3%
$
87.2
$
779
­­­­­­­­­­­

Option
2
867%
233.95
1,790
$
2,929
3%
136.31
00.28
1,213049
2,684
Option
3
7%
$
10,000/
ton87235.1
11,801
24,242
3.3%
10038.47
1,215063
22,840
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
14
Table
8­
58
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative4,
and
marginal
costs
between
each
alternativeannualized
costs
for
each
illustrative
regulatory
option
for
control
of
both
SO2SO2
and
NOx.

Table
8­
58
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
and
NoOx
Control
at
BART­
Eligible
Industrial
Boilers
Illustrative
Regulatory
AlternativeOptions
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Interest
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)

Annual
Cost
Effectiveness
($/
ton)
Option
1
Marginal
Cost
Effectiveness
($/
ton)
7%
$
74.6
3%
$
1,000/
ton35.0
Option
2
$
86.97%
527.6
3%
401.8
$
12Option
3
7%
845.4
$
99.
3%
$
1,203­­­­­­­­­­­­
$
4,000/
ton86.91
3643.3
100.21,213$
10,000/
ton87.113.3100.41,215
8.14.2
Results
for
Petroleum
Refineries
Table
8­
69
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
6
2015
SO21
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
15
Table
8­
9
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineriesa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
tonOption
1
388,56932,213199,
483
$
4,000/
ton269,3957
%
1591,387386
2,097
$
10,000/
ton220
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,
474200,308
Table
8­
7
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.

Table
8­
10
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineriesa
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
16
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
ton217,0631
49,73867,325$
4,00
0/
ton217,063Optio
n
1
86,607566
7%
82,531
4,035
3%
81,987
4,579
Option
2
86,566
7%
39,010
47,556
3%
35,307
13051,456259
$
10,000/
ton217,063
Option
3
86,541566
7%
35,250
51,316
3%
33,561
130,52253,005
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
811
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
illustrative
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeoption
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million$
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
$
1,243$
906
to
$
2,140
per
ton.

Table
8­
8$
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
17
Table
8­
11
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
AlternativeOpti
ons
Annual
Control
Cost
(
million
1999$)
An
nual
Monitorin
g
and
Administr
ative
Costs
(
million
1990$)
Inte
rest
Rate
Total
AnnualAnnualiz
ed
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
Margin
alAnnualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Costs
($/
ton)

Option
1
7%
$
1.9
$
906
­­­­­­­­­­­­

$
4,000/
ton
3%
$
10,000/
ton$
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
912
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
regulatory
alternative5option,
and
marginal
costs
between
each
alternative.

Table
8­
9option
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
cost­
effectiveness
results
range
from
$
570
to
$
3,997
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
18
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.

Table
8­
12
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrativ
e
Costs
(
million
1990$)
Interest
Rate
Total
AnnualAnnua
lized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAnnualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMargin
al
Costs
($/
ton)

Option
1
7%
$
86.9$
12$
2.4$
99.3
$
1,203570
­­­­­­­­­­­­

$
4,000/
ton
3%
$
2.7
$
595
­­­­­­­­­­­­

Option
2
86.97%
13.31
00126.2
1,2132,654
$
2,917
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
19
$
10,000/
ton873
%
142.1
13.2,
772
2,986
Option
3
100.47%
205.1
3,997
20,984
1
3%
227.6
4,21594
48,969
Table
8­
103
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative6,
and
marginal
costs
between
each
alternativeannualized
costs
for
control
of
both
SO2SO2
and
NOx.

Table
8­
103
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Petroleum
Refineries
Illustrative
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Options
Interest
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)

Annual
Cost
Effectiveness
($/
ton)
Option
1
Marginal
Cost
Effectiveness
($/
ton)
7%
$
4.2
3%
$
1,000/
ton$
86.9$
12.4$
99$
15.3
$
1,203­­­­­­­­­­­­
$
4,000/
tonOptio
n
2
86.97%
13.31
00180.2
1,213
3%
214.8
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
20
Option
3
7%
$
10,000/
ton87428.11
3.31
00.41
,2156
3%
394.8
8.14.3
Kraft
Pulp
Mills
Table
8­
114
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

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
114
2015
SO2SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Kraft
Pulp
Millsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
21
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
12
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Kraft
Pulp
Millsa
Option
1
119,818
7%
119,818
0
119,818
3%
119,818
0
Option
2
Regulatory
Alternativeb119,818
Number
of
Affected
Sources7%
2015
Baseline
Emissions109,005
10,814
119,818
3%
116,820
3,196
2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
t
on217,063149,738
Option
3
119,818
677%
91,488
28,325330
119,818
3%
105,208
$
414,000/
ton217,06
386,607130,456$
10
,000/
ton217,06386,
541130,522610
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
135
shows
the
annual
costs
,
resulting
average
annual
cost­
effectiveness
for
each
regulatory
alternative,
and
marginal
costs
between
each
alternative
for
SO2
control.
The
annual
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.
The
accompanying
average
cost­
effectiveness
results
range
from
$
1,243
to
$
2,140
per
ton.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
22
Table
8­
13
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Kraft
Pulp
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton­­­­­­­­­­­­$
4,000/
ton$
10,000/
ton
Table
8­
14
shows
the
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative7,
and
marginal
costs
between
each
alternative.

Table
8­
14
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Kraft
Pulp
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­
$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
15
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative8,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.

Table
8­
15
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Kraft
Pulp
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
23
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­
$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
8.1.3
Results
for
Portland
Cement
Plants
Table
8­
16
shows
theNOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
16
2015
SO234
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.

Table
8­
15
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Portland
Cement
PlantsaKraft
Pulp
Millsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
24
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
17
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Portland
Cement
Plantsa
Regulatory
AlternativebNumber
of
Affected
Sources2015
Baseline
Emissions2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
t
on217,063149Optio
n
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%
37,738838
6765,776
103,614
3%
37,325$
4,000/
ton21
7,06386,607827
13065,456$
10,000/
t
on217,06386,54113
0,522797
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
25
Table
8­
316
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
illustrative
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeoption
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.$
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
$
1,243
to
$
2,140
per
ton.

Table
8­
18$
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).

Table
8­
16
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Portland
Cement
PlantsKraft
Pulp
Mills
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
26
Illustrative
Regulatory
AlternativeO
ptions
Annual
Control
Cost
(
million
1999$)
Ann
ual
Monitoring
and
Administra
tive
Costs
(
million
1990$)
Inter
est
Rate
Total
AnnualAnnuali
zed
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
Margin
alAnnualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

$
4
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
4,000/
ton720
5,432
$
10,000/
ton
Table
8­
197
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
illustrative
regulatory
alternative9option,
and
marginal
costs
between
each
alternative.

Table
8­
19illustrative
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
27
Table
8­
17
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Portland
Cement
PlantsKraft
Pulp
Mills
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1990$)
Annu
al
Monitoring
and
Administrati
ve
Costs
(
million
1990$)
Intere
st
Rate
Total
AnnualAnnual
ized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAnnual
ized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Cost
($/
ton)

Option
1
7%
$
8620.97
$
12.4$
99.3$
1,203$
587
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
28
$
4,000/
ton86
.913.3100.21
,213$
10,000/
ton87.113.31
00.41,215
Table
8­
5
shows
the
total
annual
costs,
resulting
annual
average
costeffectiveness
for
each
regulatory
alternative10,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.

Table
8­
20
2015
Cost
and
Cost­
Effectivenes
s
Results
for
SO2
and
NOx
Control
at
non­
EGU
BARTEligible
Units
at
Portland
Cement
Plants
Regulatory
Alternative
Annual
Control
Cost
3%
$
45.6
$
86.49
$
12.4$
99.3$
1,203­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
29
$
4,000/
tonO
ption
2
86.913.37%
1008.2
1,213762
$
3,344
3%
99.3
1,510
$
104,452
Option
3
7%
151.8
2,308
10,000/
ton005
87
3%
99.11
3.31
00.45
1,215512
35,800
The
analysis
of
cement
manufacturing
operations
is
conducted
by
selecting
the
most
cost­
effective
control
measure
available
for
each
identified
source
that
does
not
exceed
the
cost­
effectiveness
cut­
off
specified
in
the
regulatory
alternative.
Table
7­
5
shows
the
emissions
reductions
achieved
in
the
analysis
for
each
regulatory
alternative.
The
table
indicates
that
all
the
alternatives
achieve
the
same
incremental
reductions
from
the
controlled
2015
baseline.
This
reduction
is
approximately
38%.

