Industrial Point Projection Task Force
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
- Exceptions for point sources are in the oil and gas, and rail sectors which use other data/methods outside of EIS
- Questions about what EPA does when a sources 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
- EPA starts from scratch with each triennial inventory, do not look back for sources in previous years
- Farren 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
- Can we see a closure list for the recent years?
- It's in EIS and not part of a typical report; EPA will check to see if an report can be generated
- 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 this type 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
- Qualitatively consider the impacts to different sub-sectors of the nonEGU point sector (e.g., glass or ICI boilers)
- Judy Rand 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
- 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: get list of 2020, 2021 shutdowns from EIS
- Alison: get a list of recent base year inventories to compare for identifying COVID impacts
- Rhonda: send out a Doodle poll to talk before the winter break
- 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)
2022 Inventory Approach
Proposed approach for calculating 2022 emissions for the non-EGU point sector.
- Use all data submitted for 2022 by SLTs
- Gapfill with data submitted for 2021 by SLTs, minus closures
- Gapfill with data submitted for 2020 NEI by STLs, minus closures
- 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
- Apply closures to base year data
- Add projection information from EIS
- Add federal control programs
- 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.