The MANE-VU Approach to Improving Visibility

MANE-VU Stakeholder BriefingNovember 15, 2007

Chris Salmi, New Jersey DEPGary Kleiman, NESCAUM

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Goals of Presentation

• Explain MANE-VU’s approach to establishing reasonable progress goals and defining a long term strategy for meeting those goals

• Review the anticipated visibility impacts and cost & benefit analyses of the long term strategy

• Describe specific elements of long-term strategy

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Principles• June 2007 Board Meeting Resolution by MANE-VU Class

I States on Principles for Implementing the Regional Haze Rule includes:– Establishing Reasonable Progress Goals reflecting the 4-factor

analysis to determine measures to be implemented by contributing states

– Achieving as much or more visibility improvement as the Uniform Rate of Progress

– Providing flexibility to states in in meeting the requested emission reductions

– Calling upon EPA and FLMs to identify/act on inconsistencies– Other key provisions reflecting the MANE-VU approach

• MANE-VU States are not asking others to do more than we are willing to do ourselves

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MANE-VU Statements – Our “Ask”for Improved Visibility from States

Other Regions:• BART• Focused EGU Strategy

within CAIR• 28% reduction in non-

EGU SO2 emissions• Continued evaluation of

other measures, including from all coal-burning facilities, and others

MANE-VU:• BART• Focused EGU Strategy

within CAIR • Low sulfur fuel oil

strategy• Continued evaluation of

other measures, including Energy Efficiency, Clean Fuels and others

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National “Ask” for EGUs

• Additional EGU reductions beyond CAIR requirements

• Discussing appropriate levels through the consultation process

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MANE-VU ApproachPrinciplesConceptual Model: SulfatesContribution Assessment: Contributing states“Four factor analysis”: Costs of potential controlsDeveloped MANE-VU commitments and Regional/National “Asks”Regional modeling: Visibility benefits in 2018 with comparison to uniform rate

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Sulfate Role in Visibility Impairment

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Brigantine, NJ

Acadia, ME

20% Worst Day Mass[2000-2004]

20% Worst Day Haze[2000-2004]

Sulfate

Nitrate

Organic CarbonElemental CarbonSoil

Coarse MassSea salt

8

#

#

#

#

#

#

#

Contributions to PM2.5 Extinction at 7 Sites20% Worst Visibility Days (2000-2004)

SoilSea SaltOCECNitrateSulfate

0

20

40

60

80

100

120

140

160

180

1

1

1

1

1

Extin

ctio

n (M

m-1

)

Dolly SodsShenandoah

Brigantine

Lye Brook

Great GulfAcadia

Moosehorn

9

0

5

10

15

20

25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil0%

10%

20%

30%

40%

50%

60%

70%

80%

90%

100%

2002 2018

CANADACENRAPSE_BCW_BCN_BCVTRIMEDCMSCTNHMAWIALNYILSCMITNKYNJINDEGAWVVANCMDOHPA

Brigantine20% Worst Days

IMPROVE mass 00-04 REMSAD Contribution to Sulfate

µg/m

3

0

5

10

15

20

25

Brigantine

Sulfate Nitrate EC OC Sea Salt Soil

CMAQ RRF-Based 2018 Mass

4-Factor Analysis:Requirements

• 4 factors to consider to determine reasonable measures:– Costs of compliance– Time necessary for compliance– Remaining useful life of any existing source

subject to such requirements – Energy and non-air quality environmental

impacts of compliance

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Benefits/Cost Analysis

• Weighs costs of imposing a regulatory program against monetized benefits of adoption

• Health and environmental benefits of air quality regulation has not traditionally been easy to monetize

• New tools developed by EPA help to identify these benefits of control programs

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What does BenMAP do?

∆ Air Quality

Population

Dose-Response

Health Valuation

x

x

x

x

Monetized Benefit

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What did we do?• Benefits analysis of four potential regional

haze control measures in 2018• Reference Scenario: On the Books/On

the Way (OTB/OTW) • Control Scenarios:

– “S-1” and “S-2” fuel strategies– BART (anticipated reductions)– “167 Stack” EGU strategy

• Estimated benefits with BenMAP

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Opportunities for SO2Emission Reduction

• EGUs @ $1,400/ton (IPM for >CAIR)• Industrial Boilers @ $150 - $10,000/ton

– Oil – 19,000 tons– Coal – 40,500 tons

• Fuel Oil @ $500 - $5000/ton– Distillate – 110,000 – 140,000 tons– Residual – 22,000 tons

• BART – 37,000 tons14

Description of Strategies

• S1-Low Sulfur Fuel (500ppm)• S2-Low Sulfur Fuel (15ppm)• BART- 2018 projections for 14 facilities

expected to be controlled solely due to BART.