Table
8­
21
shows
theTable
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
3%
106.3
Option
3
7%
313.3
3%
168.5
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
30
8.4.4
Results
for
Portland
Cement
Plants
Table
8­
19
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
21
2015
SO2
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BART­
Eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plantsa
Regulatory
AlternativebNumber
of
Affected
Sources2015
Baseline
Emissions2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
ton388,56932,213$
4,000/
ton269,395151,387$
10,000/
ton220,474200,308
Table
8­
22
2015
NOx0
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
Hydrofluoric,
Sulfuric,
and
Nitric
AcidPortland
Cement
Plantsa
Illustrative
Regulatory
AlternativebNumb
er
of
Affected
SourcesOptions
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
tonOption
1
116,835
7%
116,835
0
217116,835
3%
116,835
0
Option
2
116,835
7%
103,063452
13,383
116,835
3%
98,509
18,326
Option
3
149116,835
7%
90,119
26,73867,325716
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
31
116,835
$
4,000/
ton217,0633
%
86,607145
13030,456$
10,000/
t
on217,06386,54113
0,522690
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
3
shows
the
annual
costs
,
resulting
average
annual
cost­
effectiveness
for
each
regulatory
alternative,
and
marginal
costs
between
each
alternative
for
SO2
control.
The
annual
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.
The
accompanying
average
cost­
effectiveness
results
range
from
$
1,243
to
$
2,140
per
ton.

Table
8­
23
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton­­­­­­­­­­­­$
4,000/
ton$
10,000/
ton
Table
8­
24
shows
the
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative11,
and
marginal
costs
between
each
alternative.

Table
8­
24
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
25
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative12,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
32
Table
8­
25
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Hydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
26
shows
the
Table
8­
20
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
26
2015
SO216
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.

Table
8­
20
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Chemical
ProcessPortland
Cement
Plantsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources201
5
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
33
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
27
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Chemical
Process
Plantsa
Option
1
120,567
7%
101,289
19,276
120,567
3%
89,664
30,903
Option
2
Regulatory
Alternativeb
Number
of
Affected
Sources201
5
Baseline
Emissions1
20,567
7%
65,966
54,601
2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
t
on217,063149,7386
7,325$
4,000/
ton217
,06386,607130,456
$
10,000/
ton217,063
86,541130,522
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
34
Table
8­
281
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
illustrative
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeillustrative
regulatory
option
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.$
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
$
1,243$
0
to
$
25,140
per
ton.

Table
8­
28031
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.

Table
8­
21
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Chemical
ProcessPortland
Cement
Plants
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
35
Illustrative
Regulatory
AlternativeOptio
ns
Annual
Control
Cost
(
million
1999$)
Ann
ual
Monitoring
and
Administra
tive
Costs
(
million
1990$)
Inter
est
Rate
Total
AnnualAnnualiz
ed
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAn
nualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMargi
nal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

$
4
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
4,000/
ton131
6,816
$
10,000/
ton
Table
8­
292
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
illustrative
regulatory
alternative13option,
and
marginal
costs
between
each
alternative.

Table
8­
29illustrative
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
36
as
mid­
kiln
firing.

Table
8­
22
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Chemical
ProcessPortland
Cement
Plants
Illustrative
Regulatory
AlternativeO
ptions
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrativ
e
Costs
(
million
1990$)
Interes
t
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAnnua
lized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Cost
($/
ton)

Option
1
7%
$
862.9
$
12.4$
99.3$
1,203$
150
­­­­­­­­­­­­

$
4,000/
ton
3%
$
20.8
$
674
­­­­­­­­­­­­

Option
2
86.97%
13131.2
2,403
$
3,632
3%
219.3
100.23
,050
14,213839
Option
3
7%
$
10,000/
ton87275.1
133,825
7,731
3%
219.3
100.43
,050
1,215N/
A
Table
8­
308­
23
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative14,
and
marginal
costs
between
each
alternativeannualized
costs
of
each
illustrative
regulatory
option
for
control
of
both
SO2SO2
and
NOx.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
37
Table
8­
308­
23
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Chemical
ProcessPortlandCement
Plants
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Interest
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)

Annual
Cost
Effectiveness
($/
ton)
Option
1
Marginal
Cost
Effectiveness
($/
ton)
7%
$
1,000/
ton$
86$
2.9
$
12.4
3%
$
99$
20.8
Option
2
7%
174.8
3%
269.0
Option
3
$
1,203­­­­­­­­­­­­$
4,000/
ton867%
409.91
3.31
00.21
,2135
$
10,000/
ton3%
87346.1
13.3100.41,215
Table
8­
31
shows
the
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
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
31
2015
SO235
to
38
percent
for
costs
at
a
7
percent
interest
rate,
and
the
same
for
costs
at
a
3
percent
interest
rate.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
38
Table
8­
24
2015
SO2
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
IronHydrofluoric,
Sulfuric,
and
Steel
MillsaNitric
Acid
Plantsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
32
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Iron
and
Steel
Millsa
Regulatory
AlternativebNumber
of
Affected
Sources2015
Baseline
Emissions2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
t
on217,063Option
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
39
Option
3
14996,73867,325$
4
,000/
ton217,06386,
607130,456$
10,000
/
ton217,06386,5417
41
1307%
60,522188
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
33
shows
the
annual
costs
,
resulting
average
annual
cost­
effectiveness
for
each
regulatory
alternative,
and
marginal
costs
between
each
alternative
for
SO2
control.
The
annual
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.
The
accompanying
average
cost­
effectiveness
results
range
from
$
1,243
to
$
2,140
per
ton.

Table
8­
33
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton­­­­­­­­­­­­$
4,000/
ton$
10,000/
ton
Table
8­
34
shows
the
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative15,
and
marginal
costs
between
each
alternative.

Table
8­
34
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1999$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
40
Table
8­
35
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative16,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
Nox.

Table
8­
35
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Mills
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1999$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
36
shows
the
Table
8­
25
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
36
2015
SO2of
about
66%.
The
degree
of
impact
varies
little
between
regulatory
options
and
the
interest
rate
of
the
costs.

Table
8­
25
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Coke
Oven
BatteriesaHydrofluoric,
Sulfuric,
and
Nitric
Acid
Plantsa
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
41
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
37
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Coke
Oven
Batteriesa
Regulatory
AlternativebNumber
of
Affected
Sources2015
Baseline
Emissions2015
Post­
Control
Emissions2015
Emission
ReductionsOption
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
$
1,000/
ton21717,06
3059
7%
5,776
1491,73867,325$
4,
000/
ton283
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
42
21717,06386,60705
9
3%
5,776
130,456$
10,000/
ton
217,06386,541130,
52211,283
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
3826
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
illustrative
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeoption
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.$
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
$
1,243$
287
to
$
2,140
per
ton.

Table
8­
38$
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).

Table
8­
26
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Coke
Oven
BatteriesHydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
43
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1999$)
Annu
al
Monitoring
and
Administrati
ve
Costs
(
million
1990$)
Intere
st
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Annualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMargin
al
Costs
($/
ton)

Option
1
7%
$
9.8
$
287
­­­­­­­­­­­­

$
4
3%
$
9.1
$
268
­­­­­­­­­­­­

Option
2
7%
15.2
413
$
2,000/
ton067
3%
14.1
385
1,914
Option
3
7%
15.2
413
N/
A
3%
14.1
385
N/
A
$
10,000/
ton
Table
8­
3927
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
illustrative
regulatory
alternative17option,
and
marginal
costs
between
each
alternative.

Table
8­
39illustrative
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
44
Table
8­
27
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Coke
Oven
BatteriesHydrofluoric,
Sulfuric,
and
Nitric
Acid
Plants
Illustrative
Regulatory
AlternativeO
ptions
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrativ
e
Costs
(
million
1990$)
Interes
t
Rate
Total
AnnualAnnu
alized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAnn
ualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMargi
nal
Costs
($/
ton)

Option
1
7%
$
86.92
$
12.4$
99.3$
1,203$
726
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
45
$
4,000/
ton
86.913.3100.2
1,2133%
$
10,000/
ton8
7.11
3.31
00.41
,215
Table
8­
40
shows
the
total
annual
costs,
resulting
annual
average
costeffectiveness
for
each
regulatory
alternative18,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.

Table
8­
40
2015
Cost
and
Cost­
Effectivenes
s
Results
for
SO2
and
NOx
Control
at
non­
EGU
BARTEligible
Units
at
Coke
Oven
Batteries
$
646
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
46
Option
2
7%
8.2
728
$
4,000/
ton428
86.9
133%
7.3
100647
2,157
Option
3
7%
8.2
1,213728
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%
$
10,000/
ton$
18.0
87.113.3100
3%
$
16.4
1,
Option
2
7%
23.4
3%
215.4
Option
3
7%
23.4
3%
21.4
8.4.6
Results
for
Chemical
Process
Plants
Table
8­
4129
shows
the
SO2
emissions
reductions
achieved
in
the
analyses
for
each
illlustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.

