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Industrial Point Projection Task Force

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2022 Inventory Approach

Proposed approach for calculating 2022 emissions for the non-EGU point sector.

  1. Use all data submitted for 2022 by SLTs
  2. Gapfill with data submitted for 2021 by SLTs, minus closures
  3. Gapfill with data submitted for 2020 NEI by STLs, minus closures
  4. Do not apply projection or control information to the 2020 or 2021 data, use as is

Summary of EPA Projection Methods

Basic EPA projection methodology

  1. Apply closures to base year data
  2. Add projection information from EIS
  3. Add federal control programs
  4. Add state/local control programs

Details of the EPA methods

  • See section 4.2.3.6 in the 2016v3 TSD for non-EGU point projection methods
    • See section 4.2.4 for control methods
    • For the 2016v3 platform, 2023 non-EGU point was set to 2019 EIS and state submitted point source data minus plant closures that were known to occur between 2019 and 2023
    • 2026 emissions were then projected from the 2023 emissions
  • Start with a base year (e.g., 2020 or 2021)
    • What will this be for the 2022 EMP?
  • Remove known closures from the inventory (based on EIS and state-submitted data)
    • Q: Where can we find the most recent CLOSURE packet?
  • Apply projection factors from AEO; MARAMA provides their own projections
    • For the 2016v3 inventory projections are based on 2022 regional industrial source energy consumption (e.g., AEO, 2022)
    • See Table 4-14 in the 2016v3 TSD for the list of AEO tables of projection information
    • Projection factors (2026 energy/2023 energy) capped at 1.3; no floor for contraction of emissions
    • Q: What is the mapping between the AEO energy use tables and SCCs or NAICs?
  • Apply controls for national rules: RICE NSPS, natural gas turbine NSPS, process heaters NSPS, boiler MACT, etc.

Call Notes

November 20, 2023

Agenda

  • 2022 inventory
    • Discuss methods to calculate 2022 emissions for this sector
  • Projection methods and data
    • Review US EPA methods for projection non-EGU point sources
    • Orient to where to access data used in projecting this sector
  • Next call in December
    • Compare MARAMA and US EPA methods
    • Review data for the 2022 EMP: closures, projections (which version of AEO?), controls

Notes

2022 Inventory

  • EPA's plans for the 2022 inventory
    • EIS automatically generates 2022 inventories based on coding and data available in the system
    • Ptnonipm sector includes point oil and gas, airports, and railyards, and there is a process to separate these categories out from the industrial, non-EGU point sources because they use different projection methods or actual year data
    • EPA wouldn't apply control projection info for 2020->2022 because states submit the controlled emissions information as part of the EIS submission.
  • Questions about what EPA does when a source has data in one year but not the next
    • If EPA did not receive a closure request through EIS they will use data for the sources from the most recent available triennial inventory; presume the data is still operating unless they get closure information from the state
    • Unless it was marked closed, then EPA presumes the source is still operating. For example, if a source is operating in 2020 but not in 2022, carry it into 2022 unless confirmation from the agency that it is closed in 2022. This means that this information is carried over between NEI years. When it's an NEI year, it's fresh - e.g., in 2020; Alison doesn't believe there were closures carried forward from 2019. Likely to be the same between 2022 and 2023 (next NEI year). For a triennial year, no emissions are carried forward.
    • EPA starts from scratch with each triennial inventory, do not look back for sources in previous years
  • State requests
    • This task force will have a challenge with the data that is different from each year (certain states submit every year, some do not, etc.)
    • Farren (WA) asked if there is an option to use past inventory years to estimate 2022 rather than 2020 to address concerns about COVID; Can they use 2017 instead of 2020 to estimate 2022 emissions?
    • Alison noted that this isn't the way that EIS is set up, and acknowledged that they see a lot of changes between 2016v3 and 2020 in this sector
    • Andy (NC) will submit a comprehensive 2022. If that's the case, can we tell EPA not to use 2020 in any way? Judy (NJ) wants the same thing - do not bring forward 2020 at all.
    • ACTION ITEM - Alison will double-check how this process will work for states that do not want emissions carried forward - the 'bring forward' processes are all coded in the EIS software, so we have to make sure states' 2022 submissions aren't overwritten by previous year
  • Can we see a closure list for recent years?
    • It's in EIS and not part of a typical report; EPA will check to see if a report can be generated
  • Question - What about temporary vs permanent shutdowns? Temporary would not be submitted that year, but may be submitted the next. There must be a different code for temporary. Only the permanent shutdowns would be kept in the modeling platform, correct? Will the temp code get into the flat file?
    • ACTION ITEM - Alison will check if the temp closures are included in the flat file - however, if they are not, likely won't be in the analytic years.
    • Are shutdowns marked in EIS only for permanent or temporary, or both?
    • Alison thinks they're for permanent shutdowns only
    • Some sources could be below the reporting threshold, still operating in but not reporting to EIS; the algorithms will still carry forward the most recent reported emissions for these types of sources unless they are told otherwise by the state/source
    • Alison suggests looking at the percentage of sources carried forward in 2021 relative to 2020 for an indication of the sources that likely won't report in 2022
    • Someone noted that 2022 is special because of the explicit call for more information this year (e.g., Type B sources)
  • How to address COVID impacts in 2020
    • Look at how much each SCC changed from past (2016, 2017, 2019, 2020, 2021) inventories to see if there is a big difference in 2020; see this spreadsheet with point (EGU, non-EGU, oil & gas) emissions for 2016 through 2021. In the SCC total tab columns I through M you'll see the differences from year to year; column J highlights the 2019 to 2020 difference
    • Link to folder with spreadsheets comparing unit and facility level emissions for recent base years to 2020
    • Qualitatively consider the impacts on different sub-sectors of the nonEGU point sector (e.g., glass or ICI boilers)
    • Suggestion to identify certain ptnonipm sectors that were impacted by the pandemic, similar to what the nonpoint projections task force has done.
    • Good idea - look at 2019 vs 2020, and see if we can see differences between SCCs.
  • Judy noted the situation in NJ with offset banks and the need to always grow the data into the future; also noted that point source growth is limited by permit conditions; she could consider keeping the data flat from 2020 to 2022, and even into the future analytics years for parts of this sector
  • Byeong notes that we should communicate to the larger group of states during report-out calls the issue of reporting closures to ensure that sources won't be carried forward; it's not enough to just not report emissions for a source
    • Alison shared a slide presented at the last quarterly report-out about the need to report closures; we will emphasize this on the next call again
  • Discussion wrap up
    • Industrial point projections co-chairs (Zac and Rhonda) will work together to create an analysis between 2019 and 2020 SCC changes, and see if there are outliers for 2020. Will bring back to group for discussion.
    • Need a list of closures, from the 2020 - 2021 - 2022 years pulled from EIS. We will circulate for QA. Janice and/or Alison will pull the data/create the report.
    • Doodle poll will be sent for a few dates in December/January - we'll cover the items we didn't get to today.

