INTERIM REPORT OF THE COMMITTEE ON CHANGES IN NEW SOURCE REVIEW PROGRAMS FOR STATIONARY SOURCES OF AIR POLLUTANTS

Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants

Board on Environmental Studies and Toxicology

Division on Earth and Life Studies

NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES

THE NATIONAL ACADEMIES PRESS
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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants INTERIM REPORT OF THE COMMITTEE ON CHANGES IN NEW SOURCE REVIEW PROGRAMS FOR STATIONARY SOURCES OF AIR POLLUTANTS Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants Board on Environmental Studies and Toxicology Division on Earth and Life Studies NATIONAL RESEARCH COUNCIL OF THE NATIONAL ACADEMIES THE NATIONAL ACADEMIES PRESS Washington, D.C. www.nap.edu

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants THE NATIONAL ACADEMIES PRESS 500 Fifth Street, NW Washington, DC 20001 NOTICE: The project that is the subject of this report was approved by the Governing Board of the National Research Council, whose members are drawn from the councils of the National Academy of Sciences, the National Academy of Engineering, and the Institute of Medicine. The members of the committee responsible for the report were chosen for their special competences and with regard for appropriate balance. This project was supported by Cooperative Agreement No. XA-83152301-0 between the National Academy of Sciences and U.S. Environmental Protection Agency. Any opinions, findings, conclusions, or recommendations expressed in this publication are those of the author(s) and do not necessarily reflect the view of the organizations or agencies that provided support for this project. International Standard Book Number: 0-309-09578-6 Additional copies of this report are available from The National Academies Press 500 Fifth Street, NW Box 285 Washington, DC 20055 800-624-6242 202-334-3313 (in the Washington metropolitan area) http://www.nap.edu Copyright 2005 by the National Academy of Sciences. All rights reserved. Printed in the United States of America

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants THE NATIONAL ACADEMIES Advisers to the Nation on Science, Engineering, and Medicine The National Academy of Sciences is a private, nonprofit, self-perpetuating society of distinguished scholars engaged in scientific and engineering research, dedicated to the furtherance of science and technology and to their use for the general welfare. Upon the authority of the charter granted to it by the Congress in 1863, the Academy has a mandate that requires it to advise the federal government on scientific and technical matters. Dr. Bruce M. Alberts is president of the National Academy of Sciences. The National Academy of Engineering was established in 1964, under the charter of the National Academy of Sciences, as a parallel organization of outstanding engineers. It is autonomous in its administration and in the selection of its members, sharing with the National Academy of Sciences the responsibility for advising the federal government. The National Academy of Engineering also sponsors engineering programs aimed at meeting national needs, encourages education and research, and recognizes the superior achievements of engineers. Dr. Wm. A. Wulf is president of the National Academy of Engineering. The Institute of Medicine was established in 1970 by the National Academy of Sciences to secure the services of eminent members of appropriate professions in the examination of policy matters pertaining to the health of the public. The Institute acts under the responsibility given to the National Academy of Sciences by its congressional charter to be an adviser to the federal government and, upon its own initiative, to identify issues of medical care, research, and education. Dr. Harvey V. Fineberg is president of the Institute of Medicine. The National Research Council was organized by the National Academy of Sciences in 1916 to associate the broad community of science and technology with the Academy’s purposes of furthering knowledge and advising the federal government. Functioning in accordance with general policies determined by the Academy, the Council has become the principal operating agency of both the National Academy of Sciences and the National Academy of Engineering in providing services to the government, the public, and the scientific and engineering communities. The Council is administered jointly by both Academies and the Institute of Medicine. Dr. Bruce M. Alberts and Dr. Wm. A. Wulf are chair and vice chair, respectively, of the National Research Council. www.national-academies.org