Table
8­
41
2015
SO20
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
47
Non­
EGU
BART­
Eligible
Units
at
Sulfur
RecoveryChemical
Process
Plantsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
42
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Sulfur
Recovery
Plantsa
Option
1
47,700
7%
47,700
0
47,700
3%
47,700
0
Option
2
Regulatory
Alternativeb47,700
Number
of
Affected
Sources7%
45,324
2015
Baseline
Emissions2,376
47,700
3%
45,324
2015
Post­
Control
Emissions2015
Emission
Reductions2,376
Option
3
$
147,000/
ton700
7%
44,129
3,571
21747,063700
3%
149,73867,325$
444
,000/
ton129
217,06386,607130,
456$
10,000/
ton217,
063863,5471
130,522
a
The
2015
baseline
emissions
estimate
reflects
emissions
from
all
BART­
eligible
sources
in
these
source
categories,
both
controlled
and
uncontrolled.

Table
8­
43
shows
the
annual
costs
,
resulting
average
annual
cost­
effectiveness
for
each
regulatory
alternative,
and
marginal
costs
between
each
alternative
for
SO2
control.
The
annual
control
costs
range
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
48
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million.
The
accompanying
average
cost­
effectiveness
results
range
from
$
1,243
to
$
2,140
per
ton.

Table
8­
43
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Sulfur
Recovery
Plants
Regulatory
Alternative
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton­­­­­­­­­­­­$
4,000/
ton$
10,000/
ton
Table
8­
44
shows
the
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative19,
and
marginal
costs
between
each
alternative.

Table
8­
44
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Sulfur
Recovery
Plants
Regulatory
Alternative
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­
$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
45
shows
the
total
annual
costs,
resulting
annual
average
cost­
effectiveness
for
each
regulatory
alternative20,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.

Table
8­
45
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
and
NOx
Control
at
non­
EGU
BART­
Eligible
Units
at
Sulfur
Recovery
Plants
Regulatory
Alternative
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
49
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Cost
Effectiveness
($/
ton)$
1,000/
ton$
86.9$
12.4$
99.3$
1,203­­­­­­­­­­­­
$
4,000/
ton86.913.3100.21,213$
10,000/
ton87.113.3100.41,215
Table
8­
46
shows
the8­
30
shows
the
NOx
emissions
reductions
achieved
in
the
analyses
for
each
illustrative
regulatory
alternativeoption.
The
table
indicates
that
the
alternativesoptions
achieve
incremental
reductions
from
the
2015
baseline
ranging
from
_%
to
_%.
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.

Table
8­
4630
2015
SO2NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Primary
Aluminum
Ore
ReductionChemical
Process
Plantsa
Illustrative
Regulatory
AlternativebOptio
ns
Number
of
Affected
Sources2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
50
$
1,000/
ton388,5693
2,213$
4,000/
ton269
,395151,387$
10,00
0/
ton220,474200,30
8
Table
8­
47
2015
NOx
Baseline
Emissions
and
Emission
Reductions
for
Non­
EGU
BARTEligible
Units
at
Primary
Aluminum
Ore
Reduction
Plantsa
Option
1
Regulatory
Alternativeb72,577
Number
of
Affected
Sources7%
2015
Baseline
Emissions2015
Post­
Control
Emissions2015
Emission
Reductions$
1,000/
t
on1,676149,73850$
4,000/
ton1,6768648
,607
13023,970
72,577
3%
45,456435
27,142
Option
2
72,577
7%
37,941
34,636
$
10
72,000/
ton577
3%
137,676776
8634,801
Option
3
72,541577
7%
37,776
34,801
130
72,522577
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
4831
shows
the
annualannualized
costs
,
resulting
annualized
average
annual
costeffectiveness
for
each
illustrative
regulatory
alternativeoption,
and
marginal
costs
between
each
alternativeillustrative
regulatory
option
for
SO2SO2
control.
The
annualannualized
control
costs
range
from
$
200
million
to
$
2.3
billion.
Annual
monitoring
and
administrative
costs
depend
on
the
number
of
covered
sources,
and
since
the
number
of
sources
is
constant
across
the
alternatives,
this
cost
is
also
constant
at
_
million$
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
$
1,243
to
$
2,140
per
ton.

Table
8­
48$
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
51
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.

Table
8­
31
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Primary
Aluminum
Ore
ReductionChemical
Process
Plants
Illustrative
Regulatory
Alternative
Options
Annual
Control
Cost
(
million
1999$)
Annu
al
Monitoring
and
Administrati
ve
Costs
(
million
1990$)
Intere
st
Rate
Total
AnnualAnnualize
d
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
MarginalAn
nualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarg
inal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

$
4
3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
7%
2.5
1,000/
ton052
$
10,000/
ton052
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
4932
shows
the
annualannualized
costs,
resulting
annualannualized
average
costeffectiveness
for
each
illustrative
regulatory
alternative21option,
and
marginal
costs
between
each
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
52
alternative.

Table
8­
49illustrative
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.

Table
8­
32
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Primary
Aluminum
Ore
ReductionChemical
Process
Plants
Illustrative
Regulatory
AlternativeO
ptions
Annual
Control
Cost
(
million
1990$)
Annu
al
Monitoring
and
Administrati
ve
Costs
(
million
1990$)
Intere
st
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)
Annual
Cost
Effectiveness
($/
ton)
Marginal
Annualized
Average
Cost
Effectiveness
($/
ton)
$
1,000/
tonMarginal
Costs
($/
ton)

$
86.9Option
1
7%
$
124.4
$
99.3$
1,203$
601
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
53
$
4,000/
ton86.
913.3100.21,2
13$
10,000/
ton
87
3%
$
21.1
13.31
00.41
,215
Table
8­
50
shows
the
total
annual
costs,
resulting
annual
average
costeffectiveness
for
each
regulatory
alternative22,
and
marginal
costs
between
each
alternative
for
control
of
both
SO2
and
NOx.

Table
8­
50
2015
Cost
and
Cost­
Effectiveness
Results
for
SO2
and
NOx
Control
at
non­
EGU
BARTEligible
Units
at
Primary
Aluminum
Ore
Reduction
Plants
Regulatory
Alternative
­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
54
$
4,000/
tonOpt
ion
2
86.913.3100
7%
68.2
1,213969
$
5,030
$
10,000/
ton3
%
87.11
3.31
0054.4
1,215563
4,348
Option
3
7%
74.1
2,129
35,758
3%
77.1
2,191
58,082
The
remaining
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.

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
AlternativeOpti
ons
Annual
Control
Cost
(
million
1990$)
Annua
l
Monitoring
and
Administrativ
e
Costs
(
million
1990$)
Interes
t
Rate
Total
AnnualAnnualized
Costs
(
million
19909$)

Annual
Cost
Effectiveness
($/
ton)
Option
1
Marginal
Cost
Effectiveness
($/
ton)
7%
$
1,000/
ton$
86.9$
12$
14.4
3%
$
9921.1
Option
2
7%
70.8
3%
56.8
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
55
Option
3
$
1,203­­­­­­­­­
­­­
$
4,000/
ton86.
913.3100.21,2
13$
10,000/
ton
7%
87.18
13
3%
87.3
100
8.41,215
Table
8­
51
2015
NOx.
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
Lime
Kilns
Non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Millsa
Illustrative
Regulatory
AlternativeNumbe
r
of
Affected
SourcesOptions
2015
Baseline
Emissions
Interest
Rate
2015
Post­
Control
Emissions
2015
Emission
Reductions
$
1,000/
ton5742,701
Option
1
263,312541
7%
23,541
0
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
56
23,541
3%
23,541
0
Option
2
1623,541
7%
20,627
2,389914
23,541
3%
20,627
2,914
$
4,000/
tonOption
3
5723,541
7%
20,627
422,701914
23,541
26,31216,389$
103
%
20,000/
ton57627
422,70126,31216,3
89914
a
TheaThe
2015
baseline
emissions
estimate
reflects
emissions
from
all
58
largeBART­
eligible
sources
in
thisthese
source
categorycategories,
both
controlled
and
uncontrolled.

Table
7­
6
shows
the
annual
costs
and
resulting
average
cost­
effectiveness
for
each
regulatory
alternative.
The
annual
control
costs
for
all
alternatives
is
$
23.9
million,
and
is
based
on
a
combination
of
urea­
based
SNCR
and
combustion
modifications.
Annual
monitoring
and
administrative
costs
for
all
alternatives
are
$
3.7
million.
23
The
accompanying
average
cost­
effectiveness
is
$
1,458
per
ozone
season
ton,
and
the
reductions
from
uncontrolled
2007
baseline
emissions
are
just
over
40%.

