# Oil-fired Mini-Work Group

### Issues Summary

August 7, 2002 -- Draft

Prepared by Michael Shore, Environmental Defense

# 

# The follow is a summary of issues being considered by the Oil-Fired Mini Work to provide guidance to EPA on establishing nickel standards for oil-fired utility boilers. This document represents only Michael Shore's perspective and does not reflect necessarily the diverse opinions on the mini-work group. 

# 

# THE DATA

As of 1998, here is a profile of the oil industry.

-   151 facilities burning more than 50% oil

-   114 facilities burning more than 90% oil

-   90 facilities burning 100% oil

According to the excel file, oilhaps.xls, on the EPA website, there are
emissions data for 12 units. Emissions data are presented for 15 heavy
metals, but no other HAPS. 3 of these units have ESPs and 1 has a Jet
Pulse Fabric Filter.

Standards could be based on any of the heavy metals listed in the first
database, but nickel stands out because of the health attention it has
received. In the data set in the table below, three of the data points
are taken from the same facility (site 13) with different control
devices. Also, note that the worst performing unit on the list has an
ESP, but it did not appear to be working during the test period. The
best performing sample appears to be from a pilot test.

Industry stakeholders have expressed concern that the data is not good
enough to develop a precise emission standard. Other stakeholders
believe the data set is adequate.

+-----------------------------------+-----------------------------------+
| **Nickel Emissions -- Outlet      |                                   |
| Data**                            |                                   |
|                                   |                                   |
| **(lbs/trillion BTU)**            |                                   |
|                                   |                                   |
| **in order of performance**       |                                   |
+-----------------------------------+-----------------------------------+
| 1.60                              | Site 13 w/Jet Pulse Fabric Filter |
+-----------------------------------+-----------------------------------+
| 50.50                             | ESP                               |
+-----------------------------------+-----------------------------------+
| 238.00                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 306.01                            | ESP                               |
+-----------------------------------+-----------------------------------+
| 347.70                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 362.52                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 383.18                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 407.53                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 526.05                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 800.62                            | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 1353.88                           | Site 13 w/NOx controls            |
+-----------------------------------+-----------------------------------+
| 1399.37                           | Uncontrolled                      |
+-----------------------------------+-----------------------------------+
| 1827.15                           | Site 13 uncontrolled              |
+-----------------------------------+-----------------------------------+
| 2167.47                           | ESP (with only 3.7% capture rate) |
+-----------------------------------+-----------------------------------+

# CALCULATING A MACT FLOOR

There are 14 data points. There are at least two options for developing
a standard based on this data set:

-   Option A -- Best 2 data points representing the top 12% of the data
    set \[112 (d) (3) (a)\]

-   Option B -- Best 5 data points since there are less than 30 points
    in the data set \[112 (d) (3) (b)

The best performing of these data points is apparently from a pilot
test. The utilities argue that it could not be used to set a standard,
as it not a technology that is commercially demonstrated, and it
achieved this high level of performance only over a short time period.
Others have argued that this data point is legitimate, and EPA needs to
clarify its criteria for when pilot test can be used.

Based on options A and B above and decisions regarding the pilot, the
floor could be between 26 and 261 lbs. per trillion BTU or an
output-based equivalence.

# FORM OF STANDARD

There are at least two options for setting nickel standard for the
oil-fired units based on the floor above. Depending on how standard is
constructed, compliance with standards may be achieved by a combination
of installing control equipment, developing low nickel oil as a fuel
sources, and burning less oil.

**Option 1: Rate-based standard.** The unit or facility would be
required to meet the floor over a specified averaging period. The longer
the averaging period, the more flexibility the company has in meeting
the standard.

## Advantages 

-   If the standard were based on a long averaging period, most
    facilities would have considerable flexibility.

-   Unlike tonnage cap, it does not need to rely on historical use of
    oil \-- which may not be indicative of future use \-- to establish a
    standard

-   It is possible to explore the feasibility of establishing an
    output-based standard.

