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The document was marked with 804 Deletions, 857 Insertions, 0 Moves. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 2 Chapter 8. RESULTS OF COST, EMISSIONS REDUCTIONS, AND ECONOMIC IMPACT ANALYSES FOR NON ELECTRICITY GENERATING UNITS This chapter presents the results of the cost and economic impact analyses for the non EGU sources in BART source categories covered in these analyses. The cost and economic impact analyses ( including potential impacts to small entities and public sector entities) evaluate the potential impacts associated with the final BART rule, based on assumptions about how the States may implement controls for non EGU sources. As mentioned in Chapter 3, there are 25 non EGU source categories that are to be considered for controls associated with the BART program. Section 8.1 presents the average costeffectiveness of controls applied for these sourcesa short summary of the results of the impact analyses. Section 8.2 presents a description of the methodological approach for these cost analyses, the options that are analyzed, and important assumptions and details that underlie the costs and emission reductions for each option. Section 8.3 mentions the control technologies that are applied to the non EGU source categories in this analysis. Section 8.2 presents the marginal cost effectiveness4 provides a list of the source categories affected and summaries of analysis results by BART source category. Section 8.5 provides summaries of the results of these analyses across sources categories. Section 8.6 presents a listing of caveats and limitations associated with the alternatives analyzed. Section 8.3 describes the potential economic impacts of the preferred option and selected other options, and Section 8.4 analyzes the potential impacts on small entities in particular. The economic impact sections focus on detailed results for the medium strigency option and provides a brief comparison with the range of results for other options considered. cost analyses. More detailed results for the other options considered are provided in the economic impacttechnical support document for these analysies report ( RTI( E. H. Pechan, 2005).) Finally, references for the chapter are provided in Section 8.57.

8.1 Results in Brief The results for applying the alternativesoptions examined for control of 2015 SO2SO2 and NoOx emissions at non EGU BART eligible units range from 83,778 tons to 378,169 tons of SO2 toSO2 and 165,634 tons to 391,101 tons of NOx nationwide. Annual for costs annualized at a 7 percent interest rate. For costs annualized at a 3 percent interest rate, the reduction of SO2 emissions in 2015 range from 132,279 tons to 373,797 tons and the reduction of NOx emissions in 2015 range from 246,607 tons to 393,349 tons. Annualized costs associated with these reductions in 2015 range from $ 151.43 million to $ 2.24 billion ( 1999$).

8.2 Compliance Costs and Cost Effectiveness In this RIA, three regulatory alternatives are analyzed for non EGU for costs estimated at a 7 percent interest rate and from $ 272.23 million to $ 1,770.21 million ( 1999$) for costs estimated at a 3 percent interest rate. The capital costs associated with these reductions in 2015 ranges from $ 655.70 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 1 Analysis of sources in the trading program consider trading occuring across the entire SIP call region. Analysis of non EGU sources considers at the source level the application of controls at the source category level up to a specified average cost per ton cutoff.

8 3 million to $ 14.75 billion for costs estimated at a 7 percent interest rate and from $ 1,881.70 million to $ 12.73 billion.

8.2 Costs and Analysis Approach In this RIA chapter, three illustrative regulatory options are applied to non EGU BART eligible sources. Costs and emissions reductions for these sources are estimated for these annualannualized cost per ton alternativesoptions for reducing SO2SO2 and NoOx at varying levels of stringency: $ 1,000, $ 4,000, and $ 10,000.1 The $ 1,000/ ton alternative is called the " low"" least stringency alternativet" option, the $ 4,000/ ton alternative is the " medium" stringency alternativet" option, and the $ 10,000/ ton alternative is the " high"" most stringency onet" option. These alternativesoptions are applied nationwide. For purposes of consistency with the descriptions for the EGU options, the " least stringent" option is called Option 1, the " medium stringent" option is called Option 2, and the " most stringent" option is called Option 3. These options are meant to be illustrative of the potential control options that may be available to States as they consider what scenarios to include in their State Implementation Plans ( SIPs) for non EGU sources. These options are also compliance with the requirement in OMB Circular A 4 to examine alternative levels of stringency as part of an RIA.

The potential costs of complying with the BART rule have two elements: implementation ( the cost of emissions control), and administration ( the cost of monitoring emissions, and the associated administrative costs ofestimated in this chapter are those from installation, operation, and maintenance of control device that may be applied in response to the provisions of SIP) that may require controls of these non EGU sources. In addition to these analyses, results from analyses in which important components of the costs such as interest rates, labor rates, and energy rates are varied to determine the sensitivity of the costs to such variation. We present such results in Appendix B. Costs from monitoring, recordkeeping, and reporting.) The calculation of administration costs is presented later in Section 8_ are not included in this cost analysis since these costs are accounted for in the Regional Haze ICR.

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

For each affected source category, EPA's estimates of emissions reductions and compliance costs reflect the application of controls within AirControlNET, the Agency's tool for estimating impacts from control strategies applied to non EGU criteria pollutant sources. AirControlNET can estimate costs and emission reductions from control strategies for various average cost effectiveness levels and for varying Draft BART RIA Chapter  4/ 12/ 05  Deliberative 2 For more information on the emissions and control measures within AirControlNET, go to www. epa. gov/ ttn/ ecas/ AirControlNET. htm. Documentation for emissions data and control measures can be found at this Web site.

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

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

Presented below are results for eachthe 2015 emissions inventory which is a product of growing the emissions from the non EGU dataset, a database with 2001emissions in it. The procedure for growing the emissions in that database to 2015 is also described in Chapter 3.

Costs presented in this chapter are estimated at a 7 percent and also a 3 percent interest rate for purposes of annualization of capital costs. Incorporating a 7 percent interest rate is consistent with OMB Circular A 94, issued on October 29, 1992. The use of a 3 percent interest rate allows for a comparison of the costs with the discount rate that underlies the benefits estimates for purposes of social cost and benefit comparison. Equipment lives and control efficiencies for each control technology are taken from the AirControlNET control measures documentation report. Annual costs are estimated in 1999 dollars. All costs are converted from the original source year to 1999 dollars using the Gross Domestic Product ( GDP) price deflator.

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

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

In general, Flue Gas Desulfurization ( FGD) scrubbers are applied most commonly as the control technology for industrial boilers and many other non EGU sources due to its possible application to most any industrial boiler and other combustion source application. Other issues involved in choosing a control technology include ease of retrofit and reduction performance. While all controls presented in this analysis are considered generally technically feasible for each class of sources, source specific cases may exist where a control technology is in fact not technically feasible. In their response to the BART rule, States may wish to consider case specific feasibility when establishing control requirements. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 5 <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 category impacted in the analysescategories, there are other types of control technologies available that are more specific to the sources controlled. Table 8 1 lists these technologies. For more information on these technologies, please refer to the AirControlNET 4.0 control measures documentation report.

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

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

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

In general, low NOx burners ( LNB) is often applied as a control technology for industrial boilers and many other non EGU sources due to its possible application to almost any industrial boiler and other combustion source application. Other issues involved in choosing a control technology include ease of retrofit and reduction performance. While all controls presented in this analysis are considered generally technically feasible for each class of sources, source specific cases may exist where a control technology is in fact not technically feasible. In their response to the BART rule, States may wish to consider case Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 6 specific feasibility when establishing control requirements.

<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.

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 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 7 mills, and cement kilns among others. NOx control technology available for petroleum refineries, particularly process heaters at these plants, includes LNB, SNCR, FGR, and SCR along with combinations of these technologies. NOx control technology available for kraft pulp mills includes those available to industrial boilers, namely: LNB, SCR, SNCR, along with WI. NOx control technology available for cement kilns includes those available to industrial boilers, namely: LNB, SCR, SNCR. In addition, mid kiln firing ( MKF) and ammonia based SNCR can be utilized on cement kilns where appropriate. Table 8 3 lists the control technologies available for these categories. For more information on these technologies, please refer to the AirControlNET 4.0 control measures documentation report.