While
all
the
control
levels
meet
EPA's
criteria
for
highly
effective
ozone
season
NOx8­
35
shows
the
NOx
emissions
reductions,
there
are
additional
factors
that
EPA
has
considered
in
establishing
the
final
emissions
budgets
for
this
source
category.
First,
the
grouping
of
all
cement
manufacturing
operations
(
i.
e.,
wet,
dry,
and
in­
process­
bituminous
coal)
in
Tables
7­
5
and
7­
6
masks
the
fact
that
a
significant
portion
of
the
large
operations
(
21
of
58)
in
the
analysis
are
not
able
to
achieve
cost­
effective
reductions
with
technologies
more
stringent
than
combustion
modifications
(
e.
g.,
SNCR
and
SCR).
EPA
received
numerous
public
comments
confirming
this
result.
Based
on
evidence
cited
in
the
cement
ACT
document
and
in
some
comments
on
the
SIP
call
proposals,
EPA
believes
that
a
30%
reduction
from
uncontrolled
levels
would
be
within
the
cost­
effectiveness
range
for
reducing
emissions
at
all
types
of
cement
kilns.
After
reconsidering
its
own
analysis,
and
considering
public
comments,
EPA
has
decided
to
base
the
NOx
budget
level
on
the
combustion
modification
technologies
which
can
achieve
up
to
30%
control.
The
reader
should
note
that
due
to
the
timing
of
this
final
decision,
the
cost
and
economic
impact
results
presented
in
the
remainder
of
this
report
reflect
the
$
5,000/
ton
regulatory
alternative
rather
than
the
30%
control
assumption.

Table
8­
52
2015
Cost
and
Cost­
Effectiveness
Results
for
BART­
eligible
Lime
Kilns
Regulatory
AlternativeAnnual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1999$)
Ozone
Season
Cost
Effectiveness
($/
ozone
season
ton)$
1,000/
ton$
20.2$
3.7$
23.9$
1,458$
4,000/
ton20.23.723.91,458$
10,000/
ton20.23.723.91,458
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
57
Table
7­
8
shows
the
annual
costs
and
resulting
average
cost­
effectiveness
for
each
regulatory
alternative.
When
emissions
decreases
are
considered
at
all
large
glass
manufacturing
sources
(
regulatory
alternatives
greater
than
$
3,000/
ton
of
control),
the
resulting
average
cost­
effectiveness
exceeds
EPA's
$
2,000
framework.
Only
the
12
flat
glass
manufacturers
are
able
to
achieve
cost­
effective
reductions
(
after
considering
administrative
costs)
with
any
technology.
If
all
large
sources
in
this
category
were
included
in
the
NOx
Budget
Trading
Program,
the
potential
inequities
in
control
capability
across
sources
could
be
smoothed
out
but
the
average
cost
effectiveness
would
exceed
EPA's
$
2,000
framework.
Therefore,
this
source
category
exceeds
EPA's
cost
effectiveness
framework
and
is
not
included
in
the
assumed
NOx
emissions
decreases
for
the
Statewide
budgets.

Table
8­
53
2015
NOx
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.

Table
8­
35
2015
NOx
Baseline
Emissions
and
Emission
Reductions
(
in
tons)
for
Glass
Fiber
Processing
Plants
Non­
EGU
BART­
Eligible
Units
at
Iron
and
Steel
Millsa
Illustrative
Regulatory
AlternativeNum
ber
of
Affected
SourcesOptions
200715
Baseline
Emissions
Interest
Rate
200715
Post­
Control
Emissions
200715
Emission
Reductions
$
1Option
1
20,963
7%
19,927
1,000/
ton036
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
58
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
5720,963
7%
4212,701456
8,507
26,31220,96
3
3%
12,290
16,389$
4,000/
ton574
2,70126,31216,389$
1
0,000/
ton5742,70126,
31216,3898,673
a
TheaThe
200715
baseline
emissions
estimate
reflects
emissions
from
all
58
largeBART­
eligible
sources
in
thisthese
source
categorycategories,
both
controlled
and
uncontrolled.

Table
7­
68­
36
shows
the
annualannualized
costs
and,
resulting
annualized
average
costeffectiveness
for
each
regulatory
alternative.
The
annual
control
costs
for
all
alternatives
is
$
23.9
million,
and
is
based
on
a
combination
of
urea­
based
SNCR
and
combustion
modifications.
Annual
monitoring
and
administrative
costs
for
all
alternatives
are
$
3.7
million.
24illustrative
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
is
$
1,458
per
ozone
season
ton,
and
the
reductions
from
uncontrolled
2007
baseline
emissions
are
just
over
40%.

While
all
the
control
levels
meet
EPA's
criteria
for
highly
effective
ozone
season
NOx
emissions
reductions,
there
are
additional
factors
that
EPA
has
considered
in
establishing
the
final
emissions
budgets
for
this
source
category.
First,
the
grouping
of
all
cement
manufacturing
operations
(
i.
e.,
wet,
dry,
and
inprocess
bituminous
coal)
in
Tables
7­
5
and
7­
6
masks
the
fact
that
a
significant
portion
of
the
large
operations
(
21
of
58)
in
the
analysis
are
not
able
to
achieve
cost­
effective
reductions
with
technologies
more
stringent
than
combustion
modifications
(
e.
g.,
SNCR
and
SCR).
EPA
received
numerous
public
comments
confirming
this
result.
Based
on
evidence
cited
in
the
cement
ACT
document
and
in
some
comments
on
the
SIP
call
proposals,
EPA
believes
that
a
30%
reduction
from
uncontrolled
levels
would
be
within
the
cost­
effectiveness
range
for
reducing
emissions
at
all
types
of
cement
kilns.
After
reconsidering
its
own
analysis,
and
considering
public
comments,
EPA
has
decided
to
base
the
NOx
budget
level
on
the
combustion
modification
technologies
which
can
achieve
up
to
30%
control.
The
reader
should
note
that
due
to
the
timing
of
this
final
decision,
the
cost
and
economic
impact
results
presented
in
the
remainder
of
this
report
reflect
the
$
5,000/
ton
regulatory
alternative
rather
than
the
30%
control
assumption.

Table
8­
54results
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
59
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).

Table
8­
36
2015
Cost
and
Cost­
Effectiveness
Results
for
Glass
Fiber
Processing
Plants
SO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Illustrative
Regulatory
AlternativeO
ptions
Interest
Rate
Annual
Control
Cost
(
million
1999$)
Annual
Monitoring
and
Administrativ
e
Costs
(
million
1990$)
Total
AnnualAnnual
ized
Costs
(
million
1999$)
AnnualAnnualized
Average
Cost
Effectiveness
($/
ton$/
ton)
$
1,000/
tonMarginal
Costs
($/
ton)

Option
1
7%
$
20.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

Option
2
$
3.77%
5.3
$
23.9$
11,458$
4,000/
ton20.23
.72
3.98
19
1,458819
$
10,000/
ton
20.23%
3.72
3.94
1,458165
1,165
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
60
Option
3
7%
5.3
1,819
N/
A
3%
3.4
1,165
N/
A
8.1.10
Results
for
Municipal
Incinerators
The
analysis
of
municipal
incinerators
(
>
250
tons
per
day
burn
refuse
capacity)
is
conducted
by
selecting
the
most
cost­
effective
control
measure
available
for
each
identified
source
that
does
not
exceed
the
Table
8­
37
shows
the
annualized
costs,
resulting
annualized
average
cost­
effectiveness
cut­
off
specified
in
the
regulatory
alternative.
Table
7­
11for
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.

Table
8­
37
2015
Cost
and
Cost­
Effectiveness
Results
for
NOx
Control
at
non­
EGU
BART­
eligible
Units
at
Iron
and
Steel
Mills
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
61
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$)

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
analysies
for
each
illustrative
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
62
regulatory
alternativeoption.
The
table
indicates
that
the
alternativeoptions
achieve
from
incremental
reductions
from
the
200715
baseline
ranging
from
0%
to
45%.

Table
8­
55
2015
NOx0
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
for
Municipal
Incineratorsa
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Coke
Oven
Batteries
Ilustrative
Regulatory
AlternativeN
umber
of
Affected
SourcesOptio
ns
200715
Baseline
Emissions
Interest
Rate
200715
Post­
Control
Emissions
200715
Emission
Reductions
$
1,500/
tonOpt
ion
1
9,815
7%
9,815
0
2
9,852815
23%
9,852815
0
$
2,000/
tonOpt
ion
2
029,8522,8
520$
3,000/
t
on302,8521
,577815
7%
5,727
1,275$
44,000/
ton0
88
9,815
3%
6,091
3,724
Option
3
9,815
7%
303,708
26,107
9,852815
3%
4,251
15,5771,275$
5,00
0/
ton302,8521,577
1,275564
a
The
200715
baseline
emissions
estimate
reflects
emissions
from
all
30
largeBART­
eligible
sources
in
thisthese
source
categorycategories,
both
controlled
and
uncontrolled.