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants COMMITTEE ON CHANGES IN NEW SOURCE REVIEW PROGRAMS FOR STATIONARY SOURCES OF AIR POLLUTANTS Members CHARLES F. STEVENS (Chair), Salk Institute for Biological Studies, La Jolla, CA JEAN M. ANDINO, University of Florida, Gainesville LYLE R. CHINKIN, Sonoma Technology, Inc., Petaluma, CA HEREK L. CLACK, Illinois Institute of Technology, Chicago EDWIN H. CLARK II, Clean Sites, Inc., Washington, DC JOHN C. CRITTENDEN, Arizona State University, Tempe H. CHRISTOPHER FREY, North Carolina State University, Raleigh BENJAMIN F. HOBBS, Johns Hopkins University, Baltimore, MD JONATHAN I. LEVY, Harvard University, Boston, MA THOMAS A. LOUIS, Johns Hopkins University, Baltimore, MD BRIAN F. MANNIX, Mercatus Center at George Mason University, Arlington, VA JOE L. MAUDERLY, Lovelace Respiratory Research Institute, Albuquerque, NM CRAIG N. OREN, Rutgers University, Camden, NJ KAREN L. PALMER, Resources for the Future, Washington, DC LYNN M. RUSSELL, University of California at San Diego, La Jolla MITCHELL J. SMALL, Carnegie Mellon University, Pittsburgh, PA IRA B. TAGER, University of California, Berkeley JOHN G. WATSON, Desert Research Institute, Reno, NV Staff RAYMOND A. WASSEL, Project Director EILEEN ABT, Senior Program Officer CAY BUTLER, Editor MIRSADA KARALIC-LONCAREVIC, Research Associate LEAH PROBST, Research Associate BRYAN SHIPLEY, Research Associate JOHN H. BROWN, JR., Program Associate SAMMY BARDLEY, Librarian Sponsor: U.S. Environmental Protection Agency

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY1 Members JONATHAN M. SAMET (Chair), Johns Hopkins University, Baltimore, MD RAMON ALVAREZ, Environmental Defense, Austin, TX THOMAS BURKE, Johns Hopkins University, Baltimore, MD JUDITH C. CHOW, Desert Research Institute, Reno, NV RORY B. CONOLLY, CIIT Center for Health Research, Research Triangle Park, NC COSTEL D. DENSON, University of Delaware, Newark E. DONALD ELLIOTT, Willkie, Farr & Gallagher, LLP, Washington, DC CHRISTOPHER B. FIELD, Carnegie Institute of Washington, Stanford, CA WILLIAM H. GLAZE, Oregon Health and Science University, Beaverton SHERRI W. GOODMAN, Center for Naval Analyses, Alexandria, VA JUDITH A. GRAHAM, American Chemistry Council, Arlington, VA DANIEL S. GREENBAUM, Health Effects Institute, Cambridge, MA ROBERT HUGGETT, Michigan State University, East Lansing BARRY L. JOHNSON, Emory University, Atlanta, GA JAMES H. JOHNSON, Howard University, Washington, DC JUDITH L. MEYER, University of Georgia, Athens PATRICK Y. O’BRIEN, ChevronTexaco Energy Technology Company, Richmond, CA DOROTHY E. PATTON, International Life Sciences Institute, Washington, DC STEWARD T.A. PICKETT, Institute of Ecosystem Studies, Millbrook, NY JOSEPH V. RODRICKS, Environ Corp., Arlington, VA ARMISTEAD G. RUSSELL, Georgia Institute of Technology, Atlanta MITCHELL J. SMALL, Carnegie Mellon University, Pittsburgh, PA LISA SPEER, Natural Resources Defense Council, New York, NY KIMBERLY M. THOMPSON, Harvard School of Public Health, Boston, MA G. DAVID TILMAN, University of Minnesota, St. Paul CHRIS G. WHIPPLE, Environ Incorporated, Emeryville, CA LAUREN A. ZEISE, California Environmental Protection Agency, Oakland Senior Staff JAMES J. REISA, Director DAVID J. POLICANSKY, Scholar RAYMOND A. WASSEL, Senior Program Officer for Environmental Sciences and Engineering KULBIR BAKSHI, Senior Program Officer for Toxicology ROBERTA M. WEDGE, Senior Program Officer for Risk Analysis K. JOHN HOLMES, Senior Program Officer SUSAN N.J. MARTEL, Senior Program Officer SUZANNE VAN DRUNICK, Senior Program Officer EILEEN N. ABT, Senior Program Officer ELLEN K. MANTUS, Senior Program Officer RUTH E. CROSSGROVE, Senior Editor 1   This study was planned, overseen, and supported by the Board on Environmental Studies and Toxicology.