• 167 Stack Strategy – 90% control at “top impactors” relative to VISTAS IPM 2.1.9

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1. Low Sulfur Oil Strategies• Distillate (#2)

– 500 ppm by 2012, 2014 (S-1)

– 15 ppm by 2016, 2018 (S-2)

• #4 Residual (S-1 & S-2)– 0.25% to 0.5% by

2012, 2018• #6 Residual (S-1 & S-2)

– 0.3 to 0.5% by 2012, 2018

• Cost: Fuel costs may increase, but lowermaintenance costs willpartially offset

• Compliance Time: Phase-in allows time forcompliance

• Useful Life: Lower Sulfurshould extend life ofboilers

• Energy & OtherEnvironmental Impacts: Higher combustionefficiency

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Reduced PM2.5 Levels in 2018 due to S1Relative to OTB/OTW

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Reduced PM2.5 Levels in 2018 due to S2Relative to S1

18

19

0

1000

2000

3000

4000

5000

6000

7000

MANE-VU VISTAS MWRPO

Tota

l Val

ue o

f S1

and

S2, M

illio

ns o

f 200

0$

Estimated Value of Avoided Incidencesdue to change in PM2.5 from Combined Fuel Strategy (S1 + S2)

in VISTAS and MWRPO

Mortality

CardiovascularSymptoms

RespiratorySymptoms

$235M $62M

2. BART Strategy• Includes reductions at 14 facilities where BART controls

are anticipated due to the BART regulation alone

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Reduced PM2.5 Levels in 2018 due to BARTRelative to OTB/OTW

21

22

0

1000

2000

3000

4000

5000

6000

7000

MANE-VU VISTAS MWRPO

Tota

l Val

ue o

f BA

RT,

Mill

ions

of 2

000$

Estimated Value of Avoided Incidencesdue to change in PM2.5 from BART Strategy

in VISTAS and MWRPO

Mortality

CardiovascularSymptoms

RespiratorySymptoms

$200M $76M

3. “167 Stack” EGU Strategy

• Control strategy focused on reducing SO2emissions from power plants.

• Emissions from power plants continue to dominate the SO2 emissions inventory and are responsible for over half the mass and approximately 70-80 percent of the Haze

• MANE-VU is asking for 90% control at 167 “top impactors” relative to 2002

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EGU Strategy – “167 Stacks”

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Distribution of Controls Among 246 Units at "167 Stacks"

0

20

40

60

80

100

120

140

Controlled Partially Controlled Uncontrolled

Num

ber o

f Uni

ts

Roughly halfof units werecontrolled by IPM at 90% or greater

About 1/3 of units had some Control

Emissions reducedTo 90% of 2002levels

There were about 30 units that had little or no control

Emissions reducedTo 90% of 2002levels

Reduced PM2.5 Levels in 2018 due to 167 EGURelative to OTB/OTW

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Estimated Value of Avoided IncidencesValue of Avoided incidences from reductions in PM2.5 due to 167 EGU

strategy in MANE-VU, VISTAS and MWRPO

0

1000

2000

3000

4000

5000

6000

7000

MANE-VU VISTAS MWRPO

Tota

l Val

ue o

f 167

EG

U, M

illio

ns o

f 200

0$

$2.1B $2.2B

Mortality

CardiovascularSymptoms

RespiratorySymptoms

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Brigantine “Worst Day” Sulfate Mass Reductions by Strategy

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

Baseline [2000-2004] 2018 Remaining and ReducedMass

20%

Wor

st D

ays

SO4

(ug/

m3)

OTB/OTW

BART

S1

S2

167 EGUs

Remaining

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1718192021222324252627282930

2000 2005 2010 2015 2020 2025

Dec

ivie

wDegree of Visibility Improvement

Brigantine, NJ

OTB/OTW

BART

S-1 (500ppm)

S-2 (15 ppm)167 EGUs ?28% non-EGU SO2

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Acadia “Worst Day” Sulfate Mass Reductions by Strategy

0.0

2.0

4.0

6.0

8.0

10.0

12.0

14.0

Baseline [2000-2004] 2018 Remaining and ReducedMass

20%

Wor

st D

ays

SO4

(ug/

m3)

OTB/OTW

BART

S1

S2

167 EGUs

Remaining

31

1718192021222324252627282930

2000 2005 2010 2015 2020 2025

Dec

ivie

wDegree of Visibility Improvement

Acadia, ME

OTB/OTW

BARTS-1 (500ppm)

S-2 (15 ppm)167 EGUs?28% non-EGU SO2

Summary of Health Co-Benefits Regional Haze Programs in MANE-VU

• Fuel sulfur content: $3.7 billion• BART: $1.8 billion• “167 Stack” EGU measure: $6.5 billion• $12 billion combined benefit

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Summary of Health Co-Benefits in Neighboring RPOs

• Fuel sulfur content: $297 million• BART: $276 million• “167 Stack” EGU measure: $4.3 billion• $4.9 billion combined benefit

Program Grand Total = $16.9 billion

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MANE-VU Statements – Our “Ask”for Improved Visibility from States

Other Regions:• BART• Focused EGU Strategy

within CAIR• 28% reduction in non-

EGU SO2 emissions• Continued evaluation of

other measures, including from all coal-burning facilities, and others

MANE-VU:• BART• Focused EGU Strategy

within CAIR • Low sulfur fuel oil

strategy• Continued evaluation of

other measures, including Energy Efficiency, Clean Fuels and others

34

National “Ask” for EGUs

• Additional EGU reductions beyond CAIR requirements

• Discussing appropriate levels through the consultation process

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In summary

• MANE-VU Class I areas are preparing to establish reasonable progress goals based on an analysis of the impacts of reasonable strategies

• The strategies include additional SO2 controls both within and outside MANE-VU

• States will have up to 2018 to adopt and implement additional strategies

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Questions?

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