Table
7­
12
shows
the
annual
costs
and
resulting
average
cost­
effectiveness
for
each
regulatory
alternative.
Annual
monitoring
and
administrative
costs
are
not
estimated
for
this
category
of
sources
because
it
is
evident
from
Table
7­
12
that
even
without
these
additional
costs
there
is
no
regulatory
alternative
that
meets
EPA's
framework
for
highly
cost­
effective
ozone
season
NOx
8­
40
shows
the
emissions
reductions.
Therefore
no
additional
reductions
are
assumed
from
this
source
category
group
for
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
63
establishing
State
level
emissions
budgets.

Table
8­
56
2007
Cost
and
Cost­
Effectiveness
Results
for
Municipal
Incinerators
Regulatory
AlternativeAnnual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
Annual
Costs
(
million
1990$)
Ozone
Season
Cost
Effectiveness
($/
ozone
season
ton)$
1,500/
ton$
0.0naa$
0.0N/
A$
2,000/
ton0.0na0.0N/
A$
3,000/
ton2.7na2.72,118$
4,000/
ton2.7na2.72,118$
5,000/
ton2.7na2.72,118a
Monitoring
and
administrative
costs
are
not
estimtated
for
these
sources
since
the
region­
wide
average
control
cost­
effectiveness
for
the
source
category
exceeds
$
2,000
per
ozone
season
ton
reduced,
and
therefore
is
not
subject
to
additional
reductions
in
this
rulemaking.

Table
8­
57
2015
NOx
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
for
Coal
Cleaning
Plants
(
in
tons)
for
Non­
EGU
BART­
Eligible
Units
at
Coke
Oven
Batteriesa
Illustrative
Regulatory
AlternativeNumbe
r
of
Affected
SourcesOption
200715
Baseline
Emissions
200715
Post­
Control
Emissions
200715
Emission
Reductions
$
1,000/
ton5742,701
Option
1
26,3121610,389
$
4,000/
ton5742,701
26,3121610,389
$
10,000/
ton5742,70126,312160
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
200715
baseline
emissions
estimate
reflects
emissions
from
all
58
largeBART­
eligible
sources
in
thisthese
source
categorycategories,
both
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
64
controlled
and
uncontrolled.

Table
7­
68­
41
shows
the
annualannualized
costs
and,
resulting
annualized
average
costeffectiveness
for
each
regulatory
alternative.
The
annual
control
costs
for
all
alternatives
is
$
23.9
million,
and
is
based
on
a
combination
of
urea­
based
SNCR
and
combustion
modifications.
Annual
monitoring
and
administrative
costs
for
all
alternatives
are
$
3.7
million.
25illustrative
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
is
$
1,458
per
ozone
season
ton,
and
the
reductions
from
uncontrolled
2007
baseline
emissions
are
just
over
40%.

While
all
the
control
levels
meet
EPA's
criteria
for
highly
effective
ozone
season
NOx
emissions
reductions,
there
are
additional
factors
that
EPA
has
considered
in
establishing
the
final
emissions
budgets
for
this
source
category.
First,
the
grouping
of
all
cement
manufacturing
operations
(
i.
e.,
wet,
dry,
and
inprocess
bituminous
coal)
in
Tables
7­
5
and
7­
6
masks
the
fact
that
a
significant
portion
of
the
large
operations
(
21
of
58)
in
the
analysis
are
not
able
to
achieve
cost­
effective
reductions
with
technologies
more
stringent
than
combustion
modifications
(
e.
g.,
SNCR
and
SCR).
EPA
received
numerous
public
comments
confirming
this
result.
Based
on
evidence
cited
in
the
cement
ACT
document
and
in
some
comments
on
the
SIP
call
proposals,
EPA
believes
that
a
30%
reduction
from
uncontrolled
levels
would
be
within
the
cost­
effectiveness
range
for
reducing
emissions
at
all
types
of
cement
kilns.
After
reconsidering
its
own
analysis,
and
considering
public
comments,
EPA
has
decided
to
base
the
NOx
budget
level
on
the
combustion
modification
technologies
which
can
achieve
up
to
30%
control.
The
reader
should
note
that
due
to
the
timing
of
this
final
decision,
the
cost
and
economic
impact
results
presented
in
the
remainder
of
this
report
reflect
the
$
5,000/
ton
regulatory
alternative
rather
than
the
30%
control
assumption.

Table
8­
58results
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
Coal
Cleaning
PlantsSO2
Control
at
Non­
EGU
BART­
eligible
Units
at
Coke
Oven
Batteries
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
65
Illustrative
Regulatory
AlternativeO
ptions
Interest
Rate
Annual
Control
Cost
(
million
1990$)
Annual
Monitoring
and
Administrative
Costs
(
million
1990$)
Total
AnnualAnnualized
Costs
(
million
1990$)
Ozone
SeasonAnnualize
d
Average
Cost
Effectiveness
($/
ozone
season
ton$/
ton)
Marginal
Costs
($/
ton)

Option
1
7%
$
0.0
$
0
­­­­­­­­­­­­

3%
$
0.0
$
0
­­­­­­­­­­­­

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)
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
66
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
67
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
68
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.

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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
69
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
$
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
70
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
71
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.

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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
72
Illustrative
Regulatory
Options
Interest
Rate
Total
Annualized
Costs
(
million
1999$)
Annualized
Average
Cost
Effectiveness
($/
ton)
Marginal
Costs
($/
ton)

$
1,000/
ton
$
20.2$
3.7$
23.
97%
$
1,458.6
$
982
­­­­­­­­­­­­

3%
$
1.0
$
590
­­­­­­­­­­­­

$
4,000/
ton
207%
7.2
32,209
$
3,436
3%
4.72
3.95
1,458383
1,383
$
10,000/
ton
207%
7.2
3.72
3.92
,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
­­­­­­­­­­­­­­
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
73
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
1,458
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
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.

8.1.7
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
74
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
75
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
76
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
77
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
$
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
78
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
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
79
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
80
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)

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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
81
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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
82
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
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
83
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
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
Table
8­
13
contains
ofBelow
are
several
summary
tables
in
which
the
emission
reductions
and
costs
associated
with
the
final
regulatory
decisions
arising
from
the
cost­
effectiveness
analysis.
The
final
combination
of
regulatory
alternatives
achieves
an
ozone
seasonfor
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
reduction
of
approximately
203,000
tons
beyond
the
2007
baseline.
This
represents
approximately
a
62%
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
84
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
baseline
for
these
combined
sources.

Table
7­
13
2007
Ozone
Seasonthe
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
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.
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
85
Table
8­
68
SO2
Emissions
and
Emission
Reductions
and
Total
Annual
Compliance
Costs
for
Non­
Electricity
Generating
Sources
Used
to
Establish
State
NOx
Emissions
Budgets
under
the
NOx
SIP
Call
a
for
BART
Source
Categories
in
2015
BART
Source
Category
Baseline
Ozone
Season
Emissions
Ozone
Season
Emissions
After
ControlTot
al(
tons)
Interest
Rate
Illustrative
Regulatory
Options
­
Reduction
in
Ozone
Season
Emissionss
(
tons)
Total
Annual
Compliance
Costs
(
million
1990$)

Option
1
Option
2
Option
3
Industrial
Boilers
188420,782
7%
32,213
151,387
200,308
420,636782
3%
89,06565,78
3
99164,438
204,217
Petroleum
Refineries
199,571483
7%
2,097
31,319
56,462
199,483
3%
17,033
41,911
122.958,525
Combustion
TurbinesKraft
Pulp
Mills
5119,80981
8
7%
0
110,814
28,380
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
86
119,818
3%
0
3,12896
414,6814.0610
Internal
Combustion
Engines92,42
39,801
82,623100.4P
ortland
Cement
Manufacturin
gPlants
42116,7018
35
7%
0
13,383
26,312716
16
116,389835
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
TOTAL2,914
23,541
329,5693%
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%
126,3042031
3,265697
13,697
13,697
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
87
59,766
277.23%
a
Emissions
estimates
are
for
large
sources
only.
Baseline
NOx
emissions
estimates
for
industrial
boilers
do
not
include
emissions
for
the
90
nonfossil
fuel
fired
boilers.
The
emissions
reduction
estimates
reflect
the
preferred
alternative
for
other
stationary
sources
(
60%
control
of
large
industrial
boilers
and
combustion
turbines;
and
control
applied
up
to
$
5,000
per
ton
for
stationary
internal
combustion
engines
and
all
cement
kilns).
13,693
13,693
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
88
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
89
Secondary
Metal
Production
Facilities
Control
Technology
60%
Control
for
Industrial
Boilers
and
Combustion
Turbines$
5,
000/
ton
Alternative
for:
TotalIC
EnginesCem
ent
KilnsSCR80
1870267SN
CR1989,98
8
037235OT
+
WI3927%
0
0
392OTHERb13711
80
9,988
213%
2760
TOTAL80730
5580
0
TOTALS:
1,170208,08
8
7%
83,778
236,992
378,169
1,208,088
3%
132,279
290,591
a
These
results
represent
the
number
of
emissions
units
for
which
the
specified
control
technology
is
applied
in
the
control
cost
analysis.
State
and
source
control
decisions
in
response
to
the
SIP
call
may
differ.
373,797
b
Includes
sources
that
are
estimated
NOT
to
apply
addition
controls.