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants OTHER REPORTS OF THE BOARD ON ENVIRONMENTAL STUDIES AND TOXICOLOGY Health Implications of Perchlorate Ingestion (2005) Air Quality Management in the United States (2004) Endangered and Threatened Species of the Platte River (2004) Atlantic Salmon in Maine (2004) Endangered and Threatened Fishes in the Klamath River Basin (2004) Cumulative Environmental Effects of Alaska North Slope Oil and Gas Development (2003) Estimating the Public Health Benefits of Proposed Air Pollution Regulations (2002) Biosolids Applied to Land: Advancing Standards and Practices (2002) The Airliner Cabin Environment and Health of Passengers and Crew (2002) Arsenic in Drinking Water: 2001 Update (2001) Evaluating Vehicle Emissions Inspection and Maintenance Programs (2001) Compensating for Wetland Losses Under the Clean Water Act (2001) A Risk-Management Strategy for PCB-Contaminated Sediments (2001) Acute Exposure Guideline Levels for Selected Airborne Chemicals (4 volumes, 2000-2004) Toxicological Effects of Methylmercury (2000) Strengthening Science at the U.S. Environmental Protection Agency (2000) Scientific Frontiers in Developmental Toxicology and Risk Assessment (2000) Ecological Indicators for the Nation (2000) Waste Incineration and Public Health (1999) Hormonally Active Agents in the Environment (1999) Research Priorities for Airborne Particulate Matter (4 volumes, 1998-2004) The National Research Council’s Committee on Toxicology: The First 50 Years (1997) Carcinogens and Anticarcinogens in the Human Diet (1996) Upstream: Salmon and Society in the Pacific Northwest (1996) Science and the Endangered Species Act (1995) Wetlands: Characteristics and Boundaries (1995) Biologic Markers (5 volumes, 1989-1995) Review of EPA’s Environmental Monitoring and Assessment Program (3 volumes, 1994-1995) Science and Judgment in Risk Assessment (1994) Pesticides in the Diets of Infants and Children (1993) Dolphins and the Tuna Industry (1992) Science and the National Parks (1992) Human Exposure Assessment for Airborne Pollutants (1991) Rethinking the Ozone Problem in Urban and Regional Air Pollution (1991) Decline of the Sea Turtles (1990) Copies of these reports may be ordered from the National Academies Press (800) 624-6242 or (202) 334-3313 www.nap.edu

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants Preface The United States Congress directed the U.S. Environmental Protection Agency (EPA) to arrange for an independent study by the National Research Council (NRC) to evaluate potential air quality, public health, and other impacts of EPA’s final rules of December 31, 2002, and October 27, 2003, relating to the New Source Review (NSR) programs that are part of the Clean Air Act. In response, the National Research Council established the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants. Biographical information on the committee members is presented in Appendix A. In response to Congress, the committee is providing this interim report and will deliver its final report in 2005. In the course of preparing this report, the committee met three times. At two of the meetings, which were held in Washington, DC, officials from local, state, and federal agencies and representatives from the private sector and nongovernmental organizations, including regulated industries and advocacy groups, were invited to meet with the committee and present their views on changes to the NSR programs. Interested members of the public at large were also given an opportunity to speak on these occasions. The committee received oral and written presentations from the following individuals: William Becker, State and Territorial Air Pollution Program Administrators (STAPPA) and the Association of Local Air Pollution Control Officials (ALAPCO); Robert Bessette, Council of Industrial Boiler Owners; F. William Brownell, Hunton and Williams; Norbert Dee, National Petrochemical & Refiners Association; John Dege, DuPont Company; Peggy Duxbury, Calpine; Jerry Golden, Ten-