-   If the rate-based standard were applied to a facility instead of
    unit by unit, it could provide additional compliance flexibility.

-   If the rate-based standard were set based on BTU input or energy
    output over the averaging period (as opposed basing the standard
    only on periods when oil is combusted), it would allow for burning
    less oil as a compliance strategy.

## Disadvantages

-   A poorly designed rate-based standard may limit the applicability of
    compliance options such as burning less oil.

-   A poorly designed rate-based standards may put peaking units at a
    disadvantage as they may not be able to take advantage of a long
    averaging period.

-   Industry has expressed the concern that this approach would
    economically preclude burning oil at many units due to potentially
    high capital costs of installing emission controls. On the other
    hand, the environmental community believes that a rate-based
    standard could be designed to provide the industry flexibility so
    installation of control equipment is not the only option available
    to facilities.

**Option 2: Plant specific annual tonnage cap.** The tonnage cap could
be set by multiplying the floor (as discussed above) by the average oil
BTU input over a 10-year historical period for the facility.

## Advantages

Bill Bumpers describes the advantages of this approach as follows:

> The electric generating industry prefers that any MACT standard be
> expressed as an annual mass limit for multiple reasons. Most of the
> oil-fired generators in the country are utilized for non-baseload
> purposes. That is, they operate for relatively short periods of time.
> Many of these units also have dual-fuel capability to some extent.
> Some units have the ability to burn natural gas, whenever gas is
> available, while others have the ability to burn gas as a supplemental
> fuel. For many units, particularly in the Northeast, having the
> ability to burn both oil and gas is critical to ensuring reliability
> because of the frequent gas curtailments during winter. Without the
> ability to burn oil during the winter peaks, many units would be
> forced to retire. Similarly, these units are typically used for
> peaking purposes only so that any requirement to install control
> devices (e.g. electrostatic precipitators) to meet a short term
> emission rate limit would require the unit to retire.
>
> The industry prefers setting an annual mass emission limit because it
> would allow units greater flexibility in meeting the limit, while
> achieving the same environmental objective. A unit would have multiple
> options to meet the annual limit. The options would include:

-   Installing particulate control devices

-   Co-firing with natural gas

-   Fuel switching to natural gas

-   Contracting for lower-nickel oil

-   Reduced utilization

-   Load shifting to cleaner generation

> Each plant would be able to make compliance decisions that best suit
> the plant's situation, depending on fuel availability, operating
> levels, curtailment requirements, etc. In addition, the compliance
> monitoring would be much easier with a mass emission limit.

## Disadvantages

-   Historical usage may not be reflective of future use. The standard
    would have the potential to be lax at some facilities and
    unachievable at others

# MONITORING REGIME

The mini-work group has not discussed monitoring. However, one proposal
would be as follows:

-   **If No particulate control in place:** (1) analyze monthly
    composite sample of oil; (2) determine annual weighted average based
    on rolling12 months; and (3) weight average by amount of oil used
    each month.

-   **If Particulate control in place:** In addition to the oil
    sampling, (1) do annual testing of control device to determine metal
    removal efficiency, and (2) apply that efficiency factor to the
    determination of the metal emission rate as determined above.

# BACKGROUND INFORMATION

On the EPA website, the following background documents can be found on
oil-fired units:

1.  oilhaps.xls -- This excel file contains emission results for heavy
    metal HAPS from 12 oil-fired units.

2.  Oil_2501.xls -- This excel file contains the profile data for oil
    fired boilers extracted from E-Grid 2000.

3.  Draftoilni.pdf -- This file is a recent draft memo to Bill Maxwell
    from an EPA staff person that describes the health risks of nickel
    emissions from oil-fired boilers.

    4\. oil-presentation.ppt -- This is Bill Maxwell's power point
    presentation on oil-fired units to the full working group on March
    5, 2002.