7.1.8
Adminstrative
Costs
for
Non­
Electricity
Generating
Units
The
burden
to
other
stationary
source
operators
potentially
resulting
from
implementation
of
the
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
90
NOx
SIP
call
rule
are
primarily
associated
with
costs
of
installing
and
operating
a
continuous
emissions
monitoring
system
(
CEMS)
to
monitor
NOx
mass
emissions
and
demonstrate
compliance
with
limits
established
by
a
State.
This
burden
includes
the
total
time,
effort,
or
financial
resources
expended
by
an
operator
to
generate,
maintain,
retain,
or
disclose
or
provide
information
to
or
for
a
Federal
or
State
agency.

A
large
proportion
of
the
other
stationary
sources
are
expected
to
install
CEMS
and/
or
upgrade
their
data
acquisition
and
handling
systems
(
DAHS)
in
order
to
participate
in
the
NOx
trading
program.
For
trading
sources
(
industrial
boilers
and
combustion
turbines)
subject
to
Title
IV
monitoring
in
the
Ozone
Transport
Region
(
OTR),
only
administrative
costs
of
recordkeeping
and
reporting
were
estimated.
These
units
will
not
potentially
experience
additional
capital
or
operating
and
maintenance
costs
as
a
result
of
this
rulemaking
since
they
are
already
equipped
with
a
CEMS
meeting
Part
75
Subpart
H
specifications.
However,
Title
IV
units
that
are
not
in
the
OTR
will
likely
require
minor
upgrades
to
their
DAHS.
Therefore,
the
burden
estimate
associated
with
this
rulemaking
for
these
sources
includes
additional
capital
and
operations
and
maintenance
costs.

For
units
not
subject
to
Title
IV
monitoring
but
in
the
OTR,
costs
are
estimated
for
upgrading
the
DAHS
and
performing
annual
quality
assurance
testing.
For
trading
units
not
subject
to
the
Title
IV
monitoring
and
not
in
the
OTR,
additional
costs
may
result
from
installing
a
NOx
CEMS,
or
other
approved
monitoring
system,
and
a
DAHS.
The
Part
75
NOx
monitoring
requirements
vary
depending
on
the
fuel
burned
and
the
hours
of
operation.
For
example,
monitoring
requirements
are
less
stringent
for
gas/
oil
fired
sources
than
for
coal­
fired
sources,
and
are
even
less
stringent
for
peaking
units
and
low
NOx
mass
emissions
sources.
Similarly,
the
non­
trading
sources
are
assumed
to
experience
additional
costs
from
installing
a
NOx
CEMS,
or
other
approved
monitoring
system,
as
well
as
a
DAHS.
26
Although
not
explicitly
required
in
the
NOx
SIP
call,
it
is
assumed
as
a
worst­
case
scenario
that
if
controlled,
a
State
would
require
a
CEMS,
or
equivalent,
for
the
non­
trading
sources.

Table
7­
15
presents
estimates
of
the
per­
source
annual
administrative
costs
that
other
stationary
source
operators
may
experience,
based
on
assumptions
of
how
States
will
implement
administrative
requirements
in
response
to
this
rulemaking.
These
estimates
are
prepared
for
both
trading
and
non­
trading
sources
and
included
in
the
cost
analysis
results.

Table
7­
15
Average
Per
Source
Annual
Administrative
Costs
for
Other
Stationary
Sources
in
2007
(
1990
dollars)
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
91
Table
8­
69
NOx
Emissions
and
Emission
Reductions
for
BART
Source
Category
GroupAnnual
Monitoring
CostsAnnual
Reporting
&
Permitting
CostsTotal
Annual
Administrative
CostsIndustrial
Boilers
and
Combustion
Turbines$
27,201$
5,141$
32,342IC
Engines$
43,353$
253$
43,606Cement
Manufacturing$
63,540$
253$
63,793Glass
Manufacturing$
83,664$
253$
83,917
7.2
Potential
Economic
Impacts
This
section
presents
the
results
of
a
screening­
level
economic
impact
analysis
for
industrial
boilers
and
turbines
and
other
stationary
sources
potentially
affected
by
the
rule.
The
analysis
estimates
the
potential
impact
on
facilities
and
firms
affected
by
the
rule
by
comparing
compliance
costs
to
estimated
sales
or
expenditures.
Facilities
and
firms
for
whom
costs
exceed
three
percent
or
sales
or
expenditures
are
identified
as
the
most
likely
to
experience
significant
impacts
as
a
result
of
the
rule.
Those
for
whom
costs
exceed
one
percent
of
sales
or
expenditures
are
also
highlighted
as
potentially
experiencing
significant
impacts.
Costs
that
represent
less
than
one
percent
of
sales
or
expenditures
are
not
expected
to
impose
significant
impacts.

While
the
RFA
as
amended
by
SBREFA
does
not
apply
to
this
rulemaking,
the
Agency
elected
to
evaluate
the
potential
impacts
of
the
rule
on
potentially
affected
small
entities,
based
on
assumptions
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
92
about
how
the
States
could
implement
the
requirements
associated
with
meeting
their
NOx
budgets.

The
analysis
of
impacts
is
conducted
at
three
levels:
establishment
(
or
facility),
firm
and
industry:


Costs
at
the
source
level
summarized
in
Section
7.2
are
aggregated
for
each
establishment,
where
an
establishment
owns
more
than
one
affected
source.
Establishment­
level
costs
are
then
compared
with
estimated
sales
or
expenditures
for
the
average
sized
establishment
in
the
relevant
industry
(
4­
digit
SIC)
and
employee
size
category
(
small
vs.
large),
as
described
in
Chapter
5.


Establishment­
level
impacts
are
summarized
at
the
industry
level,
as
defined
by
4­
digit
SIC
codes.


Finally,
costs
are
further
aggregated
to
the
firm
level
to
account
for
the
fact
that
some
firms
own
more
than
one
establishment
affected
by
the
rule.
Firm­
level
costs
are
compared
with
firm
sales,
obtained
for
the
most
part
from
Dun
&
Bradstreet
data,
as
described
in
Chapter
5.
For
governments,
costs
are
compared
with
revenues,
and
for
colleges
and
universities
costs
are
compared
with
expenditures.

Individual
potentially
affected
establishments
and
firms
may
have
both
industrial
boilers
and
gas
turbines
(
sources
in
the
trading
program)
and
other
stationary
sources
(
sources
not
in
the
trading
program)
affected
by
the
rule.
To
assess
economic
impacts
more
thoroughly,
it
is
therefore
necessary
to
consider
the
trading
and
non­
trading
alternatives
in
combination.

Section
7.2.1
provides
an
overview
of
the
potentially
affected
firms,
facilities
and
sources
in
the
affected
universe.
Detailed
economic
impacts
are
presented
in
Section
7.2.2
for
the
preferred
regulatory
alternative
combination
­­
a
60%
reduction
from
uncontrolled
2007
emissions
for
industrial
boilers
and
combustion
turbines
and
a
$
5,000/
ton
cost­
effectiveness
cap
for
other
non­
utility
sources
(
denoted
by
"
60%/$
5,000").
Section
7.2.3
compares
these
results
with
results
for
two
additional
regulatory
alternative
combinations.
The
potential
alternative
combinations
are
shown
in
Table
7­
16,
with
the
regulatory
alternative
combinations
examined
in
the
economic
impact
analysis
indicated
with
an
"
X".
The
alternative
combinations
that
are
analyzed
capture
the
range
of
stringency
considered
by
EPA,
from
the
most
stringent
combination
(
70%/$
5,000)
to
the
least
stringent
combination
(
40%/$
1,500.)

