1
The
specific
technology
is
simple
direct
duct
injection
dry
scrubbing.
EPA
Floor
option
regulatory
scenarios
(
i.
e.,
Floor
Option
1,
Floor
Option
2,
and
Floor
Option
3)
would
not
require
dry
scrubbers
and
would
therefore
incur
no
benefits
associated
with
SO2
reductions.

1
Hazardous
Waste
Combustion
MACT
Replacement
Standards:
Proposed
Rule
Assessment
of
Benefits
Associated
with
the
Beyond­
the­
Floor
Standard
for
TCl
from
Solid
Fuel
Boilers
Burning
Hazardous
Waste
We
have
identified
expected
reductions
in
sulfur
dioxide
(
SO
2)
emissions
from
coal
fired
boilers
as
a
result
of
the
Hazardous
Waste
Combustion
(
HWC)
MACT
replacement
standards.
The
HWC
MACT
standard
for
chlorine
under
the
"
Agency
Preferred
Approach"
regulatory
scenario
will
require
facilities
with
coal­
fired
(
i.
e.,
solid
fuel)
hazardous
waste
burning
boilers
to
install
flue
gas
desulfurization
(
i.
e.,
"
dry
scrubber")
technology.
1
In
addition
to
controlling
releases
of
chlorine,
dry
scrubbers
will
reduce
emissions
of
sulfur
dioxide
from
these
facilities.

This
Assessment
examines
anticipated
benefits
associated
with
SO
2
emissions
reductions
under
the
HWC
MACT
replacement
standards,
Agency
preferred
approach.
To
develop
a
range
of
potential
benefits
estimates
of
SO
2
reductions,
we
adjusted
published
national
estimates
of
SO
2
control
benefits
to
reflect
our
estimate
of
the
total
SO
2
emissions
(
tons/
year)
avoided
in
response
to
the
beyond­
the­
floor
(
BTF)
standard
for
chlorine
in
solid
fuel
boilers.
We
first
provide
two
estimates
of
benefits
based
on
extrapolation
from
available
literature.
We
then
incorporate
a
number
of
very
conservative
assumptions
to
provide
a
"
lower
bound"
estimate
of
benefits.
Finally,
we
discuss
the
primary
limitations
associated
with
our
analysis.

Sulfur
Dioxide
Emission
Reductions
Four
facilities
in
the
HWC
MACT
regulated
universe
have
solid
fuel
boilers.
These
facilities
are:
1)
Eastman
Chemical
Company
in
Tennessee
(
seven
boilers),
2)
Union
Carbide
in
West
Virginia
(
one
boiler),
3)
Celanese
Chemicals
in
Texas
(
two
boilers),
and,
4)
Eastman
Chemical
Company
facility
in
Arkansas
(
two
boilers).
None
of
the
boilers
at
these
facilities
are
currently
equipped
with
dry
scrubbers.

We
estimate
baseline
(
SO
2)
emissions
from
these
facilities
at
37,000
tons
per
year,
2
U.
S.
EPA,
2003,
Technical
Addendum:
Methodologies
for
the
Benefit
Analysis
of
the
Clear
Skies
Act
of
2003,
accessed
February
17,
2004,
at
<
http://
www.
epa.
gov/
clearskies/
tech_
addendum.
pdf>;
U.
S.
EPA,
2003,
Technical
Support
Document
for
the
Clear
Skies
Act
2003
Air
Quality
Modeling
Analysis,
accessed
February
17,
2002,
at
<
http://
www.
epa.
gov/
air/
clearskies/
aq_
modeling_
tsd_
csa2003.
pdf>;
U.
S.
EPA,
Benefits
of
the
Proposed
Inter­
State
Air
Quality
Rule,
accessed
February
17,
2004,
at
<
http://
www.
epa.
gov/
interstateairquality/
tsd0175.
pdf>.
In
addition,

2
reflecting
operating
requirements
under
test
conditions.
The
Texas
and
Arkansas
facilities
are
assumed
to
use
low
sulfur
coal
(
sulfur
content
of
0.6
percent),
and
the
West
Virginia
and
Tennessee
facilities
are
believed
to
use
eastern
coal
(
sulfur
content
ranging
from
one
to
five
percent,
with
an
average
value
of
2.5
percent).