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

8.4 Listing of Affected Source Categories and Results For Each We present below results for each BART source category impacted in the analyses. Results presented here reflect the use of 7 percent and 3 percent interest rates as part of the control strategy analysis for each option. There are no impacts for 8 of the 25 non EGU source categories because there are no control measures available to reduce SO2SO2 and NoOx from these categories within Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 8 AirControlNET.

8.1There are seven source categories for which only NOx reductions take place in these analyses due to there being no control measures available within AirControlNET or no controls available at $ 10,000/ ton ( or Option 3) or below. Finally, there are 10 source categories for which both SO2 and NOx reductions take place in these analyses. The first 10 source categories for which impacts are presented those for which both SO2 and NOx reductions take place in these analyses. These BART source categories are:

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

petroleum refineries

kraft pulp mills

portland cement plants

hydrofluoric, sulfuric, and nitric acid

chemical process plants

iron and steel mills

coke oven batteries

sulfur recovery plants

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

lime kilns

glass fiber processing plants

municipal incinerators ( 250 tons refuse burn capacity or greater)

coal cleaning plants ( thermal dryers)

carbon black plants ( furnace process)

phosphate rock processing plants Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 9

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

primary lead smelters

primary copper smelters

primary zinc smelters

fuel conversion plants

sintering plants

taconite ore processing plants

petroleum storage and transfer facilities 8.4.1 Results for Industrial Boilers Table 8 14 shows the SO2 emissions reductions achieved in the analyses for each illustrative regulatory alternativeoption. Besides the standard BART eligibility criteria mentioned in Chapter _. 3, boilers that are BART eligible are those with heat input design capacities of 250 mmBTU/ hr or greater and and are fossil  fueled. The table indicates that the alternativesoptions achieve incremental reductions from the 2015 baseline ranging from _% to _%.

Table 8 1 2015 SO28 to 48 percent given a 7 percent interest rate for the costs, and from 16 to 49 percent for costs at a 3 percent interest rate.

Table 8 4 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Non EGU Industrial Boilersa Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 10 Illustrative Regulatory AlternativebOpti onsb Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ tonOption 1 420,782 7% 388,569 32,213 $ 4,000/ ton 420,782 3% 354,999 65,783 Option 2 420,782 7% 269,395 151,387 $ 10,000/ ton 420,782 3% 256,344 164,438 Option 3 420,782 7% 220,474 200,308 420,782 3% 216,565 204,217 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 5 presents the NOx baseline emissions and reductions for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 32 percent to 60 percent for costs at a 7 percent interest rate, and from 52 to 60 percent for costs at a 3 percent interest rate.

Table 8 25 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU Industrial Boilersa Illustrative Regulatory AlternativebOpti ons Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 11 $ 1,000/ tonOption 1 217,063 7% 149,738 67,325 $ 4,000/ ton 217,063 3% 105,124 111,939 Option 2 217,063 7% 86,607 130,456 $ 10,000/ ton 217,063 3% 86,639 130,424 Option 3 217,063 7% 86,541 130,522 217,063 3% 86,558 130,505 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 36 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each regulatory alternativeoption, and marginal costs between each alternativeillustrative regulatory option for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million$ 26 million to $ 610 million with costs at a 7 percent interest rate, and from $ 48 million to $ 505 million with costs at a 3 percent interest rate. The accompanying average annualized cost effectiveness results range from $ 1,243$ 807 to $ 23,140 per ton.

Table 8 3047 per ton with costs at a 7 percent rate and from $ 727 to $ 2,471 per ton with costs at a 3 percent rate. In addition, the marginal costs range from $ 2,250 to $ 6,463 per ton with costs at a 7 percent interest rate and from $ 2,202 to 6,023 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect FGD scrubbers applied to all of these units. The average and marginal costs rise as a result of FGD scrubbers being applied to more coal fired units with lower sulfur contents and to oil fired units that have lower sulfur contents than coal fired units. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 12 Table 8 6 2015 Cost and Cost Effectiveness Results for SO2SO2 Control at Non EGU BART eligible Industrial Boilers Illustrative Regulatory AlternativeO ptions Annual Control Cost ( million 1999$) Annual Monitoring and Administrativ e Costs ( million 1999$) Interes t Rate Total AnnualAnnualized Costs ( million 1999$) Annual Cost Effectiveness ($/ ton) MarginalAn nualized Average Cost Effectiveness ($/ ton) $ 1,000/ tonMarginal Costs ($/ ton)

Option 1 7% $ 26.0 $ 807

3% $ 4,000/ ton$ 47.8 $ 727

Option 2 7% 294.1 1,943 $ 2,250 3% 265.0 1,612 2,202 Option 3 7% 610.3 3,047 $ 6,463 3% 504.6 2,471 $ 106,000/ ton023 Table 8 47 shows the annualannualized costs, resulting annualannualized average costeffectiveness for each illustrative regulatory alternative3option, and marginal costs between each alternative.

Table 8 4illustrative regulatory option for NOx control. The annualized control costs range from $ 48.6 million to $ 235.1 million with costs at a 7 percent rate, and from $ 87.2 million to $ 138.7 million with costs at a 3 percent rate. The accompanying annualized average cost effectiveness results range from $ 722 to $ 1,801 per ton with costs at a 7 percent rate, and from $ 779 to $ 1,063 per ton with costs at a 3 percent rate. In addition, the marginal costs range from $ 2,929 to $ 24,242 per ton with costs at a 7 percent rate, and from $ 2,684 to $ 22,840 per ton with costs at a 3 percent rate.

The average and marginal costs increase as the options become more stringent due to additional application of SCR. SCR is the most expensive NOx control device available to industrial boilers in our Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 13 analysis, though they also have a high control level ( 80 percent).

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

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

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

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

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

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

Table 8 6 2015 SO21 percent to 28 percent for costs estimated at a 7 percent interest rate, and from 9 percent to 29 percent for costs estimated at a 3 percent interest rate. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 15 Table 8 9 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Petroleum Refineriesa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ tonOption 1 388,56932,213199, 483 $ 4,000/ ton269,3957 % 1591,387386 2,097 $ 10,000/ ton220 199,483 3% 182,450 17,033 Option 2 199,483 7% 168,164 31,319 199,483 3% 157,572 41,911 Option 3 199,483 7% 143,021 56,462 199,483 3% 140,958 58,525 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, 474200,308 Table 8 7 both controlled and uncontrolled.

Table 8 10 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 5 to 59 percent for costs estimated at a 7 percent interest rate, and from 6 to 60 percent for costs estimated at a 3 percent interest rate.

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

Table 8 811 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each illustrative regulatory alternativeoption, and marginal costs between each alternativeoption for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million$ 1.9 million to $ 223.5 million with costs at a 7 percent interest rate, and from $ 12.5 million to $ 167.3 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 1,243$ 906 to $ 2,140 per ton.

Table 8 8$ 3,958 per ton with costs at a 7 percent interest rate, and from $ 736 to $ 2,858 per ton with costs at a 3 percent interest rate . In addition, the marginal costs range from $ 1,783 to $ 6,741 per ton with costs at a 7 percent interest rate, and from $ 2,417 to $ 5,692 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect FGD scrubbers applied to all of these units. The average and marginal costs rise as a result of FGD scrubbers being applied to units such as fluid catalytic cracking units ( FCCUs) with lower sulfur contents. As sulfur content of the fuel for a units decreases, the cost per ton of control increases and vice versa. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 17 Table 8 11 2015 Cost and Cost Effectiveness Results for SO2SO2 Control at Non EGU BART eligible Units at Petroleum Refineries Illustrative Regulatory AlternativeOpti ons Annual Control Cost ( million 1999$) An nual Monitorin g and Administr ative Costs ( million 1990$) Inte rest Rate Total AnnualAnnualiz ed Costs ( million 19909$) Annual Cost Effectiveness ($/ ton) Margin alAnnualized Average Cost Effectiveness ($/ ton) $ 1,000/ tonMarginal Costs ($/ ton)

Option 1 7% $ 1.9 $ 906

$ 4,000/ ton 3% $ 10,000/ ton$ 12.5 $ 736

Option 2 7% 54.0 1,724 $ 1,783 3% 72.7 1,734 2,417 Option 3 7% 223.5 3,958 6,741 3% 167.3 2,858 5,692 Table 8 912 shows the annualannualized costs, resulting annualannualized average costeffectiveness for each regulatory alternative5option, and marginal costs between each alternative.