  • Next call
    • We will talk in December but not before the projections WG call; Rhonda to send out a Doodle Poll
    • Review 2020 vs other recent years to see if we can identify COVID impacts
    • Review list of closures
    • Talk about plans for analytic years

Action Items

  • Alison: double-check how it will work for states that do not want emissions carried forward from 2020 to 2022
  • Alison: get a list of 2020, 2021 shutdowns from EIS
  • Alison: get a list of recent base year inventories to compare for identifying COVID impacts. Zac and Rhonda will use list to create an analysis between 2019 and 2020 SCC changes, and see if there are outliers for 2020.
  • Alison will check if the temp closures are included in the flat file
  • Rhonda: send out a Doodle poll to talk before the winter break
    • Done, scheduled for 12/18 @ 1:00 Eastern
  • Read the US EPA 2016v3 TSD sections on the non-EGU point sector (note that nonegu point and ptnonipm are used interchangeably)
    • Section 4.2/4.2.1: general background on projection approach and CoST
    • Section 4.2.2: closure methods (SMOKE CLOSURE packet)
    • Section 4.2.3 intro: summary of projection methods (SMOKE PROJECTION packet)
    • Section 4.2.3.6: non-EGU point methods/details
    • Section 4.2.4: summary and descriptions of controls applied to non-EGU point (SMOKE CONTROLS packet)

December 18, 2023

Agenda

  • Review the analysis tools/products on the taskforce wiki (see below).
  • Discuss current default approach with U.S. EPA to calculate 2022 emissions from 2020, 2021, and 2022 data
  • Identify alternative approaches for 2022 and how to recommend those approaches to U.S. EPA

Notes

Wiki Resources:

  • Spreadsheet of 20163 nonEGU Point SCCs (US_State_SCC_ptnonimp_2016v3_26jan2023.xlsx): This workbook is intended to help identify subsector projection approaches and priorities based on 2016v3 (2019) data. See the "README" tab in the workbook for further explanation. Note that AEO is used for analytic year projections, not how to get from 2020 to 2022. However, we can use these subcategories to prioritize things and identify COVID impacts. The workbook contains three sheets:
    • Projection Priorities -Priorities: based on AEO Projection Category (sector-fuel) and how EPA applies projection factors to the subsectors of the inventory. EPA mapped AEO categories (economic indicators) to groups of SCCs to project activity.
    • 2016v3 (2019) Emissions -Emissions: these are the best emissions we have projected. Organized by region.
    • Projections by Region - SCCSCC: -Can canorganize to see the projection numbers used (2023 to 2026) associated with an AEO category. Note that AEO is used for analytic year projections, not how to get from 2020 to 2022. However, we can we use these subcategories to prioritize things and identify COVID impacts

  • 2020-2021 point source shutdown report §
    • Pulled out of EIS. By region, state, FIPs code, EIS id,ID, all the way to the facility, what planned, perm, and temporary shutdowns there are, and when those shutdowns arewill planned to happen ○ happen.
    • Annual total report §
    • Used to help with covidCOVID impacts
    • Zac created a ratio from one year to the next to help identify a signal. We need to think about if there are any covidCOVID impacts.

Resources