Our
engineers
have
determined
that
the
installation
of
dry
scrubbers
for
required
control
of
HCl
(
beyond­
the­
floor
standard
of
the
agency
preferred
approach)
will
reduce
SO
2
emissions
by
60
percent,
or
22,000
tons
per
year.
Exhibit
1
summarizes
the
SO
2
emissions
reductions.

Exhibit
1
SUMMARY
OF
ESTIMATED
SO2
EMISSION
REDUCTIONS
Associated
with
the
AGENCY
PREFERRED
APPROACH
Beyond­
the­
Floor
Standard
for
TCl
­
Solid
Fuel
Boilers
Facility
Sulfur
Content
of
Coal
Baseline
SO2
Emissions
SO2
Emission
Reductions
SO2
Emissions
Under
Agency
Preferred
Approach
Eastman
Chemical
Co.,
Kingsport,
Tennessee
2.5%
26,130
15,680
10,450
Celanese
Chemicals,
Pampa,
Texas
0.6%
6,280
3,770
2,510
Union
Carbide,
South
Charleston,
West
Virginia
2.5%
4,000
2,400
1,600
Eastman
Chemical
Co.,
Batesville,
Arkansas
0.6%
550
330
220
TOTAL
36,960
22,180
14,780
Evaluation
of
Benefits
To
develop
initial
estimates
of
potential
benefits
associated
with
SO
2
emissions
reductions,
we
scale
existing
published
national
benefits
assessments
associated
with
SO
2
emissions
reductions
under
the
Clear
Skies
Initiative
and
the
Inter­
State
Air
Quality
Rule
(
IAQR).
2
As
we
examined
an
unpublished
draft
report
by
Carrothers
et
al.
(
2002),
which
estimates
national
exposure
to
PM
2.5
and
gaseous
precursors
from
coal­
fired
power
plants
and
mobile
sources.
The
report
then
estimates
benefits
associated
with
reduced
mortality
due
to
decreases
in
emissions.
Carrothers,
Timothy
J.,
Scott
K.
Wolff,
Jouni
Tuomisto,
Andrew
M.
Wilson,
Jonathan
I.
Levy,
John
D.
Graham,
John
D.
Graham,
John
S.
Evans,
2002,
Assessing
the
Economic
Value
of
Further
Research
about
Fine
Particle
Air
Pollution:
Model
Framework
and
Preliminary
Findings,
final
review
draft.

3
Note
that
this
is
a
conservative
assumption
because
in
general,
SO2
is
a
more
efficient
precursor
of
particulate
matter
than
nitrous
oxides.

4
These
estimates
reflect
the
average
of
a
range
of
discount
rates
and
scenarios.
Low
end
estimates
reflect
IAQR
study
near
term
benefits
using
a
seven
percent
discount
rate;
High­
end
estimates
reflect
Clear
Skies
study
longer
term
benefits
using
a
three
percent
discount
rate.
The
estimates
also
exclude
ozone­
related
benefits;
IAQR
study
estimated
total
benefits
(
including
ozone­
related
benefits)
at
$
54
to
$
84
billion;
the
Clear
Skies
study
estimated
total
benefits
(
including
ozone­
related
3
detailed
in
these
documents
and
other
literature,
a
significant
percentage
of
the
benefits
associated
with
the
control
of
SO
2
results
from
avoided
health
effects
associated
with
the
development
of
fine
particulate
matter
(
PM)
formed
by
SO
2
in
the
atmosphere.
The
Clear
Skies
Initiative
and
the
IAQR
both
examine
benefits
associated
with
reduction
in
PM
resulting
from
both
SO
2
and
nitrogen
(
NOx)
releases.