Table 8 9option for NOx control. The annualized control costs range from $ 2.3 million to $ 205.1 million with costs at a 7 percent interest rate, and from $ 2.7 million to $ 227.6 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 570 to $ 3,997 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 18 per ton with costs at 7 percent interest rate, and from $ 595 to $ 4,294 per ton with costs at a 3 percent interest rate. In addition, the marginal costs range from $ 2,917 to $ 20,984 per ton with costs at a 7 percent interest rate, and from $ 2,986 to $ 48,969 per ton with costs at a 3 percent interest rate.

The average and marginal costs rise as a result of additional process heaters having to apply LNB + SNCR. In most cases, the average cost per ton of control is between $ 4,000 and $ 5,000 per ton.

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

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

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

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

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

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

0 to 24 percent for costs at a 7 percent interest rate, and from 0 to 12 percent for costs at a 3 percent interest rate.

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

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

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

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

Table 8 16 2015 SO234 percent to 63 percent for costs at a 7 percent interest rate, and from 52 to 63 percent for costs at a 3 percent interest rate.

Table 8 15 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Portland Cement PlantsaKraft Pulp Millsa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 24 $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 17 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Portland Cement Plantsa Regulatory AlternativebNumber of Affected Sources2015 Baseline Emissions2015 Post Control Emissions2015 Emission Reductions$ 1,000/ t on217,063149Optio n 1 103,614 7% 68,365 35,249 103,614 3% 49,885 53,729 Option 2 103,614 7% 42,196 61,418 103,614 3% 37,822 65,792 Option 3 103,614 7% 37,738838 6765,776 103,614 3% 37,325$ 4,000/ ton21 7,06386,607827 13065,456$ 10,000/ t on217,06386,54113 0,522797 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 25 Table 8 316 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each illustrative regulatory alternativeoption, and marginal costs between each alternativeoption for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million.$ 0 million to $ 161.5 million with costs at a 7 percent interest rate, and from $ 0 million to $ 69.0 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 1,243 to $ 2,140 per ton.

Table 8 18$ 0 to $ 5,691 per ton with costs at a 7 percent interest rate, and from $ 0 to $ 4,720 per ton with costs at a 3 percent interest rate. In addition, the marginal costs range from $ 3,098 to $ 7,287 per ton with costs at a 7 percent interest rate, and from $ 2,189 to $ 5,432 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect FGD scrubbers applied to all of these units. The average and marginal costs rise as a result of FGD scrubbers being applied to units for which the application is more expensive ($ 6,000 to $ 10,000 per ton).

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

Option 1 7% $ 0.0 $ 0

$ 4 3% $ 0.0 $ 0

Option 2 7% 33.5 3,098 $ 3,098 3% 7.0 2,189 2,189 Option 3 7% 161.5 5,691 7,287 3% 69.0 4,000/ ton720 5,432 $ 10,000/ ton Table 8 197 shows the annualannualized costs, resulting annualannualized average costeffectiveness for each illustrative regulatory alternative9option, and marginal costs between each alternative.

Table 8 19illustrative regulatory option for NOx control. The annualized control costs range from $ 20.7 million to $ 151.8 million with costs at a 7 percent interest rate, and from $ 45.6 million to $ 99.8 million with costs at a 3 percent rate. The accompanying annualized average cost effectiveness results range from $ 587 to $ 2,308 per ton with costs at a 7 percent interest rate, and from $ 849 to $ 1,512 per ton with costs at a 3 percent interest rate. In addition, the marginal costs range from $ 3,344 to $ 10,005 per ton with costs at a 7 percent interest rate, and from $ 4,452 to $ 35,800 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect greater applications of SCR as the cost per ton cap rises, particularly for sulfite pulping recovery furnaces. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 27 Table 8 17 2015 Cost and Cost Effectiveness Results for NOx Control at non EGU BART eligible Units at Portland Cement PlantsKraft Pulp Mills Illustrative Regulatory Alternative Options Annual Control Cost ( million 1990$) Annu al Monitoring and Administrati ve Costs ( million 1990$) Intere st Rate Total AnnualAnnual ized Costs ( million 19909$) Annual Cost Effectiveness ($/ ton) MarginalAnnual ized Average Cost Effectiveness ($/ ton) $ 1,000/ tonMarginal Cost ($/ ton)

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

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

Table 8 21 shows theTable 8 18 shows the total annualized costs of each illustrative regulatory option for control of both SO2 and NOx.

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

Option 1 7% $ 20.7 3% $ 45.6 Option 2 7% 141.7 3% 106.3 Option 3 7% 313.3 3% 168.5 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 30 8.4.4 Results for Portland Cement Plants Table 8 19 shows the SO2 emissions reductions achieved in the analyses for each illustrative regulatory alternativeoption. The table indicates that the alternativesoptions achieve incremental reductions from the 2015 baseline ranging from _% to _%.

Table 8 21 2015 SO2 Baseline Emissions and Emission Reductions for Non EGU BART Eligible Units at Hydrofluoric, Sulfuric, and Nitric Acid Plantsa Regulatory AlternativebNumber of Affected Sources2015 Baseline Emissions2015 Post Control Emissions2015 Emission Reductions$ 1,000/ ton388,56932,213$ 4,000/ ton269,395151,387$ 10,000/ ton220,474200,308 Table 8 22 2015 NOx0 percent to 23 percent for costs at a 7 percent interest rate, and from 0 to 26 percent for costs at a 3 percent interest rate.

Table 8 19 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Hydrofluoric, Sulfuric, and Nitric AcidPortland Cement Plantsa Illustrative Regulatory AlternativebNumb er of Affected SourcesOptions 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ tonOption 1 116,835 7% 116,835 0 217116,835 3% 116,835 0 Option 2 116,835 7% 103,063452 13,383 116,835 3% 98,509 18,326 Option 3 149116,835 7% 90,119 26,73867,325716 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 31 116,835 $ 4,000/ ton217,0633 % 86,607145 13030,456$ 10,000/ t on217,06386,54113 0,522690 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

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

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

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

Table 8 26 2015 SO216 percent to 60 percent for costs at a 7 percent interest rate, and from 26 to 60 percent for costs at a 3 percent interest rate.

Table 8 20 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Chemical ProcessPortland Cement Plantsa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources201 5 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 33 $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 27 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Chemical Process Plantsa Option 1 120,567 7% 101,289 19,276 120,567 3% 89,664 30,903 Option 2 Regulatory Alternativeb Number of Affected Sources201 5 Baseline Emissions1 20,567 7% 65,966 54,601 2015 Post Control Emissions2015 Emission Reductions$ 1,000/ t on217,063149,7386 7,325$ 4,000/ ton217 ,06386,607130,456 $ 10,000/ ton217,063 86,541130,522 120,567 3% 48,646 71,921 Option 3 120,567 7% 48,646 71,921 120,567 3% 48,646 71,921 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 34 Table 8 281 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each illustrative regulatory alternativeoption, and marginal costs between each alternativeillustrative regulatory option for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million.$ 0 to $ 134.4 million with costs at a 7 percent interest rate, and from $ 0 to $ 126.8 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 1,243$ 0 to $ 25,140 per ton.

Table 8 28031 per ton with costs at a 7 percent interest rate, and from $ 0 to $ 4,131 per ton with costs at a 3 percent interest rate. In addition, the marginal costs range from $ 3,250 to $ 6,818 per ton with costs at a 7 percent interest rate, and from $ 2,710 to $ 6,816 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect FGD scrubbers applied to all of these units. The average and marginal costs rise as a result of FGD scrubbers being applied to more units with lower sulfur content fuels.

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

Option 1 7% $ 0.0 $ 0

$ 4 3% $ 0.0 $ 0

Option 2 7% 43.5 3,250 $ 3,250 3% 49.7 2,710 2,710 Option 3 7% 134.4 5,031 6,818 3% 126.8 4,000/ ton131 6,816 $ 10,000/ ton Table 8 292 shows the annualannualized costs, resulting annualannualized average costeffectiveness for each illustrative regulatory alternative13option, and marginal costs between each alternative.

