P.1 

OAR Box 1865 

Prepped by Charmelle Mathews 

Document Number: 

57) IV-H-4 

Docket Number: 

A-83-27 

Printed 12/3/2008 9:15:29 AM Sheet 57 of 105 
# — RADIAN A" §2 "^ 

CORPORATIO N IV n H 

February 19, 1988 

MEMORANDUM 

TO: File (Docket No. A-83-27 ) 

FROM: D.M. White W«#I # 

Radian Corporation 

SUBJECT: Interagency Review Materials 

The attached documents were received prior to promulgation by the 

Office of Management and Budget and forwarded to the U.S. Environmental 

Protection Agency, Office of Air Quality Planning and Standards for 

inclusion in this rulemaking docket. 

Attachments 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541-9100 

P.2 

7 
P.3 

cr/o/v 

*

N

^r 
P.4 

Ot.'l 

•I /* , <s$>* 

COUNCIL OF INDUSTRIAL BOILER OWNERS 

November 5, 1987 

Mr. Nicholas Garcia 

Office of Management & Budget 

726 Jackson Place,. NW 

NEOB, Rm. 3019 

Washington, DC 20503 

Dear Mr. Garcia: 

This will confirm my delivery to you of the following 

documents relating to the proposed NSPS (S02) for industrial 

boilers: 

1. National Coal Council Report, 6/86 

2. CIBO comments to EPA, 10/8 6 

3. CIBO petition to EPA, 1/87 

* Letter to CIBO from ESI, 9/1/87 

5"- Letter to CIBO from ESI, 10/5/87 

6- Letter to ESI from United McGill, 10/1/87 

7.Various trade press articles (1986) 

any que 

Please call me if you wish additional information or h 

uestions. ave 

WBM:bjf 

cc: Craig Potter, EPA 

Wendy Gramm, OMB 

Sincerely yours, 

'William B. Marx 

THIS ENCLOSURE MAY BE 

FOUND IN DOCKET ITEM: 

Enclosure 

Enclosure 

Enclosure 

Enclosure 

Enclosure 

Enclosure 

A-83-27, IV-D-28 

A-83-27, IV-D-50 

A-79-02, 

A-83-27, 

A-83-27, 

VI-D-2 

IV-D-107 

IV-D-106 

A-83-27, IV-D-107 

!»S7B;!.'keCe:i!rt;r'a.-w,-.!) Biike VifQi'-„;i ?.\;: 
P.5 

loe Csioian?o 

ij i /*pS> 

A» Li 

HhAB1^ (fun Piwti^wral w^n pifs 

EPA introduces 90% SO? reduction to new industrial coal- and oil-fired units. 

An estimated 250 planned boiler projects may switch to natural gas 8S a result 

industrial boiler ow-ners burning oi! or coal face very Btrin3 gent SOrCmiJsion controls, eccordin| lo the Latest Bfwtource performance standards (NSPS) proposed by the EPA. 

The agency current!) is receiving comments from interested 

panics These may bt incorporated into the final rules when 

they are issued, no birr than Nov J, 19S7. A public bearing 

on the proposals will be held in Durham, NC Sept 4-5. 

The NSPS will regulate only new and modified industrial 

boilers, with capacities greater than 29 MW (!CC'-rnjJhb:o 

Biu/hr). This means that large institutional snd industrial 

facilities, as well as small utility boilers (heretofore unregulated) will be subject to controls—assuming there are ino 

Changes to the NSPS before they're finalized. Speci6ca!iy, 

boilers must achieve a 9C5i reduction in SO; emissions white 

those emissions leaving the stack must contain mo more than 

1.2 Jb of SQj/million Btu Boilers firing either coal or oi) are 

subject to the new standard This regulation, called pcrccnt8|e reduction, forces even a low-sulfur-fuel user to install 

additional SO; controls at s powerplant. (Oil-fired boilers 

with emissions of 0.2 lb/million Btu or kss are exempted 

from percentage reduction.) Utility boilers greater than 250-

million Btu/hr are already subject to percentage reductionTM 

ss dictated by NSPS issued in 1979. It is generally accepted 

thai this regulation was devised an order to keep the bighjulfur-coal industry competitive. 

In the industrial NSPS, EPA claims it is encouraging tbe 

use of coal, isince the agency recognLzes thai some users may 

switch So natural gas if control costs get loo bi^h. Aay boiler 

wsin£ new, "unproven" emission-control technologies—such 

as limestone injection—must reduct SO; by 50V but stack 

emissions are limited to just 0.6 lb of SO^/million Biu Aa 

EPA spokesman explained that the lower standards ^tre to 

promote development of new technologies, but the stricter 

stack emissions would require that these systems operate 

only on low-sulfur coals. 