Our
preliminary
benefit
estimate
assumes
a
linear
relationship
between
quantity
of
sulfur
dioxide
controlled
and
monetary
benefits.
In
addition,
we
assume:


The
facilities
in
the
HWC
MACT
universe
are
similar
to
the
national
average
addressed
in
the
Clear
Skies
and
IAQR
analyses
in
terms
of
affected
populations
and
avoided
health
impacts.


The
relationship
between
benefits
and
quantity
of
SO
2
emissions
reduced
is
linear
even
at
relatively
small
quantities
(
i.
e.,
22,000
tons).


Where
benefits
related
to
particulate
matter
associated
with
SO
2
emissions
reductions
and
NOx
reductions
are
not
reported
separately,
the
relationship
between
benefits
is
proportional
to
the
quantity
of
pollutants
(
i.
e.,
if
SO
2
emissions
represent
50
percent
of
the
per
weight
pollutant
reductions,
then
they
represent
50
percent
of
the
benefits).
3
The
Clear
Skies
and
IAQR
analyses
each
predicted
a
total
reduction
in
SO
2
emissions
of
roughly
3.5
million
tons
and
NOx
reductions
of
1.5
million
tons.
The
total
benefits
associated
with
particulate
matter
reductions
were
estimated
at
$
51.5
to
$
109.3
billion
(
1999
dollars)
in
the
Clear
Skies
analysis
and
$
54.5
to
$
83.6
billion
(
1999
dollars)
in
the
IAQR
analysis.
4
benefits)
at
$
52
to
$
113
billion.

5
The
Clear
Skies
and
IAQR
total
predictions
(
SO2
plus
NOx)
of
approximately
5.0
million
tons/
yr
emissions
reductions
(
3.5/
5.0
=
70
percent).

4
Assuming
that
SO
2
emissions
reductions
represent
roughly
70
percent5
of
total
particulate
matter
benefits,
we
estimate
that
a
reduction
of
22,000
tons
of
SO
2
emissions
under
the
HWC
MACT
standards
would
incur
total
monetized
benefits
ranging
from
$
212
million
to
$
350
million
per
year.
This
result
reflects
a
"
dollar
per
ton"
range
of
$
9,700
to
$
15,900
for
benefits
per
ton
of
SO
2
removed.
If
only
mortality
is
included,
annual
monetized
benefits
would
range
from
$
193
million
to
$
320
million,
reflecting
a
"
dollar
per
ton"
range
of
approximately
$
8,800
to
14,600
for
benefits
per
ton
of
SO
2
removed.

Exhibit
2
provides
a
more
detailed
summary
of
the
range
of
potential
benefits
based
on
both
studies.
5
Exhibit
2
SUMMARY
OF
BENEFITS
ASSOCIATED
WITH
SO2
EMISSION
REDUCTIONS
Benefit
Category
IAQR
Analysis
(
million
1999$)
Clear
Skies
Analysis
(
million
1999$)

Total
Mortality
50,000
­
72,000
47,000
­
100,000
Total
Infant
Mortality
Benefits
130
­
180
 