Table 8 29illustrative regulatory option for NOx control. The annualized control costs range from $ 2.9 million to $ 275.1 million with costs at a 7 percent interest rate, and from $ 20.8 million to $ 219.3 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 150 to $ 3,825 per ton with costs at a 7 percent interest rate, and from $ 674 to $ 3,050 per ton with costs at a 3 percent interest rate. In addition, the marginal costs range from $ 3,632 to $ 7,731 per ton with costs at a 7 percent interest rate, and $ 4,893 per ton with costs at a 3 percent interest rate between the $ 1,000/ ton and the $ 4,000/ ton option. There is no marginal costs between the $ 4,000/ ton and $ 10,000/ ton options with costs at the 3 percent interest rate since there is no difference in the impacts of the options.

The average and marginal costs of control increase as more SCR applications take place as the cost per ton cap rises. These applications take the place of less expensive but less effective controls such Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 36 as mid kiln firing.

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

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

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

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

Annual Cost Effectiveness ($/ ton) Option 1 Marginal Cost Effectiveness ($/ ton) 7% $ 1,000/ ton$ 86$ 2.9 $ 12.4 3% $ 99$ 20.8 Option 2 7% 174.8 3% 269.0 Option 3 $ 1,203$ 4,000/ ton867% 409.91 3.31 00.21 ,2135 $ 10,000/ ton3% 87346.1 13.3100.41,215 Table 8 31 shows the 8.3.5 Results for Hydrofluoric, Sulfuric, and Nitric Acid Plants Table 8 24 shows the SO2 emissions reductions achieved in the analyses for each illustrative regulatory alternativeoption. The table indicates that the alternativesoptions achieve incremental reductions from the 2015 baseline ranging from _% to _%.

Table 8 31 2015 SO235 to 38 percent for costs at a 7 percent interest rate, and the same for costs at a 3 percent interest rate. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 38 Table 8 24 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at IronHydrofluoric, Sulfuric, and Steel MillsaNitric Acid Plantsa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 32 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Iron and Steel Millsa Regulatory AlternativebNumber of Affected Sources2015 Baseline Emissions2015 Post Control Emissions2015 Emission Reductions$ 1,000/ t on217,063Option 1 96,741 7% 62,601 34,140 96,741 3% 62,601 34,140 Option 2 96,741 7% 60,188 36,753 96,741 3% 60,188 36,753 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 39 Option 3 14996,73867,325$ 4 ,000/ ton217,06386, 607130,456$ 10,000 / ton217,06386,5417 41 1307% 60,522188 36,753 96,741 3% 60,188 36,753 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 33 shows the annual costs , resulting average annual cost effectiveness for each regulatory alternative, and marginal costs between each alternative for SO2 control. The annual control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million. The accompanying average cost effectiveness results range from $ 1,243 to $ 2,140 per ton.

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

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

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

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

Table 8 25 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Coke Oven BatteriesaHydrofluoric, Sulfuric, and Nitric Acid Plantsa Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 41 Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 37 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Coke Oven Batteriesa Regulatory AlternativebNumber of Affected Sources2015 Baseline Emissions2015 Post Control Emissions2015 Emission ReductionsOption 1 17,059 7% 5,783 11,276 17,059 3% 5,783 11,276 Option 2 17,059 7% 5,776 11,283 17,059 3% 5,776 11,283 Option 3 $ 1,000/ ton21717,06 3059 7% 5,776 1491,73867,325$ 4, 000/ ton283 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 42 21717,06386,60705 9 3% 5,776 130,456$ 10,000/ ton 217,06386,541130, 52211,283 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 3826 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each illustrative regulatory alternativeoption, and marginal costs between each alternativeoption for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million.$ 9.8 million to $ 15.2 million with costs at a 7 percent interest rate, and from $ 9.1 million to $ 14.1 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 1,243$ 287 to $ 2,140 per ton.

Table 8 38$ 413 per ton with costs at a 7 percent interest rate, and from $ 268 to $ 385 per ton with costs at a 3 percent interest rate. In addition, the marginal costs are $ 2,067 per ton with costs at a 7 percent interest rate and $ 1,914 per ton with costs at a 3 percent interest rate. In this case, there are no controls between $ 4,000/ ton and $ 10,000/ ton, thus there are no marginal costs between these two options.

The costs and emission reductions are flat between the options because there is only one control technique available to reduce SO2 emissions from these sources  increase sulfur conversion to meet the sulfuric acid NSPS ( 99.7 percent control).

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

Option 1 7% $ 9.8 $ 287

$ 4 3% $ 9.1 $ 268

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

Table 8 39illustrative regulatory option for NOx control. The annualized control costs range from $ 8.19 to $ 8.21 million with costs at a 7 percent interest rate, and from $ 7.29 to $ 7.30 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 726 to $ 728 per ton with costs at a 7 percent interest rate, and from $ 646 to $ 647 per ton with costs at a 3 percent interest rate. In addition, the marginal costs are $ 2,067/ ton with costs at a 7 percent interest rate and $ 1,914/ ton with costs at a 3 percent interest rate. In this case, there are no controls between $ 4,000/ ton and $ 10,000/ ton, thus there are no marginal costs between these two options.

The costs and emission reductions are flat between the options because there is only one control technique available to reduce NOx emissions from these sources  SNCR applied to nitric acid manufacturing sources. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 44 Table 8 27 2015 Cost and Cost Effectiveness Results for NOx Control at non EGU BART eligible Units at Coke Oven BatteriesHydrofluoric, Sulfuric, and Nitric Acid Plants Illustrative Regulatory AlternativeO ptions Annual Control Cost ( million 1990$) Annual Monitoring and Administrativ e Costs ( million 1990$) Interes t Rate Total AnnualAnnu alized Costs ( million 19909$) Annual Cost Effectiveness ($/ ton) MarginalAnn ualized Average Cost Effectiveness ($/ ton) $ 1,000/ tonMargi nal Costs ($/ ton)

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

Table 8 40 2015 Cost and Cost Effectivenes s Results for SO2 and NOx Control at non EGU BARTEligible Units at Coke Oven Batteries $ 646  Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 46 Option 2 7% 8.2 728 $ 4,000/ ton428 86.9 133% 7.3 100647 2,157 Option 3 7% 8.2 1,213728 N/ A 3% 7.3 647 N/ A Table 8 28 shows the total annualized costs of each illustrative regulatory option for control of both SO2 and NOx.

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

Option 1 7% $ 10,000/ ton$ 18.0 87.113.3100 3% $ 16.4 1, Option 2 7% 23.4 3% 215.4 Option 3 7% 23.4 3% 21.4 8.4.6 Results for Chemical Process Plants Table 8 4129 shows the SO2 emissions reductions achieved in the analyses for each illlustrative regulatory alternativeoption. The table indicates that the alternativesoptions achieve incremental reductions from the 2015 baseline ranging from _% to _%.

Table 8 41 2015 SO20 percent to 7 percent for costs at either a 7 or a 3 percent interest rate.

Table 8 29 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 47 Non EGU BART Eligible Units at Sulfur RecoveryChemical Process Plantsa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 42 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Sulfur Recovery Plantsa Option 1 47,700 7% 47,700 0 47,700 3% 47,700 0 Option 2 Regulatory Alternativeb47,700 Number of Affected Sources7% 45,324 2015 Baseline Emissions2,376 47,700 3% 45,324 2015 Post Control Emissions2015 Emission Reductions2,376 Option 3 $ 147,000/ ton700 7% 44,129 3,571 21747,063700 3% 149,73867,325$ 444 ,000/ ton129 217,06386,607130, 456$ 10,000/ ton217, 063863,5471 130,522 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

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

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

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

Table 8 45 2015 Cost and Cost Effectiveness Results for SO2 and NOx Control at non EGU BART Eligible Units at Sulfur Recovery Plants Regulatory Alternative Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 49 Annual Control Cost ( million 1990$) Annual Monitoring and Administrative Costs ( million 1990$) Total Annual Costs ( million 1990$) Annual Cost Effectiveness ($/ ton) Marginal Cost Effectiveness ($/ ton)$ 1,000/ ton$ 86.9$ 12.4$ 99.3$ 1,203 $ 4,000/ ton86.913.3100.21,213$ 10,000/ ton87.113.3100.41,215 Table 8 46 shows the8 30 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory alternativeoption. The table indicates that the alternativesoptions achieve incremental reductions from the 2015 baseline ranging from _% to _%. 33 percent to 48 percent for costs at a 7 percent interest rate, and from 37 to 48 percent for costs at a 3 percent interest rate.