Table
7­
16
Potential
Regulatory
Alternative
Combinations
for
Non­
Electricity
Generating
Unit
Economic
Impact
Analysis
Regulatory
Alternatives
for
Industrial
Boilers
and
Combustion
Turbines40%
Control50%
Control60%
Control70%
ControlRegulatory
Alternatives
for
IC
Engines
and
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
93
Cement
Manufacturing$
1,500/
tonX$
2,000/
ton$
3,000/
ton$
4,000/
ton$
5,000/
tonXX
Throughout
the
discussion,
economic
impacts
are
presented
separately
by
size
of
the
potentially
affected
entity
that
owns
the
affected
establishments.
Section
7.3
discusses
firm­
level
impacts
for
potentially
affected
small
entities
in
more
detail.
Chapter
8
discusses
impacts
on
potentially
affected
government­
owned
entities
in
more
detail.

7.2.1
Overview
of
Potentially
Affected
Sources,
Establishments
and
Firms
Table
7­
17
shows
the
number
of
firms
potentially
affected
under
the
preferred
alternative,
by
source
category.
27Categories
in
2015
Table
7­
18
shows
the
same
information
by
sector
and
by
size
of
entity.

Table
7­
17
Number
of
Firms
and
Other
Entities
Potentially
Affected,
byBART
Source
Category
Source
TypeBasel
ine
Emissions
(
tons)
Interest
Rate
Potentially
Affected
Firms/
Entities
Illustrative
Regulatory
Options
Option
1
Option
2
TotalSmallOptio
n
3
Industrial
Boilers
221217,06
3
7%
67,325
130,456
130,522
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
94
217,063
283%
111,939
130,424
Gas
Turbines221
Internal
Combustion
Engines130,505
Petroleum
Refineries
1886,566
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
265,776
103,614
3%
53,729
65,792
Cement
Manufacturing65,
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
2017,059
7%
11,276
11,283
11,283
17,059
53%

Table
7­
18
Number
of
Firms
Potentially
Affected,
by
Sector
and
Size
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
95
Iron
and
Steel
Mills
Sector
and
Size
of
EntityPoten
tially
Affected
Firms/
Entit
ies20,963
7%
1,036
6,997
8,507
20,963
3%
1,036
8,500
8,673
Coke
Oven
Batteries
Firms
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
Primary
Aluminum
Ore
Reduction
Plants
1,676
7%
50
253
of
which255
1,
small
entities676
36%
large
entities50
253
255
Lime
Kilns
17612,849
7%
2,683
4,471
7,153
12,849
3%
4,471
7,153
7,153
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
96
Glass
Fiber
Processing
Plants
6,677
7%
568
2,116
entity
size
unknown
a41Federal
government1Other
government7Utilit
y
(
SIC
4911,
4931)
b14Colleges/
univer
sities6TOTAL281
a
Unknown
size
refers
to
entities
whose
employee
size
could
not
be
determined.

b
These
are
primarily
cogenerators
that
supply
less
than
50%
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
97
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
681,765
3%
246,067
390,871
393,349
Table
8­
70
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
98
Total
Annualized
Costs
of
generated
power
to
the
electric
power
grid.

7.2.2
Results
for
the
Preferred
Alternative
Combination
(
60%/$
5,000)

Firm/
Entity­
Level
Impacts
Screening­
level
impact
results
at
the
firm
level
are
summarized
in
Table
7­
19.
This
table
shows
the
number
of
potentially
affected
firms
or
entities
at
particular
levels
of
firm­
level
costs
as
a
percentage
of
firm
sales,
revenues
or
expenditures.

Table
7­
19
shows
that,
at
the
firm
or
entity­
level,
only
a
small
percentage
of
the
potentially
affected
firms
or
entities
for
which
sales
estimates
are
available
(
14
of
232
or
six
percent)
experience
costs
above
one
percent
of
sales,
and
of
these
only
eight
of
the
232
(
three
percent)
experience
costs
above
three
percent
of
sales.
Five
out
of
36
identified
potentially
affected
small
entities
may
experience
costs
of
three
percent
of
sales
or
greater.

EPA
expects
that
States
implementing
the
SIP
call
will
take
these
potential
impacts
into
account
in
designing
their
implementation
scenarios.
Industries
with
establishments
having
the
potential
for
significant
impacts
are
likely
candidates
to
be
excluded
from
control
requirements.

Table
7­
19
Number
of
Potentially
Affected
Firms
by
Firm
Costs
as
a
Percentage
of
Sales/
Expenditures:
60%/$
5,000
<
0.5
%
0.5­
1.0%
1
­
3%>
3%
Sales
NA
aTotalFirms/
Non­
Profits184134646253Of
which,
small
entities22545036large
entities1598018176entity­
size
unknown30003841Federal
Government
anananana11Other
Government
a311117Utility
b10111114Colleges/
Universities600006TOTAL203156849281a
Sales
not
available
or
(
for
the
federal
government)
not
applicable.
b
Co­
generation
units
that
supply
less
than
50%
of
generated
power
to
the
electric
power
grid.

Establishment­
Level
Impacts
The
281
potentially
affected
firms
are
comprised
of
546
establishments.
Establishment
level
impacts
provide
additional
insights
on
individual
facilities,
which
in
some
cases
are
seen
as
stand­
alone
profit
centers.
Table
7­
20
summarizes
the
results
of
the
establishment­
level
analysis,
by
sector
and
firm
size.

Table
7­
20
shows
that
impacts
of
the
preferred
regulatory
alternative
are
somewhat
variable.
The
large
majority
of
establishments
(
347)
incur
costs
that
represent
one
percent
or
less
of
estimated
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
99
sales/
expenditures,
and
of
those
286
incur
costs
less
than
0.5
percent
of
sales/
expenditures.
Of
the
110
establishments
potentially
incurring
costs
that
exceed
three
percent
of
estimated
sales/
expenditures,
only
seven
are
owned
by
identified
small
entities.
One
non­
federal
government
and
one
utility
establishment
incur
costs
greater
than
three
percent
of
revenues.

EPA
expects
that
States
implementing
the
SIP
call
will
take
these
potential
impacts
into
account
in
designing
their
implementation
scenarios.
Industries
with
establishments
having
the
potential
for
significant
impacts
are
likely
candidates
to
be
excluded
from
control
requirements.

Table
7­
20
Number
of
Establishments
by
Costs
as
a
Percentage
of
Value
of
Shipments/
Expenditures
and
Sector
and
Firm
Size:
60%/$
5,000
<
0.5
%
0.5­
1.0%
1
­
3%>
3%
TotalFirms/
Non­
Profits2695771109506Of
which,
owned
by
small
entities2145737owned
by
large
entities226495598428entity­
size
unknown22411441Federal
Government
anananana12Other
Government
a31117Utility
b733114Colleges/
Universities70007TOTAL2866175111546a
Revenues
not
available
for
one
"
other
government"
and
12
federal
government
establishments.
b
Co­
generation
units
that
supply
less
than
50%
of
generated
power
to
the
electric
power
grid.

Industry­
Level
Impacts
Table
7­
21
shows
estimated
impacts
at
the
establishment
level
by
industry
(
2
digit
SIC
code
level).
Table
7­
21
shows
that,
for
the
most
part,
only
a
small
number
of
establishments
(
usually
less
than
0.1
percent
of
the
total)
are
potentially
significantly
impacted
in
any
single
industry
compared
to
the
total
number
of
establishments
for
each
potentially
affected
industry
within
the
SIP
call
region.
The
546
affected
establishments
represent
only
0.02
percent
of
all
the
establishments
in
the
SIP
call
region
(
roughly
3.6
million).
In
most
cases,
potential
impactsControl
for
BART
Source
Categories
in
2015
(
million
1999$)

BART
Source
Category
Interest
Rate
Illustrative
Regulatory
Options
Option
1
Option
2
Option
3
Industrial
Boilers
7%
$
74.6
527.6
845.4
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
100
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
Primary
Aluminum
Ore
Reduction
Plants
7%
1.7
7.76
7.82
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
101
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
8.6
Caveats
and
Limitations
of
the
Analyses
There
are
a
number
of
caveats
and
limitations
associated
with
these
analyses.
They
are:
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
102

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
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
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
103
modest.
There
also
may
be
unquantified
costs
of
transitioning
to
BART,
such
as
the
costs
associated
with
the
NOx
SIP
call
are
unlikely
to
result
in
any
significant
impacts
at
the
industry
level
for
potentially
affected
industries
because
the
number
of
affected
establishments
are
a
very
small
proportion
of
the
total
in
those
industries.
In
addition,
because
only
a
very
few
establishments
may
experience
potentially
significant
costs
in
each
industry,
the
rule
is
not
likely
to
result
in
price
increases
to
customers
of
the
affected
firms
or
other
indirect
economic
impacts.
Furthermore,
EPA
expects
that
States
implementing
the
SIP
call
will
take
these
potential
impacts
into
account
in
designing
their
implementation
scenarios.
Industries
with
potentially
significant
impacts
are
likely
candidates
to
be
excluded
from
control
requirements.
EPA
has
therefore
concluded
that
a
more
detailed
market­
level
impacts
analysis
is
not
needed
for
any
of
these
industries.

