Control Strategy Design Process

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Control Strategy Design Process

• VISTAS Technical Analysis Workgroup and
• Planning Workgroup Meeting
• Atlanta, GA
• August 26, 2004
• Gregory Stella
• VISTAS Technical Advisor Emission Inventories
• Alpine Geophysics, LLC

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Control Design Process

• Identify sources of emissions
• Identify existing levels of control
• Identify expected levels of control
• Review sensitivities for most effective strategy
  application
• Design Strategy
• Application

3
Identify Sources

• Using Base Year and Future Year inventories and
  modeling
• Locate percentage of contribution to overall
  domain of interest
• Determine which categories or sources have
  largest contribution

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2002 Base Year Emissions
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(No Transcript)
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Pulp and Paper Products FacilitiesAnnual SO2
Emissions (Tons)
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Existing Level of Controls

• Once categories or sources have been defined
• Determine what level of control or applied
  programs already in place in base year (2002)
• Prevention of double counting of reductions
• Allows identification of incremental controls

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Expected Level of Controls

• Based on recently promulgated emission reductions
• Federal
• State
• Local
• Site-specific

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Emission Projection Scenarios

• Base 1 (Promulgated as of January 1, 2004)
• Atlanta / Northern Kentucky / Birmingham 1-hr
  SIPs
• Gulf Power (Crist 7) SCR application
• Heavy Duty Diesel (2007) Engine Standard (HDD)
• Large Spark Ignition and Recreational Vehicle
  Rule
• North Carolina Clean Smokestacks Act
• NOx RACT in 1-hr NAA SIPs
• NOx SIP Call (Phase I)
• Include states who have adopted Phase II already
  e.g. NC
• Petroleum Refinery Initiative
• October 1, 2003 notice MS WV
• RFP 3 Plans where in place for one hour plans
• TECO VEPCO Consent Agreements
• Tier 2 Tailpipe
• Title IV for Phase I and II EGUs
• VOC 2-, 4-, 7-, and 10-year MACT Standards
• Combustion Turbine MACT

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Emission Projection Scenarios

• Base 2a
• Base 1 assumptions
• 8-hr attainment plans (e.g., NOx RACT)
• Industrial Boiler/Process Heater/RICE MACT
• Nonroad Diesel Rule (Tier 4)
• NOx SIP Call (Phase II)
• Remaining States IC engines
• TVA scrubber application
• Clean Air Interstate Rule (CAIR)
• Base 2b
• Base 2a assumptions
• Excludes CAIR

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Should We Modify Base Cases?

• Question for move to Base 1 (OTB) from Base 2
  (OTW)
• Nonroad Diesel Rule (Tier 4)
• NOx SIP Call (Phase II)
• Industrial Boiler/Process Heater/RICE MACT
• They are now On The Books and promulgated by
  EPA

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Where does BART fit in?

• Designed in parallel track
• Continued refinement of State BART lists
• Review of technology application lists
• Preliminary application of BART technologies
• Review of application
• Integration into control strategies???

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Review of Sensitivities

• After final conclusions agreed upon from VISTAS
• Determine which strategies are most effective to
  meet VISTAS or State-specific needs
• Pollutant
• Source
• Geography
• Episode

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Review of Sensitivities (2)

• Review sources for remaining categories for
  control
• Are technologies available and cost-effective?
• Do technologies allow for reductions developed in
  sensitivities (e.g., 30)?
• Are they enough to get what is needed?
• Do we need more detailed sensitivities to fully
  define?

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Development of Strategies

• Using all related information from
• Emission source identification
• Existing and expected controls
• Results from sensitivities
• Remaining needs
• Now we can start to piece the puzzle together

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Application Options

• Command and Control
• Take every controllable category or source and
  apply reductions until we meet emission
  requirements
• Apply technology and accept resulting emissions
• Application cost not a prohibitive element

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Application Options (2)

• Incremental Cost-Effectiveness
• Develop full list of categories and all available
  technologies
• Sort by incremental cost-effectiveness of control
  among all categories (or individuals)
• Go down list until emission reduction target is
  met
• Requires additional cost estimates for
  incremental application

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Application Options (3)

• Mixed application
• Use both command and control and
  cost-effectiveness methods to design strategy

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Planned Schedule

• Sept 2004 (Using revised 2002 EI)
• Identify sources of emissions
• Identify existing levels of control
• Oct 2004 (Using revised 2009/2018)
• Identify expected levels of control
• Sept Nov 2004
• Review sensitivities for most effective strategy
  application
• Nov Dec 2004
• Design Strategy
• Initial Application