Table 8 4630 2015 SO2NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Primary Aluminum Ore ReductionChemical Process Plantsa Illustrative Regulatory AlternativebOptio ns Number of Affected Sources2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 50 $ 1,000/ ton388,5693 2,213$ 4,000/ ton269 ,395151,387$ 10,00 0/ ton220,474200,30 8 Table 8 47 2015 NOx Baseline Emissions and Emission Reductions for Non EGU BARTEligible Units at Primary Aluminum Ore Reduction Plantsa Option 1 Regulatory Alternativeb72,577 Number of Affected Sources7% 2015 Baseline Emissions2015 Post Control Emissions2015 Emission Reductions$ 1,000/ t on1,676149,73850$ 4,000/ ton1,6768648 ,607 13023,970 72,577 3% 45,456435 27,142 Option 2 72,577 7% 37,941 34,636 $ 10 72,000/ ton577 3% 137,676776 8634,801 Option 3 72,541577 7% 37,776 34,801 130 72,522577 3% 37,385 35,192 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 4831 shows the annualannualized costs , resulting annualized average annual costeffectiveness for each illustrative regulatory alternativeoption, and marginal costs between each alternativeillustrative regulatory option for SO2SO2 control. The annualannualized control costs range from $ 200 million to $ 2.3 billion. Annual monitoring and administrative costs depend on the number of covered sources, and since the number of sources is constant across the alternatives, this cost is also constant at _ million$ 0 to $ 13.7 million with costs at a 7 percent interest rate, and from $ 0 to $ 10.2 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 1,243 to $ 2,140 per ton.

Table 8 48$ 0 to $ 3,836 per ton with costs at a 7 percent interest rate, and from $ 0 to $ 2,850 per ton with costs at a 3 percent interest rate. The marginal costs range from $ 1,052 to $ 9,372/ ton with costs at a 7 percent interest rate and from $ 1,013 to $ 6,527 per ton with costs at a 3 percent interest rate. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 51 The costs and emission reductions reflect a major difference in the impacts between the two available control techniques: increase sulfur percent conversion to meet the sulfuric acid NSPS ( 99.7 percent control) and FGD scrubbers.

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

Option 1 7% $ 0.0 $ 0

$ 4 3% $ 0.0 $ 0

Option 2 7% 2.5 1,000/ ton052 $ 10,000/ ton052 3% 2.4 1,013 1,013 Option 3 7% 13.7 3,836 9,372 3% 10.2 2,850 6,527 Table 8 4932 shows the annualannualized costs, resulting annualannualized average costeffectiveness for each illustrative regulatory alternative21option, and marginal costs between each Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 52 alternative.

Table 8 49illustrative regulatory option for NOx control. The annualized control costs range from $ 14.4 million to $ 74.1 million with costs at a 7 percent interest rate, and from $ 21.1 million to $ 77.1 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 601 to $ 2,129 per ton with costs at a 7 percent interest rate, and from $ 776 to $ 2,191 per ton with costs at a 3 percent interest rate. In addition, the marginal costs of the options ranges from $ 5,030 to $ 35,758 per ton with costs at a 7 percent interest rate, and from $ 4,348 to $ 58,082 per ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect the application of many different types of NOx controls. The reason for the large increase in marginal costs associated with the $ 10,000/ ton option is the applications of LNB + SNCR or SCR that would take place at units within these plants according to our analysis.

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

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

Table 8 50 2015 Cost and Cost Effectiveness Results for SO2 and NOx Control at non EGU BARTEligible Units at Primary Aluminum Ore Reduction Plants Regulatory Alternative  Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 54 $ 4,000/ tonOpt ion 2 86.913.3100 7% 68.2 1,213969 $ 5,030 $ 10,000/ ton3 % 87.11 3.31 0054.4 1,215563 4,348 Option 3 7% 74.1 2,129 35,758 3% 77.1 2,191 58,082 The remaining BART source categories only have Nox controls applied to their affected units. This is because there are no SO2 emissions from BART eligible units in these source categories.

Table 8 33 shows the total annualized costs of each illustrative regulatory option for control of both SO2 and NOx. Table 8 33 2015 Cost Results for SO2 and NOx Control at non EGU BART Eligible Units at Chemical Process Plants Illustrative Regulatory AlternativeOpti ons Annual Control Cost ( million 1990$) Annua l Monitoring and Administrativ e Costs ( million 1990$) Interes t Rate Total AnnualAnnualized Costs ( million 19909$)

Annual Cost Effectiveness ($/ ton) Option 1 Marginal Cost Effectiveness ($/ ton) 7% $ 1,000/ ton$ 86.9$ 12$ 14.4 3% $ 9921.1 Option 2 7% 70.8 3% 56.8 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 55 Option 3 $ 1,203  $ 4,000/ ton86. 913.3100.21,2 13$ 10,000/ ton 7% 87.18 13 3% 87.3 100 8.41,215 Table 8 51 2015 NOx. 7 Results for Iron and Steel Mills Table 8 34 shows the SO2 emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 0 to 12 percent for costs at either a 7 or 3 percent interest rate.

Table 8 34 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Lime Kilns Non EGU BART Eligible Units at Iron and Steel Millsa Illustrative Regulatory AlternativeNumbe r of Affected SourcesOptions 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions $ 1,000/ ton5742,701 Option 1 263,312541 7% 23,541 0 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 56 23,541 3% 23,541 0 Option 2 1623,541 7% 20,627 2,389914 23,541 3% 20,627 2,914 $ 4,000/ tonOption 3 5723,541 7% 20,627 422,701914 23,541 26,31216,389$ 103 % 20,000/ ton57627 422,70126,31216,3 89914 a TheaThe 2015 baseline emissions estimate reflects emissions from all 58 largeBART eligible sources in thisthese source categorycategories, both controlled and uncontrolled.

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

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

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

Table 8 53 2015 NOx achieved in the analyses for each illustative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 5 to 41 percent at costs of either 7 or 3 percent interest rate.

Table 8 35 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Glass Fiber Processing Plants Non EGU BART Eligible Units at Iron and Steel Millsa Illustrative Regulatory AlternativeNum ber of Affected SourcesOptions 200715 Baseline Emissions Interest Rate 200715 Post Control Emissions 200715 Emission Reductions $ 1Option 1 20,963 7% 19,927 1,000/ ton036 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 58 20,963 3% 19,927 1,036 Option 2 20,963 7% 13,966 6,997 20,963 3% 12,463 8,500 Option 3 5720,963 7% 4212,701456 8,507 26,31220,96 3 3% 12,290 16,389$ 4,000/ ton574 2,70126,31216,389$ 1 0,000/ ton5742,70126, 31216,3898,673 a TheaThe 200715 baseline emissions estimate reflects emissions from all 58 largeBART eligible sources in thisthese source categorycategories, both controlled and uncontrolled.

Table 7 68 36 shows the annualannualized costs and, resulting annualized average costeffectiveness for each regulatory alternative. The annual control costs for all alternatives is $ 23.9 million, and is based on a combination of urea based SNCR and combustion modifications. Annual monitoring and administrative costs for all alternatives are $ 3.7 million. 24illustrative regulatory option, and marginal costs between each illustrative regulatory option for SO2 control. The annualized control costs range from $ 0 million to $ 5.3 million with costs at a 7 percent interest rate and from $ 0 to $ 3.4 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness is $ 1,458 per ozone season ton, and the reductions from uncontrolled 2007 baseline emissions are just over 40%.