Table
7­
21
Number
of
Establishments
By
Establishment­
Level
Costs
as
a
Percentage
of
Value
of
Shipments/
Expenditures
and
Industry:
60%/$
5,000
SICIndustry/
Sector<
0.5
%
0.5­
1.0%
1­
3
%>
3%
TotalPercent
of
Establishments
in
SIP
Call
Region
Potentially
Affected
at
the
2­
digit
SIC
Code
Level10Metal
mining100010.614Non­
metal,
non­
fuel
mining/
quarrying
002350.220Food
and
kindred
products
mfgr.
35103390.421Tobacco
products
mfgr200021.622Textile
mill
products501170.124Lumber
&
wood
products,
exc.
furniture00011<
0.125Furniture
&
fixtures101240.126Paper
and
Allied
Products681773952.027Printing
&
publishing10102<
0.128Chemicals
&
allied
products581195831.029Petroleum
refining
and
related
industries18211221.630Rubber
&
plastics
products710190.132Stone,
Clay,
Glass
and
Concrete
Products46237430.533Primary
metals35522440.934Fabricated
metal
products,
exc.
machinery
&
trans.
equip.
41005<
0.135Industrial
&
commerical
machinery
&
computer
equip.
31138<
0.136Electronic
&
other
elec.
equip.,
exc.
computer
equip.
40004<
0.137Transportation
equipment11011130.238Measuring
instr.,
photo,
med
&
optical
goods;
clocks10001<
0.139Miscellaneous
manufacturing
industries11103<
0.149Electric,
gas
&
sanitary
services121422751231.251Wholesale
trade
­
nondurable
goods10012<
0.172
Personal
services00101<
0.179Amusement
and
recreation
services00101<
0.180Health
services30014<
0.189Miscellaneous
services10001<
0.1Colleges/
universities70007<
0.1Federal
government
anananana12naOther
government
a31116naTOTAL2866175111546<
0.1
b
Includes
natural
gas
transmission
establishments
(
SIC
4922)
and
electric
utilities
establishments
(
SIC
4911).
Utilities
having
non­
EGU
sources
affected
by
these
alternatives
have
co­
generation
units
that
supply
less
than
50%
of
generated
power
to
the
electric
power
grid.
aRevenues
not
available
for
one
"
other
government"
and
12
federal
government
establishments
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
104
7.2.3
Comparison
by
Regulatory
Alternative
Tables
7­
22
and
7­
23
provide
an
overview
of
economic
impacts
for
the
three
combinations
of
regulatory
alternatives
considered.
Table
7­
22
presents
results
at
the
firm
level,
and
Table
7­
23
shows
impacts
at
the
establishment
level.

Table
7­
22
Number
of
Firms
by
Firm
Costs
as
a
Percentage
of
Sales/
Expenditures
and
by
Regulatory
Alternative
<
0.5
%
0.5­
1.0%
1
­
3%>
3%
Sales
NA
aTotal40%/$
1,500208126649281Preferred
Alternative:
60%/$
5,000
20315684928170%/$
5,00019814101049281a
Sales
not
available
or
(
for
federal
government)
not
applicable.

Table
7­
23
Number
of
Establishments
by
Establishment­
Level
Costs
as
a
Percentage
of
Value
of
Shipments/
Expenditures
and
by
Regulatory
Alternative
<
0.5
%
0.5­
1.0%
1
­
3%>
3%
Sales
NA
aTotal40%/$
1,500333316610313546Preferred
Alternative:
60%/$
5,00028661751111354670%/$
5,000252668812713546a
Sales
not
available
or
(
for
federal
government)
not
applicable.

The
comparison
among
these
regulatory
alternatives
shows
a
modest
difference
in
potential
economic
impacts
between
the
preferred
alternative
and
either
the
least
or
most
stringent
combination
of
regulatory
alternatives
considered.
Only
two
additional
firms
and
17
additional
establishments
may
incur
costs
above
one
percent
of
sales/
expenditures
for
the
preferred
alternative
compared
to
the
least
stringent
regulatory
alternative.
Applying
the
most
stringent
regulatory
alternative
results
in
an
increase
of
six
firms
and
29
establishments
that
may
incur
costs
above
one
percent
of
sales/
expenditures
when
compared
to
the
preferred
alternative.

7.3
Small
Entity
Impacts
This
section
discusses
potential
impacts
on
small
entities
that
may
be
affected
by
requirements
related
to
the
NOx
SIP
call.
Since
States
are
ultimately
charged
with
achieving
reductions
to
meet
their
emissions
budgets,
they
should
seek
to
minimize
impacts
on
small
entities
to
the
maximum
extent
practicable.
In
this
analysis,
EPA
has
simulated
State
choices,
so
these
impacts
may
or
may
not
be
respresentative
of
actual
impacts
once
States
make
their
own
choices.
The
information
presented
in
this
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
105
section
may
assist
States
in
selecting
control
measures
that
minimize
small
entity
impacts.

Table
7­
24
shows
potential
small
entity
impacts
for
the
preferred
alternative
combination
and
the
other
two
regulatory
alternative
combinations
considered.

Table
7­
24
Number
of
Potentially
Affected
Small
Entities
by
Cost
as
a
Percentage
of
Sales/
Expenditures
by
Regulatory
Alternative
Regulatory
AlternativeTotal
Small
Entities
Potentially
Affected<
1%
1­
3%>
3%
40%/$
1,500362943Preferred
Alternative:
60%/$
5,00036274570%/%
5,000362457
This
comparison
shows
that
only
a
small
absolute
number
of
small
entities
is
predicted
to
incur
costs
above
one
percent
in
any
of
the
regulatory
alternatives.
In
addition,
the
preferred
alternative
only
results
in
2
additional
potentially
affected
small
entities
with
compliance
costs
greater
than
one
percent
of
firm/
entity
sales
or
revenues,
compared
to
the
least
stringent
regulatory
alternative.
States
should
carefully
select
control
measures
to
avoid
adverse
impacts
on
these
and
other
small
entities
to
the
extent
practicable.

The
maximum
number
of
potentially
affected
small
entities
that
may
be
significantly
impacted
under
the
preferred
alternative
is
9,
as
shown
in
Table
7­
24.
Table
7­
25
presents
the
industries
(
classified
by
4
digit
SIC
code)
that
have
potentially
affected
small
entities
with
compliance
costs
greater
than
one
percent
of
firm/
entity
sales
or
revenues
for
the
preferred
regulatory
alternative,
and
the
number
of
small
entities
in
each
industry
potentially
affected
at
this
level
of
impact.
This
calculation
excludes
entities
for
which
firm/
entitylevel
sales
or
revenues
are
not
available
(
41
entities)
and
which
could
not
be
classified
as
small
or
large
based
on
employment.
Some
of
these
firms
are
likely
to
be
small
but
the
Agency
can
not
estimate
how
many.

Table
7­
25
Potentially
Affected
Small
Entities
that
May
Incur
Compliance
Costs
of
Greater
Than
1
Percent
of
Sales/
Revenues
for
the
60%/$
5,000
Regulatory
Alternative
SIC
CodeDescription
of
Affected
IndustryNumber
of
Potentially
Affected
Small
Entities
in
Each
Affected
Industry2033Canned
fruit,
vegetables,
preserves,
jams,
jellies12075Soybean
oil
mills12434Wood
kitchen
cabinets12869Industrial
Organic
Chemicals,
n.
e.
c.
13241Cement,
hydraulic5
7.4
References
Abt
Associates,
1998.
Non­
Electricity
Generating
Unit
Economic
Impact
Analysis
for
the
NOx
SIP
Call
Draft
BART
RIA
Chapter
­
4/
12/
05
­
Deliberative
8­
106
RIA.
Prepared
for
the
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
September
1998.

Pechan­
Avanti
Group.
Ozone
Transport
Rulemaking
Non­
Electricity
Generating
Unit
Cost
Analysis.
Prepared
for
the
U.
S.
Environmental
Protection
Agency,
Office
of
Air
Quality
Planning
and
Standards,
September
1998.
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.