The Energy Secretary's advisory group, the National Coal 

Council, claims that the propositi NSPS will increase the cost 

©f producing steam by at least $0.?0/millio» Blu—about 

SS7/lon. Tbe standards will induct many users Oo owjich So 

Bsatura! gas, annually displacing about S.^-miJlion Coos of 

<w>al. By 3950. at feast 70% of all ocw industrial boiler capacity (about 770 units) will be gas-fired, She couocil predicts;. 

©bout half of Shis total will have switchc*3 to avoid sosiaJliRj 

0uc-gJs~desulfurin»on equipment EPA concedes that then* 

will be considerable feel switching.' h i-stimales that gas twill 

fuel 60%.of She ration's eaparily. Coal will be used in only 

30-40 of the flew 720 anils expected to Sx ordered in She mM 

three years. 

According to William B Marx, president ofthe Council of 

Industrial Boiler Owners (CIBO). "We (coal users) simp!) 

cannot live with this rule." Percentage reduction, he explains, 

will force boiler owners lo take expensive measures to meet 

the standards If only 8 stack-emission figure w-r« required, 

users would have the option of usin.r lowjj-r.ulrur fuels. By 

making coal use &o expensive, the proposed NSPS essentially 

regulate the choice of fuel for boiler owners This is not the 

job ofthe EPA, Mar* says.. 

CIBO members ere likely to take one of two options: 5n 

order to completely avoid installing a new boiler re-quiring 

Iflue-gas-desulfurizatiori equipment, many will keep repairing 

their old, unregulated units. Marx siotes that ihis may, in hex, 

impede improvements in air quality, sines dirty boilers will 

not be gradually retired. The second option will be fuel 

switching Her? boiler owners may face a problem with She 

Fuel Use Act, which prohibits the use of oil md £as in new 

boilers after 1990 This law has never been enforced by the 

Reagan Administration, and Congress has recently been 

making moves lo repeal il (POWER, June S9S6, p ?). 

II mil two years ago, it teemed unlikely that EPA would 

develop NSPS regulating boilers smaller fcn 73 MW 

(2>0-rni!lion Biu/hr). Bn 1964, [however, two environmental 

groups filed suit against tiie EPA claiming that the agency was 

dawdling over issuing regulations on all industrial units, 

which—under the Ckan Air Ad amendments of 1977— 

should have been issued in 1978 (PQWEJI, May 1984, p 9). As 

part of their claim, the environmentalists called for controls 

on any boiler with a capacity over SOO-million Btu/hr. 

CIBO—acting as an intervenor in the case—argued thnt 

the Ckan Air Art was concerned moinly with jiii'ity boilers. 

When EPA ranked imajor sources of pollutants-, industrial 

facilities were placed Uth. Further, She eo until contended, 

the Act grants She administrator tbe power so %&.. into COBaideralior! other,rooncnvironro.es)fa! factors,8uc!h sscost and 

energy requirements., wftcn wsuiji&NFPS. Tbese imay exempt 

many of tiie small boilers from S'Sgubuon. 

Tbe court, Ekowcvci, roled in Caver ofthe environmental 

groups, and late in S9S5 ordered the nrjency *o develop and 

publish SO; NSPS for boilers grealc; than SCO-n-.ilJion Bin/ 

hi. These MSPS fciall EPA's instate . 

Pcw»». August ves * 
P.6 

<f<3 WW I &£ m iiMOIH M 0 (PIDBW^ 

sob «£»»snjsrtial 

110 WALL STREET, W.V., W. V. 10005 

FRIDAY, SEPTEMBER 5, 1036 

E

!X H E1* fH \ z? ^ ^ ^ L?*ft f?*i 8 17" f," (7* 

H\1 r Im C^ I f H I? S w" &• Si 

Emission Controls 

To Force Fuel Switch? 

WASHINGTON - Tbe Council of 

Industrial Boiler Owners said 

proposed federal regulations on 

emissions at coal and oil-fired 

boilers, will force tbe industrial 

sector to use other fuels. 

William B. Man, tbe council's 

president, told an Environmental 

Protection Agency bearing in Nortfo 

Carolina that most of U.S. industry 

"will be forced to go off coaJ «ad oil 

altogether as they expand or replace 

existing boilers" because of tbe cost 

of compliance. 