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

Table 8 54results range from $ 0 to $ 1,819 per ton with costs at a 7 percent interest rate and from $ 0 to $ 1,165 per ton with costs at a 3 percent interest rate. In addition, the marginal costs are $ 1,819/ ton with costs at a 7 percent interest rate and $ 1,165 / ton with costs at a 3 percent interest rate. In this case, there are no controls between $ 4,000/ ton and $ 10,000/ ton, thus there are no marginal costs between these two options.

The costs and emission reductions are flat between the options because the two controls available Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 59 both have similar average cost per ton estimates below $ 4,000 sulfuric acid plant and increase sulfur conversion to meet the sulfuric acid NSPS ( 99.7 percent control).

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

Option 1 7% $ 20.0 $ 0

3% $ 0.0 $ 0

Option 2 $ 3.77% 5.3 $ 23.9$ 11,458$ 4,000/ ton20.23 .72 3.98 19 1,458819 $ 10,000/ ton 20.23% 3.72 3.94 1,458165 1,165 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 60 Option 3 7% 5.3 1,819 N/ A 3% 3.4 1,165 N/ A 8.1.10 Results for Municipal Incinerators The analysis of municipal incinerators ( > 250 tons per day burn refuse capacity) is conducted by selecting the most cost effective control measure available for each identified source that does not exceed the Table 8 37 shows the annualized costs, resulting annualized average cost effectiveness cut off specified in the regulatory alternative. Table 7 11for each regulatory option, and marginal costs between each illustrative regulatory option for NOx control. The annualized control costs range from $ 0.6 million to $ 27.9 million with costs at a 7 percent interest rate and from $ 0.4 million to $ 29.0 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 579 to $ 3,280 per ton with costs at a 7 percent interest rate and from $ 431 to $ 3,343 per ton with costs at a 3 percent interest rate. The marginal costs range from $ 2,953 to $ 6,424/ ton with costs at a 7 percent interest rate and from $ 2,532 to $ 56,052/ ton with costs at a 3 percent interest rate.

The costs and emission reductions reflect a rise in the costs of control due to additional applications of LNB + either SNCR or SCR.

Table 8 37 2015 Cost and Cost Effectiveness Results for NOx Control at non EGU BART eligible Units at Iron and Steel Mills Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 61 Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton)

Option 1 7% $ 0.6 $ 579

3% $ 0.4 $ 431

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

Table 8 38 2015 Cost Results for SO2 and NOx Control at non EGU BART Eligible Units at Iron and Steel Mills Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$)

Option 1 7% $ 0.6 3% $ 0.4 Option 2 7% 23.5 3% 22.7 Option 3 7% 33.2 3% 32.4 8.4.8 Results for Coke Oven Batteries Table 8 39 shows the SO2 emissions reductions achieved in the analysies for each illustrative Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 62 regulatory alternativeoption. The table indicates that the alternativeoptions achieve from incremental reductions from the 200715 baseline ranging from 0% to 45%.

Table 8 55 2015 NOx0 to 62 percent for costs at a 7 percent interest rate, and from 0 to 57 percent for costs at a 3 percent interest rate.

Table 8 39 2015 SO2 Baseline Emissions and Emission Reductions for Municipal Incineratorsa ( in tons) for Non EGU BART Eligible Units at Coke Oven Batteries Ilustrative Regulatory AlternativeN umber of Affected SourcesOptio ns 200715 Baseline Emissions Interest Rate 200715 Post Control Emissions 200715 Emission Reductions $ 1,500/ tonOpt ion 1 9,815 7% 9,815 0 2 9,852815 23% 9,852815 0 $ 2,000/ tonOpt ion 2 029,8522,8 520$ 3,000/ t on302,8521 ,577815 7% 5,727 1,275$ 44,000/ ton0 88 9,815 3% 6,091 3,724 Option 3 9,815 7% 303,708 26,107 9,852815 3% 4,251 15,5771,275$ 5,00 0/ ton302,8521,577 1,275564 a The 200715 baseline emissions estimate reflects emissions from all 30 largeBART eligible sources in thisthese source categorycategories, both controlled and uncontrolled.

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

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

Table 8 57 2015 NOx achieved in the analyses for each illustrative regulatory option for NOx control. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 0 to 56 percent for costs at a 7 or 3 percent interest rate.

Table 8 40 2015 NOx Baseline Emissions and Emission Reductions for Coal Cleaning Plants ( in tons) for Non EGU BART Eligible Units at Coke Oven Batteriesa Illustrative Regulatory AlternativeNumbe r of Affected SourcesOption 200715 Baseline Emissions 200715 Post Control Emissions 200715 Emission Reductions $ 1,000/ ton5742,701 Option 1 26,3121610,389 $ 4,000/ ton5742,701 26,3121610,389 $ 10,000/ ton5742,70126,312160 10,389 10,389 0 Option 2 10,389 4,621 5,768 10,389 4,621 5,768 Option 3 10,389 4,621 5,768 10,389 4,621 5,768 a The 200715 baseline emissions estimate reflects emissions from all 58 largeBART eligible sources in thisthese source categorycategories, both Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 64 controlled and uncontrolled.

Table 7 68 41 shows the annualannualized costs and, resulting annualized average costeffectiveness for each regulatory alternative. The annual control costs for all alternatives is $ 23.9 million, and is based on a combination of urea based SNCR and combustion modifications. Annual monitoring and administrative costs for all alternatives are $ 3.7 million. 25illustrative regulatory option, and marginal costs between each option for SO2 control. The annualized control costs range from $ 0 million to $ 21.3 million with costs at a 7 percent interest rate and from $ 0 million to $ 14.1 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness is $ 1,458 per ozone season ton, and the reductions from uncontrolled 2007 baseline emissions are just over 40%.

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

Table 8 58results range from $ 0 to $ 3,488 per ton with costs at a 7 percent interest rate and from $ 0 to $ 2,529 per ton with costs at a 3 percent interest rate. The marginal costs range from $ 1,517 to $ 7,479/ ton with costs at a 7 percent interest rate and from $ 1,074/ ton to $ 5,489/ ton with costs at a 3 percent interest rate.

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

Table 8 41 2015 Cost and Cost Effectiveness Results for Coal Cleaning PlantsSO2 Control at Non EGU BART eligible Units at Coke Oven Batteries Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 65 Illustrative Regulatory AlternativeO ptions Interest Rate Annual Control Cost ( million 1990$) Annual Monitoring and Administrative Costs ( million 1990$) Total AnnualAnnualized Costs ( million 1990$) Ozone SeasonAnnualize d Average Cost Effectiveness ($/ ozone season ton$/ ton) Marginal Costs ($/ ton)

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

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

Table 8 42 2015 Cost and Cost Effectiveness Results for NOx Control at non EGU BART eligible Units at Coke Oven Batteries Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton) Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 66 Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

Option 2 7% 12.5 2,167 $ 2,167 3% 10.9 1,898 1,898 Option 3 7% 12.5 2,167 N/ A 3% 10.9 1,898 N/ A Table 8 43 shows the total annualized costs for control of both SO2 and NOx.

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

Option 1 7% $ 0.0 3% $ 0.0 Option 2 7% 18.7 3% 14.9 Option 3 7% 33.8 3% 25.0 8.4.9 Results for Sulfur Recovery Plants Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 67 Table 8 44 shows the SO2 emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline of 23 percent for costs at a 7 or a 3 percent interest rate. The emission reductions are the same for each option because of the few controls available between $ 1,000 and $ 10,000 per ton average cost.

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

Table 8 45 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Sulfur Recovery Plantsa Illustrative Regulatory Options 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Option 1 651 7% 516 135 651 3% 516 135 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 68 Option 2 651 7% 510 141 651 3% 510 141 Option 3 651 7% 510 141 651 3% 510 141 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 46 shows the annualized costs, resulting annualized average cost effectiveness for each illustrative regulatory option, and marginal costs between each option for SO2 control. The annualized control costs range are $ 11.6 million with costs at a 7 or a 3 percent interest rate . The accompanying annualized average cost effectiveness results are $ 847 per ton with costs at a 7 percent interest rate and $ 849 per ton with costs at a 3 percent interest rate, and the marginal costs are $ 847 per ton with costs at a 7 percent interest rate and $ 849 per ton at a 3 percent interest rate. There are no available controls between $ 4,000/ ton and $ 10,000/ ton, so there are no other marginal costs.