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants nessee Valley Authority; William Harnett, Jeffrey Holmstead, Michael Ling, Philip Lorang, all of the U.S. Environmental Protection Agency; David McIntosh, Natural Resources Defense Counsel; Christopher Miller, U.S. Senate Committee on Environment and Public Works; William Pedersen, William F. Pedersen PLLC; Eric Schaeffer, Environmental Integrity Project; Scott H. Segal, Electric Reliability Coordinating Council; John Shanahan, U.S. Senate Committee on Environment and Public Works; Robert Slaughter, National Petrochemical and Refiners Association; Joseph Stanko, Hunton and Williams; Margaret Taylor, University of California at Berkeley; Michael Vince, Louisiana Department of Environmental Quality; Steve Wilson, Southern Company; James Witkowski, International Paper and the American Forest and Paper Association; Samuel Wolfe, New Jersey Department of Environmental Protection; and Tammy R. Wyles, Georgia-Pacific Corporation and the American Forest and Paper Association. In addition to the information provided in those presentations, the committee is using peer-reviewed scientific literature, reports from government agencies and nongovernmental organizations, databases, and other types of information. The committee has not completed the process of information gathering and analysis; therefore, readers of this interim report should not assume that the committee has reached any final conclusions or recommendations in response to its charge from Congress. Those will be presented in the committee’s final report. We wish to thank William Happer for his valuable service as chair of the committee during the early stages of this study. He resigned appropriately from the committee to serve on the Science and Technology Advisory Committee for the U.S. Department of Homeland Security. The committee’s work for this interim report was assisted by staff of the NRC’s Board on Environmental Studies and Toxicology (BEST). We wish to thank Raymond Wassel, project director, and James Reisa, director of BEST. Scientific and technical information was provided by Eileen Abt, Leah Probst, Mirsada Karalic-Loncarevic, Bryan Shipley, Sammy Bardley, and Alexandra Stupple. Invaluable logistical support was provided by John Brown and Kemi Yai. The report was ably edited by Cay Butler. Charles Stevens, Chair Comittee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants Acknowledgment of Review Participants This report has been reviewed in draft form by individuals chosen for their diverse perspectives and technical expertise, in accordance with procedures approved by the NRC’s Report Review Committee. The purpose of this independent review is to provide candid and critical comments that will assist the institution in making its published report as sound as possible and to ensure that the report meets institutional standards for objectivity, evidence, and responsiveness to the study charge. The review comments and draft manuscript remain confidential to protect the integrity of the deliberative process. We wish to thank the following individuals for their review of this report: Wayne T. Davis, University of Tennessee; Jeremy Hales, Envair Corporation; Jay Hofmann, Trinity Consultants; Morton Lippmann, New York University School of Medicine; Janet G. McCabe, Indiana Department of Environmental Management; Jana B. Milford, Environmental Defense and University of Colorado; Robert O’Keefe, Health Effects Institute; Richard Revesz, New York University School of Law; Ralph L. Roberson, RMB Consulting & Research, Inc.; James Jay Schauer, University of Wisconsin; Robert N. Stavins, Harvard University; and Samuel A. Wolfe, New Jersey Department of Environmental Protection. Although the reviewers listed above have provided many constructive comments and suggestions, they were not asked to endorse the conclusions or recommendations, nor did they see the final draft of the report before its release. The review of this report was overseen by

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants David Allen, University of Texas. Appointed by the NRC he was responsible for making certain that an independent examination of this report was carried out in accordance with institutional procedures and that all review comments were carefully considered. Responsibility for the final content of this report rests entirely with the authoring committee and the institution.

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants Contents     Summary   1 1   INTRODUCTION   13      Charge to the Committee,   14      Committee Approach,   15      Report Structure,   16 2   REGULATORY OVERVIEW   17      Introduction,   17      Framework of the Clean Air Act,   23      NSR Programs,   28      New Source Reform Project,   40 3   OVERVIEW OF HEALTH EFFECTS, AIR QUALITY, AND EMISSIONS   49      Introduction,   49      National Ambient Air Quality Standards for Criteria Pollutants,   49      Health Effects of Air Pollution,   52      Attainment Status of National Ambient Air Quality Standards,   62      Emission Sources and Trends,   68      Vintages of Emission Sources,   76      Summary,   80 4   EMISSION SOURCES AND TECHNOLOGY OPTIONS   84      Introduction,   84

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants      Overview of NSR Permits,   85      Process Technologies of Emission Sources: Process Description, Repairs and Replacement, and Pollution Prevention and Control Approaches,   100      Technological Change,   125      Summary,   131 5   ANALYTIC METHODS FOR ASSESSING EFFECTS OF NEW SOURCE REVIEW RULE CHANGES   134      Introduction,   134      Frameworks for Assessing the Impact of Regulation,   137      Summary Evaluation of Applicability of Analysis Methods for Estimating Impacts of Changes in NSR Rules,   168 6   A GENERAL APPROACH TO ASSESSING IMPACTS OF NSR RULE CHANGES   170      Introduction,   170      Scenarios of Regulatory Backdrops and NSR Rules,   171      Assessing Impacts of Individual Scenarios,   172     References   176     Terms and Abbreviations   194 Appendix A   Committee Biosketches   197 Appendix B   Congressional Mandate   204 Appendix C   Statement of Task   206 Appendix D   Repair and Replacement Activities in Selected Industries   208

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Interim Report of the Committee on Changes in New Source Review Programs for Stationary Sources of Air Pollutants INTERIM REPORT OF THE COMMITTEE ON CHANGES IN NEW SOURCE REVIEW PROGRAMS FOR STATIONARY SOURCES OF AIR POLLUTANTS

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