He said the Industrial sector wifl 

have to install costly equipment to 

clean up the emissions from coal and 

oil-fired boilers and that such 

machinery can cost as much ss tbe 

boiler itself. 

Industry comments on the 

proposed rules are due Oct 2 and 

ERA could Issue a final emissions 

plan in December. 
P.7 

i If %ps!f<Cl^ 

IT Y 

6>£HJ 

JiLgj&L iiX^4;L (Urn V Xk^L>N^i l 

A FAIR ".MIL D BUSINESS NEWSPAPER 

VOL. 11 NO. 34« MONDAY. SEPTEMBER 8. 1956 

JT iMSiSl^JSli^g 

Gbo'T ainst Strict Emissions Stmiclaris 

By VIRGINIA BI1NES 

VASHINGTON-Proposed industrial boiler emissions standards would force boiler owners 

to install exorbitantly expensive 

scrubbers or limit their fuel 

sources, all for miniscule environmental improvements, 

Bill Marx president of the 

Council of Industrial Boiler 

Owners (Cibo), told the Environmental Protection Agency 

last week. 

Marx was testifying on the 

EPA's proposed New Source 

Performance Standards, which 

would require a SO percent reduction in sulfur emissions by 

new industrial boilers that burn 

oil or coal and have a beat input 

of 100 million Btu or more. 

Furthermore, the new boilers 

would have an overall emissions 

limit of 1.2 pounds of sulfur per 

million Btu of heat input. 

Marx complained that utilities, which produce far more 

sulfur pollution than industry, 

are only required to lower sulfur 

emissions by 70 percent under 

current policy. According to 

EPA estimates, industry contributes ©nhy 1.5 percent of 

sulfur emissions in the county. 

Scrubber systems cost 

millions of dollars, doubling the 

expense of new boilers, Marx 

noted. 

Additionally, scrubbers are a 

maintenance problem and may 

not always meet the emissions 

control performance standards 

for which they are d-esigned. 

By making nsw boilers an Wiettractive alternative, • 8ha 

proposed rule tvUl encourage 

users to keep their old, d\riy 

boilers in service, which will (ultimately impede progress 

against air oollution, Marx p?e> 

dieted. ' 

Cibo recommends an emissions limit of 1.6 pounds of sulfur 

per million Btu of heat input for 

industrial boilers between SCO 

snd 250 million Btu; with the 

more stringent EPA figure of 

1.2 pounds applied only to 

boilers over 250 million Btu. 

Cibo recommends against per" 

centage reductions requirements. 

The only alternative to scrubbers is switching to cleanerburning fuels, but "industry 

need s mor e — no t 

less-flexibility to obtain the 

most economic fuel for its 

boilers," Marx noted. 

The typical alternative fuel 

would be natural gas, but there 

are several" problems with 

switching to gas including: 

supply uncertainty caused by 

the regulatory' dilemma of 

Order 436; the fact that gas is 

technically prohibited as a 

boiler fuel by the Fuel Use Act; 

and the fact that it is more expensive than coal or oil, Mara 

explained. 

*EPA clearly has not thought 

tins rule through rationally," 

Marx concluded. 

. The measure is widely opposed by manufacturers and 

cogenerators, among others. 

Comments on the propesc-d 

standards are due at EPA Oct S. 

The sgencv will issue the final 

standards Before Bee. I. 
P.8 

s ,_. Lw— 

Tuesday, Sep!emt>er 9, 3986 

cw-ri 

' "J 

I 

915 15th Sneet. N W 

Suite 400-

[:, \\ b Washington. D.C 20005 

vA. W 202-6384260 

Volume 14, Number 273 

New EPA Emissions Standard 

>een Edginlg Out Coal end Oil b> 

BY BRIAN SALA 

Small iDdcstrjal boilers snlJ stop burning coal and oil if tbe Environmental 

Protection Agency's rsrcend* proposed lacvi source performance standards 

ore implemented, representatives from hotter owners, roanufsctorer* tun. 

coal coi-spitnies said las? week la Durham, N.C. Tbe testimony came 8a 

r«ponse Jo a proposed EPA rule requiring new, small {100 to 250 million 

Biu) industrial boilers to anret both a 3.2 pounds sulfur diosjde per million 

jB.u emissions standard aad achieve a 90 percent SO* emissions redoctjoa, 

EPA's proposal to cut SOj emissions by 90 percent is "regulatory 

overkill," insisted William B. Marx, 

president of the Council of Industrial Boiler Owners (CIBO). The 

proposal docs not meet "ihe standards of cost effectiveness and 

reliability cited by the courts" in 

their interpretation ofthe Clean Air 

Act, he said, branding the proposals 

as "uDfair, unrealistic and 

untenable." 