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

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

Option 1 7% $ 11.6 $ 847

3% $ 11.6 $ 849

Option 2 7% 11.6 847 $ 847 3% 11.6 849 849 Option 3 7% 11.6 847 N/ A 3% 11.6 849 N/ A Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 69 Table 8 47 shows the annualized costs, resulting annualized average cost effectiveness for each illustrative regulatory option, and marginal costs between each option for NOx control. The annualized control costs range from $ 0.07 million to $ 0.52 million with costs at a 7 percent interest rate and from $ 0.05 million to $ 0.47 million with costs at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 519 to $ 3,652 per ton with costs at a 7 percent interest rate and from $ 400 to $ 3,315 per ton with costs a 3 percent interest rate. In addition, the marginal costs are $ 74,167/ ton with costs at a 7 percent interest rate and $ 68,833/ ton with costs at a 3 percent interest rate. There are no available controls between $ 4,000/ ton and $ 10,000/ ton, so there are no other marginal costs.

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

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

Option 1 7% $ 0.1 $ 519

3% $ 0.1 $ 400

Option 2 7% 0.5 3,652 $ 74,167 3% 0.5 3,315 68,833 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 70 Option 3 7% 0.5 3,652 N/ A 3% 0.5 3,315 N/ A Table 8 48 shows the total annualized costs for control of both SO2 and NOx.

Table 8 48 2015 Cost Results for SO2 and NOx Control at non EGU BART Eligible Units at Sulfur Recovery Plants Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$)

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

Table 8 49 2015 SO2 Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Primary Aluminum Ore Reduction Plantsa Illustrative Regulatory Option 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Option 1 47,552 7% 45,922 1,630 47,552 3% 45,922 1,630 Option 2 47,552 7% 44,292 3,260 47,552 3% 44,292 3,260 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 71 Option 3 47,552 7% 44,292 3,260 47,552 3% 44,292 3,260 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

Table 8 50 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 3 to 15 percent with costs at a 7 or 3 percent interest rate.

Table 8 50 2015 NOx Baseline Emissions and Emission Reductions ( in tons) for Non EGU BART Eligible Units at Primary Aluminum Ore Reduction Plantsa Illustrative Regulatory Option 2015 Baseline Emissions 2015 Post Control Emissions 2015 Emission Reductions Option 1 1,676 1,626 50 1,676 1,626 50 Option 2 1,676 1,423 253 1,676 1,421 255 Option 3 1,676 1,421 255 1,676 1,421 255 a The 2015 baseline emissions estimate reflects emissions from all BART eligible sources in these source categories, both controlled and uncontrolled.

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

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

Table 8 51 2015 Cost and Cost Effectiveness Results for SO2 Control at Non EGU BART eligible Units at Primary Aluminum Ore Reduction Plants Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 72 Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton)

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

3% $ 1.0 $ 590

$ 4,000/ ton 207% 7.2 32,209 $ 3,436 3% 4.72 3.95 1,458383 1,383 $ 10,000/ ton 207% 7.2 3.72 3.92 ,209 N/ A 3% 4.5 1,383 N/ A Table 8 52 shows the annualized costs, resulting annualized average cost effectiveness for each regulatory option, and marginal costs between each option for NOx control. The annualized control costs range from $ 0.04 million to $ 0.7 million with costs at a 7 percent interest rate and from $ 0.04 to $ 0.4 million with cost at a 3 percent interest rate. The accompanying annualized average cost effectiveness results range from $ 740 to $ 2,639 per ton with costs at a 7 percent interest rate and from $ 509 to $ 1,764 per ton with costs at a 3 percent interest rate. The marginal costs range from $ 2,823 to $ 30,500 per ton with costs at a 7 percent interest rate. With costs at a 3 percent interest rate, the marginal costs are $ 1,764 per ton between the $ 1,000/ ton and $ 4,000/ ton options, but there is no marginal cost between the $ 4,000/ ton and $ 10,000/ ton options since the impacts are the same.

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

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

Option 1 7% $ 0.0 $ 740

3% $ 0.0 $ 509  Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 73 Option 2 7% 0.6 2,411 $ 2,823 3% 0.4 1,764 1,764 Option 3 7% 0.7 2,639 30,500 3% 0.4 1,458 764 N/ A Table 8 53 shows the total annualized costs for control of both SO2 and NOx.

Table 8 53 2015 Cost Results for SO2 and NOx Control at non EGU BART Eligible Units at Primary Aluminum Ore Reduction Plants Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$)

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

8.1.7 The next seven BART source categories only have NOx controls applied to their affected units. This is because there are no SO2 emissions from BART eligible units in these source categories that can be controlled at under $ 10,000/ ton ( 1999$). Hence, all the reductions and costs for the remaining source categories are only for NOx, not SO2. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 74 8.4.11 Results for Lime Kilns Table 8 54 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 21 to 56 percent for costs at a 7 or 3 percent interest rate.

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

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

Table 8 55 2015 Cost and Cost Effectiveness Results for BART eligible Lime Kilns Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 75 Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton)

Option 1 7% $ 2.0 $ 745

3% $ 4.3 $ 953

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

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

Table 8 57 shows the annualized cost, resulting annualized average cost effectiveness and marginal costs for each illustrative regulatory option. The total annualized costs for these options ranges from $ 0.5 million to $ 7.8 million with costs at a 7 percent interest rate and from $ 0.7 million to $ 6.8 million with costs Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 76 at a 3 percent interest rate. The annualized average cost effectiveness ranges from $ 937 to $ 3,549 per ton with costs at a 7 percent interest rate, and from $ 880 to $ 3,108 per ton with costs at a 3 percent interest rate. Marginal costs are $ 3,101/ ton for reaching the $ 4,000/ ton option and $ 30,488/ ton between the $ 4,000/ ton and $ 10,000/ ton options with costs at a 7 percent interest rate, and $ 3,057/ ton for reaching the $ 4,000/ ton option and $ 25,402/ ton between the $ 4,000/ ton and $ 10,000/ ton options with costs at a 3 percent interest rate. The impacts reflect application of LNB at $ 1,000/ ton and $ 4,000/ ton, and then oxygen firing under the $ 10,000/ ton option.

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

Option 1 7% $ 0.5 $ 937

3% $ 0.7 $ 880

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

Table 8 58 2015 NOx Emission Reductions ( in tons) for BART eligible Municipal Incineratorsa Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 77 Illustrative Regulatory Options 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Option 1 1,656 7% 1,656 0 1,656 3% 1,656 0 Option 2 1,656 7% 912 744 1,656 3% 912 744 Option 3 1,656 7% 912 744 1,656 3% 912 744 a The 2015 baseline emissions estimate reflects emissions from all sources in this source category, both controlled and uncontrolled.

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0 Option 2 7% 1.1 1,478 1,478 3% 0.9 1,207 1,207 Option 3 7% 1.1 1,478 N/ A 3% 0.9 1,207 N/ A Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 78 8.4.14 Results for Coal Cleaning Plants Table 8 60 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 0 to 46 percent for costs at a 7 or a 3 percent interest rate.