Total
Other
Benefits
4,902
­
5,019
4,518
­
9,184
Total
Benefits
54,532
­
83,599
51,518
­
109,284
Total
SO2
Benefits
39,911
­
57,812a
34,478
­
73,255b
Total
Benefits
of
HWC
MACT
SO2
Reductions:
Agency
Preferred
Approach
(
based
on
22,000
tons/
yr)
c
Total
Benefits
(
millions)
$
247.4
­
$
332.9
$
212.4
­
$
350.0
Average
of
Total
Benefits
(
millions)
$
281.7
$
281.9
Total
Benefits,
per
Ton
(
dollars)
$
10,642
­
$
15,133
$
9,655
­
$
15,908
Average
of
Total
Benefits,
per
Ton
(
dollars)
$
12,808
$
12,814
Mortality
Benefits
Only
(
millions)
$
215.2
­
$
307.4
$
193.8
­
$
320.3
Average
of
Mortality
Benefits
Only
(
millions)
$
259.5
$
257.7
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
9,783
­
$
13,971
$
8,808
­
$
14,557
Average
of
Mortality
Benefits
Only,
per
Ton
(
dollars)
$
11,797
$
11,714
Notes:
a
Based
on
3.7
­
3.8
million
tons
SO2
avoided,
adjusted
to
exclude
28­
31%
NOx
contribution.
b
Based
on
3.6
­
4.6
million
tons
SO2
avoided,
adjusted
to
exclude
33%
NOx
contribution.
c
These
ranges
reflect
the
use
of
different
discount
rates,
time
frames,
and
assumptions
about
non­
mortality
benefits.
Low
end
estimates
reflect
near
term
mortality
benefits
only,
using
a
seven
percent
discount
rate;
highend
estimates
reflect
longer
term
total
benefits
using
a
three
percent
discount
rate.
6
Note
that
this
assumption
is
very
conservative
and
is
designed
solely
to
develop
a
lower
bound
estimate.
Because
boilers
are
designed
to
provide
power
for
other
facility
processes,
it
would
be
unusual
for
them
to
operate
at
levels
as
low
as
50
percent.
In
addition,
trial
burn
data
(
collected
as
part
of
the
RCRA
permitting
process)
were
used
to
identify
total
coal
requirements
for
boilers.
Trial
burns
are
typically
designed
to
reflect
maximum
hazardous
waste
combustion.
Because
SO2
is
associated
with
the
supplemental
fuel
coal
(
and
not
with
hazardous
waste),
it
is
possible
that
trial
burn
data
may
understate
baseline
SO2
emissions
if
normal
operations
involve
less
hazardous
waste
and
more
coal.

6
Lower
Bound
Estimate
of
Benefits
In
addition
to
the
estimates
based
on
a
simple
extrapolation
of
Clear
Skies
and
IAQR
analyses,
we
have
developed
a
conservative
lower­
bound
estimate
of
potential
benefits
(
mortality
only)
associated
with
SO
2
emissions
reductions
resulting
from
the
BTF
TCl
level
for
solid
fuel
boilers.
This
estimate
includes
only
emissions
reductions
from
the
Tennessee
Eastman
facility
and
makes
the
following
conservative
assumptions:


The
facility
uses
only
coal
with
a
low
sulfur
content
of
one
percent
(
initial
estimate
is
based
on
sulfur
content
of
2.5
percent);


The
facility
operates
boilers
at
50
percent
of
the
intensity
reflected
in
the
trial
burn
data
(
initial
estimate
assumes
that
boilers
operate
as
continuous
process
equipment
at
90
percent
of
annual
trial
burn
capacity);
and
6

The
low­
end
benefit
estimate
of
$
8,808
per
ton
of
SO
2
eliminated
accurately
reflects
regional
benefits
in
northeastern
Tennessee.

The
resulting
reductions
in
SO
2
emissions
from
the
facility
are
therefore
3,100
tons
per
year
rather
than
15,680
tons
per
year.
Under
these
lower­
bound
assumptions,
we
estimate
annual
benefits
of
roughly
$
27
million
associated
with
SO
2
emission
reductions.
This
reflects
only
the
Eastman
Tennessee
facility
and
does
not
consider
any
benefits
associated
with
the
remaining
three
facilities
with
coal­
fired
hazardous
waste
boilers.

Key
Limitations:

This
assessment
incorporates
various
key
assumptions
and
limitations.
These
include:


the
affected
populations
for
each
of
the
facilities
of
concern
are
assumed
to
be
generally
consistent
with
populations
affected
by
facilities
examined
in
the
Clear
Skies
and
IAQR
analyses,
7

the
boiler
operation
and
stack
heights
of
the
facilities
of
concern
are
generally
representative
of
the
boilers
and
stack
heights
at
the
facilities
examined
in
the
Clear
Skies
and
IAQR
analyses,


the
linear
extrapolation
of
national­
level
SO
2
reduction
benefits
is
reasonable
for
quantities
of
roughly
20,000
tons;
and

baseline
emissions
estimates
used
in
this
analysis
reflect
current
emissions
for
each
of
the
facilities
of
concern.