Said James D. Beatty, an environmental technology manager 

for Procter & Gamble: "The proposed standards are counterproductive. They will not achieve our 

ujutuaj goaj ol cleaner air." 

The standard, which would require new industrial boilers to 

reduct SO, emissions by SO percent, 

compared to only 70 percent for 

utility boilers, ignore economic 

reality, Beatty said. "A recent 

CIBO survey showed that §0 percent 

of new industrial boilers were 

replacement units. These 

replacements were justified by 

economics as companies retired 

older, less efficient and more 

polluting units" with more efficient 

units which polluted less. "These 

proposed regulations increase both 

the capital cost and the operating 

cost of a replacement 

'boiler....[Replacementj Infers that' 

[previously may have been 

economically justified now will not 

be/ ' 

The National Coal Association is 

also worried about the proposals, 

said NCA spokesman Jerry Lombards The standards would divert 

industrial boiler operators from using coal, because "after 1990, a major portion of the large-scale steam 

industrial boiler population will 

have reached the end of its useful 

life and will be replaced." In order 

to cope with the standards, industry 

will be forced to turn to natural gas. 

This will cause coal to "lose a major 

portion of its existing market" 

because of the costs the standards 

would impose on coal users. 

Gas could soon be the fuel of 

choice for industrial boilers, agreed 

William Axtman, executive director 

of the Arlington, Va.-based 

American Boiler Manufacturers 

Association (ABMA). "The NSPS 

requirements will drive industrial 

fuel selection toward?gas," be said. 

"ABMA is opposed to a regulation 

that drives the industrial fuel selection to gas." 

But EPA disagrees. Although fuel 

switching from coal and oil is expected, said the agency, "the impact 

of this on coal, oil and natural gas 

markets would be small." 

The proposed standards are projected to reduce SOs

 emissions from 

530 to 2,670 tons a year par steaia 

generating unit. EPA estimates that 

by the fifth year of jmplenwatatioo, 

nationwide emissions would be cot 

by up to 320,000 tons per year. 

The boilerrnaker association 

questions EPA's projections. ABMA reckons growth rates for industrial boiler units are "well below 

EPA projections...land] therefore 

the overall effect of air quality improvements are mostly overrated." 

Typical small steam generating 

units will cost from 4:25 percent 

more with the new standards than 

without them, according to EPA 

estimates. Annualized costs would 

increase from 6-22 percent. Nationwide, says EPA, fifth-year annualized costs would bt about Si65 

million—or 4 percent—higher than 

at the regulatory baseline because of 

the new standards. 

The boiler owners charge that 

EPA is mistaken to place what ihey 

see as a heavy burden on American 

industry", particularly considering 

that industrial SO.- emissions have 

declined dramatically over the past 

decade—46 percent from 1972-39S4 

according to CIBO data. "Industry 

does not believe that Congress intended the 1977 Clean Air Act percent reduction requirement to apply 

to industrial units," said CIBO's 

Mars. "Even without further 

regulation, [industrial boiler emissions) would contribute less than 1.5 

percent of the total U.S. sulfur dioxide emissions." 

Added NCA's Lombardo: "EPA 

has not adequately demonstrated a 

technology for coal fired units after 

taking into consideration cost and 

encrev requirements, short of simply suggesting use of natural gas nationwide in this category of 

sources. " EPA is simply 

"establishing national energy policy 

without truly considering or analyzing the impact of that decision," ihe 

said. 

CIBO's EPA testimony com?s on 

the heels of objections it presented 

to the House Energy rind Commerce' 

Committee regarding proposed ;>.c!& 

IT ain legislation (HR C-S7). This oill 

seeks to include industrial boii«*r$ 

under a 1.2 pounds per million Btu 

sulfur emissions standard. 

EPA is scheduled lo issue- .<• final 

standard no bter then Decern L:<r 1, 

19S7. Tiie agency is -'iking for comment« fin »K>- WIP? .-tr,~i*^r*.ril Si. <rv» 
P.9 

A McGraw-Hill Publication VOL. 12 NO. S£ Septembers. 18&S 

ifvtuty^^ ^'•iwwiini * I'I » IT" rti 

An Inie'i.pt-nce Service fo' ERetuiivcn Covenng U5 Steam Coal Pntfci Wa-teu. Politic* 6 Economic 

, tJCESmt.rlJ'N.-WOIiKSa 

PP*1* «

,

*.**.*i*-jm*r'*'v&~* 

=MW*«» ^ w«#«.>«ifr«p*w^MW^.»»s3>s^fl^^ . -v**, 

O O VERNrVI Efof r 

NCA, BOILER OWNERS ATTACK EPA 

PROPOSAL ON SULFUR RESTRICTIONS 

Representatives from the coal and industrial boiler industries last 

week blasted the Environmental Protection Agency's new industrial boiler standards, calling on EPA to consider and resubmit 

a proposal limiting sulfur dioxide emissions for boilers smaller 

than 250 mrnBtu/hr. 

