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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

petroleum refineries

kraft pulp mills

portland cement plants

hydrofluoric, sulfuric, and nitric acid

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

iron and steel mills

coke oven batteries

sulfur recovery plants

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

lime kilns

glass fiber processing plants

municipal incinerators ( 250 tons refuse burn capacity or greater)

coal cleaning plants ( thermal dryers)

carbon black plants ( furnace process)

phosphate rock processing plants

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

primary lead smelters

primary copper smelters

primary zinc smelters

fuel conversion plants

sintering plants

taconite ore processing plants

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

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

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

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

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

Option 1 7% $ 26.0 $ 807

3% $ 47.8 $ 727

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

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

Option 1 7% $ 48.6 $ 722

3% $ 87.2 $ 779

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

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

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

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

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

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

Option 1 7% $ 1.9 $ 906

3% $ 12.5 $ 736

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

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

Option 1 7% $ 2.3 $ 570

3% $ 2.7 $ 595

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

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

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

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

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

Option 1 7% $ 20.7 $ 587

3% $ 45.6 $ 849

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

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

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

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

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

Option 1 7% $ 2.9 $ 150

3% $ 20.8 $ 674

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

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

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

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

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

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

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

Option 1 7% $ 9.8 $ 287

3% $ 9.1 $ 268

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

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

Option 1 7% $ 8.2 $ 726

3% $ 7.3 $ 646

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

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

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

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

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

Option 1 7% $ 14.4 $ 601

3% $ 21.1 $ 776

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

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

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

Option 1 7% $ 0.6 $ 579

3% $ 0.4 $ 431

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

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

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

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

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

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

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

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

Option 1 7% $ 0.0 $ 0

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

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

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

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

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

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

Option 1 7% $ 11.6 $ 847

3% $ 11.6 $ 849

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

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

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

Option 1 7% $ 0.1 $ 519

3% $ 0.1 $ 400

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

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

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

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

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

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

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

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

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

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

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

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

Option 1 7% $ 0.0 $ 740

3% $ 0.0 $ 509

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

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

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

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

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

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

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

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

Option 1 7% $ 2.0 $ 745

3% $ 4.3 $ 953

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

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

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

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

Option 1 7% $ 0.5 $ 937

3% $ 0.7 $ 880

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

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

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

Option 1 7% $ 0.0 $ 0

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

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

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

3% $ 0.0 $ 830

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

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

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

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

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

Option 1 7% $ 0.0 $ 760

3% $ 0.0 $ 511

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

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

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

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

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

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

BART Source Category Interest Rate Illustrative Regulatory Options Option 1 Option 2 Option 3 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 64 Industrial Boilers 7% $ 74.6 527.6 845.4 3% 135.0 401.8 643.3 Petroleum Refineries 7% 4.2 180.2 428.6 3% 15.3 214.8 394.8 Kraft Pulp Mills 7% 20.7 141.7 313.3 3% 45.6 106.3 168.5 Portland Cement Plants 7% 2.9 174.8 409.5 3% 20.8 269.0 346.1 Hydrofluoric, Sulfuric, and Nitric Acid Plants 7% 18.0 23.4 23.4 3% 16.4 21.4 21.4 Chemical Process Plants 7% 14.4 70.8 87.8 3% 21.1 54.4 77.1 Iron and Steel Mills 7% 0.6 23.5 33.2 3% 0.4 22.7 32.4 Coke Oven Batteries 7% 0.0 18.7 33.8 3% 0.0 14.9 25.0 Sulfur Recovery Plants 7% 11.7 12.1 12.1 3% 11.7 12.1 12.1 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 65 Primary Aluminum Ore Reduction Plants 7% 1.7 7.76 7.82 3% 1.0 5.0 5.0 Lime Kilns 7% 2.0 5.0 31.8 3% 4.3 25.4 25.4 Glass Fiber Processing Plants 7% 0.5 5.3 7.8 3% 0.7 4.8 6.8 Municipal Incinerators 7% 0.0 1.1 1.1 3% 0.0 0.9 0.9 Coal Cleaning Plants 7% 0.0 1.0 1.0 3% 0.0 0.8 0.8 Carbon Black Plants 7% 0.01 0.2 0.2 3% 0.005 0.1 0.1 Phosphate Rock Processing Plants 7% 0.0 0.1 0.2 3% 0.0 0.2 0.2 Secondary Metal Production Facilities 7% 0.02 0.04 0.1 3% 0.0 0.0 0.0 TOTALS: 7% $ 151.43 $ 1,193.24 $ 2,237.24 3% $ 272.34 $ 1,157.09 $ 1,770.21 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 66 8.6 Caveats and Limitations of the Analyses There are a number of caveats and limitations associated with these analyses. They are:

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

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

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

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

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

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

Control programs implemented as command and control regulation, as this analysis models controls to affected non EGU sources, will lead to less induced technological innovation Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 67 when compared to a market incentives based approach ( e. g., a cap and trade program).

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

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

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

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

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

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