Presentation to EPA/ICAC Control Technology Roundtable -

Status of EPA Air Pollution Control Cost Manual Update

Larry Sorrels, US EPA/OAQPS/HEID

December 5, 2016

Purpose of Today’s Briefing

• To give a technical overview of EPA’s Air Pollution Control Cost Manual Update

• Five topics to be covered:

– What is the EPA Air Pollution Control Cost Manual;

– Why the update is taking place;

– How chapters are being updated;

– What has been accomplished (especially since last year’s roundtable);

and

– What will come next.

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• Over the past 30 years, EPA’s Air Pollution Control Cost Manual has become a key air pollution control cost estimation guidance document

for EPA rulemakers, permit writers and reviewers, industry, and others.

• Foundation for cost analysis that supports:– Toxics rules (NESHAPs)

– New Source Performance Standards (NSPSs)

– Control Techniques Guidelines (CTGs) and ACTs

– EPA review of best available control technology (BACT) permits, and

– Best available retrofit technology (BART) determinations.

• In addition, many States (e.g., Virginia, Indiana, Texas) require permitted sources to follow the Cost Manual’s guidance.

• Control Cost Manual contains 15 chapters, including: – Material on estimating costs (capital and annual) in general

– A separate chapter providing a detailed methodology for estimating control costs

– More specific chapters on estimating costs for a variety of control technologies, and

– Individual chapters on VOC, PM, SO2, and NOx controls

• Each contains data and algorithms for estimating the costs of installing and operating specific add-on or

end-of-pipe control technologies. 3

What is the EPA Air Pollution Control Cost Manual?

Need for New Version of

Control Cost Manual

• Current version of the Control Cost Manual is the 6th edition.

• EPA/OAQPS has not updated the Control Cost Manual since 2003.

– State and industry officials have raised questions about the age and accuracy of the cost data and algorithms over the last several years.

• January 2014 Consolidated Appropriations (or Omnibus) Bill says that EPA “shall

begin development of a seventh edition of the document entitled EPA Air Pollution

Control Cost Manual.”

– Other language in the Bill requires that EPA “shall consult, and seek comment from state, local, and tribal departments of environmental quality during development of such seventh edition, and provide opportunity for public comment.”

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Brief Summary of Control Cost Manual Update

• Spring 2014: EPA/OAQPS began consultation with stakeholders on updating to the seventh edition, including:

– states,

– industry groups,

– Multi-jurisdictional organizations (MJOs), and

– environmental groups.

• EPA has posted a timeline for the update to the Control Cost Manual.

– Timeline lists chapters and dates of planned publication.

– Timeline is public, updated periodically, and last updated in August, 2016:

https://www3.epa.gov/ttn/ecas/docs/cost_manual_timeline_2016-08-04.pdf.

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Chapters That Are Complete –SNCR and SCR

• Selective non-catalytic reduction (SNCR) and selective catalytic seduction (SCR) are two types of NOx emission control technologies.

– SCR is much more effective in reducing NOx than SNCR (90% versus 25-45%), but is also more expensive.

• For both chapters, EPA updated cost and performance equations and assumptions for:

– Coal-fired power generating sources, by integrating data from IPM, US EPA/CAMD’s model for analyzing

electric power sector control strategies; and

– Industrial boilers and cement kilns, using other reports.

• Our June 2015 Notice of Data Availability (NODA) released updated chapters for a 90-day public comment period.

We received comments from:

– A number of industry groups (API, CIBO, UARG, among others),

– Two environmental groups (Sierra Club, NPCA),

– A local air district in CA (San Joaquin Valley), and

– One state (FL).

• In May 2016 we released final updated chapters along with:

– A response to comment (RTC) document for each chapter; and

– A separate spreadsheet for each chapter containing all relevant cost and performance assumptions.

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Public Comments on SNCR/SCR

Chapters, and Responses

• Summary of significant comments

– Equations and data not applicable to smaller units

– Cost data not applicable to both industrial and utility boilers

– Equations and data from the current version of the Integrated Planning Model (IPM), which are included in the SNCR and SCR chapters, should not be used because they are outdated and not transparent

• EPA revised both chapters, including in response to edits from the Portland

Cement Association (PCA). Among the major revisions were: – An increase in equipment life for SCR (to 30 from 20 years);

– Updates to SCR catalyst and reagent costs;

– An additional approach for catalyst replacement costs along with the approach in the former SCR chapter; and

– Clarification of SNCR applicability to cement kilns, and other sources.

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Process for Updated SNCR

and SCR Chapters

• The process used for SNCR/SCR chapters will be the model for subsequent chapter

updates.

– RTC lays out the comments on the chapters, and EPA’s responses.

• This is the first use of a public comment process to prepare or update Control Cost Manual chapters.

– Spreadsheets in Excel available to the public to use for each chapter.

• These are the first spreadsheets to accompany Control Cost Manual chapters released by EPA in

more than a decade.

• EPA will prepare a spreadsheet for estimating costs to accompany each new chapter when that

chapter is available in a final form.

• All Control Cost Manual chapters, RTC documents, spreadsheets and the Update

timeline are available at https://www.epa.gov/economic-and-cost-analysis-air-

pollution-regulations/cost-reports-and-guidance-air-pollution.

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Summary Timeline for Cost Manual

Update – Coming Chapters

Completion of Chapters and Related Products (RTC documents, spreadsheets)

Completion Date

Control Cost Methodology March 2017

Incinerators/Oxidizers (VOC) May 2017

Refrigerated Condensers (VOC) May 2017

Carbon Adsorbers (VOC) July 2017

Flares (VOC) September 2017

NOx Combustion Controls (new chapter) February 2018

FGD Scrubbers (SO2) April 2018

Fabric Filters (PM) June 2018

ESPs (PM) September 2018

Wet particulate scrubbers (PM) December 2018

DSI (new chapter) (SO2) March 2019

Hoods, Ductwork, Stacks September 2019

PTEs (Permanent Total Enclosures) (VOC) February 2020

ACI (new chapter) (Hg) August 2020

Monitors April 2021

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Status of Other Chapters

• Currently drafts of 3 chapters are available for public comment via NODA

published in the Federal Register on September 22nd:

– Control costs: concepts and methodology.

• Clarifying use of cost methodology,

• more definition of cost items,

• more discussion of cost escalation and interest rate clarifications (use of 7% interest rate for cost estimation)

– Incinerators. Provided updated information on technologies, including:

• More detail on oxidizers (chapter now titled “incinerators/oxidizers”).

• Update in VOC control efficiency to 99% from 98%.

• Clarifications in cost estimates.

– Refrigerated condensers.

• Provided updated information on technologies.

• Revised cost examples.

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NODAs, Docket and Other

Details

• The purpose of releasing chapters and RTCs via NODAs is to invite and

receive public input. – This process will also help to fulfill EPA’s peer review requirements for the Control Cost

Manual update.

– 90 day public comment period for current NODA will end on Dec. 21st.

• Public docket established for the Control Cost Manual Update (EPA-HQ-

OAR-2015-0341) contains all publicly available material pertaining to the

update. – All comments will be placed in the docket.

• Cautionary Note: The Control Cost Manual is different from CoST (Control

Strategy Tool), a software tool maintained by US EPA for control cost

analysis for non-EGUs (i.e., industrial sources). – The Control Cost Manual provides costs and other information for control measures used as

inputs for CoST.

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Any Questions?

• Please let me know if you have questions. You can email the coordinator for the Control Cost Manual at sorrels.larry@epa.gov, or call me at 919-541-5041. Thank you for your time today.

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