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

Table 8 61 shows the annualized costs, annualized average cost effectiveness and marginal costs for each illustrative regulatory option. The total annualized costs for these options ranges from $ 0 to $ 1 million with costs at a 7 percent interest rate and from $ 0 to $ 0.8 million with costs at a 3 percent interest rate. The annualized average cost effectiveness is $ 1,900 per ton with costs at a 7 percent interest rate and $ 1,534 per ton with costs at a 3 percent interest rate. The marginal costs are $ 1,900/ ton for reaching the $ 4,000/ ton option with costs at a 7 percent interest rate and $ 1,534/ ton with costs at a 3 percent interest rate. Since there are no other controls between $ 4,000/ ton and $ 10,000/ ton, there are no additional reductions and hence no marginal costs between these two options. Controls available to these sources are LNB and SNCR. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 79 Table 8 61 2015 Cost and Cost Effectiveness Results for BART eligible Units at Coal Cleaning Plants Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton)

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

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

Table 8 59 2015 NOx Emission Reductions ( in tons) for BART eligible Units at Carbon Black Plants Illustrative Regulatory Options 2015 Baseline Emissions Interest Rate 2015 Post Control Emissions 2015 Emission Reductions Option 1 4,645 7% 4,638 7 4,645 3% 4,638 7 Option 2 4,645 7% 4,525 120 4,645 3% 4,525 120 Option 3 4,645 7% 4,525 120 4,645 3% 4,525 120 a The 2015 baseline emissions estimate reflects emissions from all sources in this source category, both controlled and uncontrolled Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 80 Table 8 63 shows the annualized cost, resulting annualized average cost effectiveness and marginal costs for each illustrative regulatory option. The total annualized costs for these options ranges from $ 0.1 million to$ 0.2 million with costs at a 7 percent interest rate and from $ 0.006 million to $ 0.15 million with costs at a 3 percent interest rate. The annualized average cost effectiveness ranges from $ 957 to $ 1,608 per ton with costs at a 7 percent interest rate and from $ 830 to $ 1,237 per ton with costs at a 3 percent interest rate. The marginal costs between the $ 1,000/ ton and the $ 4,000/ ton option are $ 1,646/ ton with costs at a 7 percent interest rate and $ 1,237/ ton with costs at a 3 percent interest rate. Since there are no other controls between $ 4,000/ ton and $ 10,000/ ton, there are no additional reductions and hence no marginal costs between these two options. NOx controls available to these sources are SNCR and SCR and the cost per ton for these controls is fairly similar for these sources in this analysis.

Table 8 63 2015 Cost and Cost Effectiveness Results for BART eligible Units at Carbon Black Plants Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Costs ($/ ton)

Option 1 7% $ 0.1 $ 957

3% $ 0.0 $ 830

Option 2 7% 0.2 1,608 1,646 3% 0.1 1,237 1,237 Option 3 7% 0.2 1,608 N/ A 3% 0.1 1,237 N/ A 8.4.16 Results for Phosphate Rock Processing Plants Table 8 64 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory option. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 0 to 7 percent for costs at either 7 or 3 percent interest rate. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 81 Table 8 64 2015 NOx Emission Reductions ( in tons) for BART eligible Units at Phosphate Rock Processing Plants Illustrative Regulatory Options 2015 Baseline Emissions 2015 Post Control Emissions 2015 Emission Reductions Option 1 719 719 0 719 719 0 Option 2 719 674 45 719 671 48 Option 3 719 671 48 719 671 48 a The 2015 baseline emissions estimate reflects emissions from all sources in this source category, both controlled and uncontrolled Table 8 65 shows the annualized cost, resulting annualized average cost effectiveness and marginal costs for each illustrative regulatory option. The total annualized costs for these options ranges from $ 0 to $ 0.2 million with costs at a 7 or 3 percent interest rate. The annualized average cost effectiveness ranges from $ 1,978 to $ 4,646 per ton with costs at a 7 percent interest rate and from $ 0 to $ 3,221 per ton with costs at a 3 percent interest rate. The marginal costs between the $ 1,000/ ton and the $ 4,000/ ton option are $ 1,978/ ton while the marginal costs between the $ 4,000/ ton and the $ 10,000/ ton options are $ 44,667/ ton with costs at a 7 percent interest rate. With costs at a 3 percent interest rate, the marginal costs between the $ 1,000/ ton and the $ 4,000/ ton option are $ 3,221/ ton, and there is no marginal cost between the $ 4,000/ ton and the $ 10,000/ ton option since the impacts are the same for each option. The only available NOx control for this source is LNB + SNCR.

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

Option 1 7% $ 0.0 $ 0

3% $ 0.0 $ 0

Option 2 7% 0.1 1,978 1,978 3% 0.2 3,221 3,221 Option 3 7% 0.2 4,646 44,667 Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 82 3% 0.2 3,221 N/ A 8.4.17 Results for Secondary Metal Production Facilities Table 8 66 shows the NOx emissions reductions achieved in the analyses for each illustrative regulatory options. The table indicates that the options achieve incremental reductions from the 2015 baseline ranging from 2 to 3 percent for costs at either a 7 or 3 percent interest rate.

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

Table 8 67 shows the annualized cost, resulting annualized average cost effectiveness and marginal costs for each illustrative regulatory option. The total annualized costs for these options ranges from $ 0.01 million to $ 0.12 million with costs at a 7 percent interest rate and from $ 0.01 to $ 0.04 million with costs at a 3 percent interest rate. The annualized average cost effectiveness ranges from $ 760 to $ 1,800 per ton with costs at a 7 percent interest rate and from $ 511 to $ 1,247 per ton with costs at a 3 percent interest rate. With costs at a 7 percent interest rate, the marginal costs between the $ 1,000/ ton and the $ 4,000/ ton options are $ 2,000/ ton and $ 9,000/ ton between the $ 4,000/ ton and the $ 10,000/ ton options. With costs at a 3 percent interest rate, the marginal costs between the $ 1,000/ ton and the $ 4,000/ ton options are $ 3,100/ ton and there are no marginal costs between the $ 4,000/ ton and the $ 10,000/ ton options since the impacts are the same. Available NOx controls are LNB and the more expensive LNB + SNCR. Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 83 Table 8 67 2015 Cost and Cost Effectiveness Results for BART eligible Units at Secondary Metal Processing Facilities Illustrative Regulatory Options Interest Rate Total Annualized Costs ( million 1999$) Annualized Average Cost Effectiveness ($/ ton) Marginal Cost ($/ ton)

Option 1 7% $ 0.0 $ 760

3% $ 0.0 $ 511

Option 2 7% 0.0 1,088 2,000 3% 0.0 1,247 3,100 Option 3 7% 0.1 1,800 9,000 3% 0.0 1,247 N/ A 8.5 Summary of Results for Non Electricity Generating Sources Table 8 13 contains ofBelow are several summary tables in which the emission reductions and costs associated with the final regulatory decisions arising from the cost effectiveness analysis. The final combination of regulatory alternatives achieves an ozone seasonfor the 3 non EGU illustrative regulatory options applied are shown by source category and also by the interest rate for the annualized costs. Table 8 68 summarizes the SO2 emission reductions for the analyses to the BART non EGU source categories using an interest rate of 7 percent and also showing results using an interest rate of 3 percent. In total, the 3 options applied in this analysis lead to nationwide SO2 emission reductions ranging from 83,778 tons to 378,169 tons with costs at a 7 percent interest rate. These options lead to SO2 emission reductions ranging from 132,280 to 373,798 tons with costs at a 3 percent rate. These represent a reduction of 11 to 30 percent from the 2015 baseline. For Option 2, the SO2 emission reduction estimate is 269,992 tons or a 22 percent reduction from the 2015 baseline with costs at a 7 percent interest rate, and 290,591 tons or a 24 percent reduction from the 2015 baseline with costs at a 3 percent interest rate.

Table 8 69 summarizes the NOx emission reduction of approximately 203,000 tons beyond the 2007 baseline. This represents approximately a 62% reductions. The nationwide NOx emission reductions from applying these 3 illustrative regulatory options range from 165,634 tons to 391,101 tons with costs at a 7 percent interest rate. These represent a reduction of 24 to 57 percent from the 2015 baseline. These options lead to NOx emission reductions ranging from 246,067 to 393,349 tons with costs at a 3 percent Draft BART RIA Chapter  4/ 12/ 05  Deliberative 8 84 rate. These represent a reduction of 36 to 58 percent from the 2015 baseline. For Option 2, the NOx emission reduction estimate is 361,152 tons or a 53 percent reduction from baseline for these combined sources.

Table 7 13 2007 Ozone Seasonthe 2015 baseline with costs at a 7 percent interest rate, and 390,871 tons or a 57 percent reduction from the 2015 baseline with costs at a 3 percent interest rate.

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