Designing Control Strategies for Reasonable Progress

1
Designing Control Strategies for Reasonable
Progress

• VISTA Joint Workgroup Meeting
• Sep 6, 2006

2
Control Strategy Design

• (NH4)2SO4 is the major contributor to current
  visibility impairment at VISTAS Class I areas
• 20 worst days, 20 best days, interior and
  coastal sites
• 50-80 of total extinction due to SO4
• SO2 emissions are the major contributor to SO4
  particles
• primary PM emissions only minor contributor to
  SO4
• Point sources (EGU and non-EGU) are the major
  contributors to SO2 emissions
• Roughly 80-85 EGU, 10-15 non-EGU, 5 all other

3
Control Strategy Design

• Conclude to improve visibility, reduce SO2
  emissions from point sources
• Clean Air Interstate Rule (CAIR) sets state caps
  for EGU SO2 in 2010 and 2015.
• Trading and banking allows flexibility actual
  emissions may be gt or lt than caps
• EPA considers CAIR to be reasonable regional
  control level for EGU within these time
  intervals, given market constraints

4
Control Strategy Design

• VISTAS Base F 2018 accounts for CAIR plus
  existing state and federal controls on
  industrial, mobile, and area sources
• Base F EGU emissions based on IPM model (applied
  in summer 2005) using least cost and regional
  trading assumptions
• VISTAS Base G 2018 updated IPM EGU forecast with
  utility plans and permits
• EGU SO2 emissions in VISTAS region reduced 60
  between 2002 and 2018 reductions vary among
  states

5
Control Strategy Design

• VISTAS Base F4 modeling projects that most VISTAS
  interior Class I areas and some VISTAS coastal
  areas will meet uniform rate of progress
• EPA QA even if meet uniform rate of progress by
  controlling one source sector, need to evaluate
  what controls are reasonable for other sources
  sectors
• EPA QA CAIR BART for EGU, not necessarily
  CAIR reasonable progress

6
Control Strategy Design

• Even after projected CAIR implementation, EGU
  still the source category with largest remaining
  SO2 emissions
• Industrial fuel combustion next largest category
• Cost per ton generally lower for EGU than non-EGU
  
• Emissions reductions per control installation
  generally larger for EGU than non-EGU

7
Control Strategy Design

• VISTAS is developing lists of EGU and non-EGU
  sources within the Area of Influence for each
  Class I area
• States are considering criteria for sources to be
  modeled in control strategies
• Separate BART run?
• Include BART controls with evaluation of
  potential controls on non-BART sources?
• Set /ton limit?
• Target tons needed without limiting cost?

8
Control Strategy Design

• Base G modeling results will not be available
  until end of Oct/early Nov 2006
• Control strategy design discussions can begin
  before Base G results delivered