EPA's current proposal would require new or modified steamgenerated units of 100 rnmBtu/hr or more to make a 90% reduction in sulfur, dioxide emissions. Boilers with scrubbers would 

have to make a 50% cut. The rule would apply to industnal 

boilers, large institutional and cornmerciar-boilers and small utility boilers. 

The National Coal Assn., along with the Council of Industrial 

Boiler Owners, says such a standard would force many industrial coal users to switch to natural gas or to extend the lives of 

existing boilers, which are often dirtier and less efficient than 

new boilers on the market today. 

Instead, NCA urges EPA to resubmit a proposal that would 

limit emissions only from units larger than 250 mmBtu/hr. NCA 

says that EPA should determine from public comment whether 

a limit should be imposed on units between 100 and 250 

mmBtu/hr. 

In its testimony, CIBO proposes the following new source performance standard requirements: continue the current emission 

limit of 1.2 Ibs./mmBtu sulfur for industrial boilers larger than 

250 mmBtu/hr; apply a new limit of 1.6 Ibs./mmBtu sulfur for 

boilers between 100-250 mmBtu/hr; and to scrap the idea of a 

percentage reduction requirement. 

Comments on the EPA proposal are due Oct. 2. A 

standard is to be issued by Dec. 1,1987. 
•r i r. 

P.10 

CHEMICAL MARKETING REPORTER 

September 22 3986 

Iff, lo

r Kuiesiaiv 

p^i or* 

Environmental Protection Agency ts 

threatening lo hand American industry a 

Hobs.on'5 choice between unaffordable 

boiler emissions controls and limited 

fuel sources in order lo obtain minisculc 

environmental improvements, a group 

of industrial boiler owners- 5.1 ys. 

The Council ol Industrial iVdler Owners 

(CIBO). representing 50 US industrial firms 

that rely on a variety ol Joel sources Jor their 

operations, says that proposed limitations on 

Sulfur emissions from small, new. industrial 

boilers that burn coal or oil are unfair, unre-

alistic and untenable. 

The proposals. kno»n as New Source Per-

formance Standards (NSPS) for industrial 

boilers, would require 90 percent reductions 

in sulfur emissions from new equipment even 

though the agency estimates such equipment 

vill contribute at most only 1.5 percent of 

Iota) I'S sulfur emissions. CIBO says Utility 

emissions, which account for far more sulfur 

in the air. are not as lightly regulated.CJBO 

adds. 

STRINGENT REGULATIONS 

William B Mars, president of CIBO. says. 

"The only nay for us lo meet these regula-

tions and still be able to burn coal or oil will 

be to add extremely costly and unreliable 

desulfurization scrubbers Jo snew boilers. 

Scrubbers cos! as much as Ihe boiler itself — 

doubling She cost of even 3 small unit lo 

perhaps H million — and they cannot hold up 

to the 98 percent reliability demand of indus-

try " 

"Most of American industry w ill be forced 

lo jo olf coat and oil altogether as they eip.ind or replace existing boil?rs." Mr. Mara 

asserts 

"They will be forced to burn natural gas. 

e\en ihoupMhe ability to obtain it ons long-

term, non-mterruptible basis is a matter of 

dfbate. Furthermore, ttu> 197B Furl Use Act 

prohibits the use of natural gas as a fcoiler 

lucl unless an exemption ts obtained Indus-

try needs e&ore — r>ot IKS — flexibility to 

obtain th? snost economic luel Jor its toilers." 

Ironically. Qhe overly stringent NSPS will 

encourage eaduslry to cnlerxl th-r lives &f ?3-

iMinr. boilrn. uhicli arc dirtier and less G»JIicicnt than &rw boilers on th,- market 5o<5ay, 

Mr. Mara says "The f»l2 actually will kn-

ptnlc Improvement SHI iiir quality." he aays. 

"EPA elratly &ar. uol thought llbis rale 

through ratKKially." 

BOIIM Mj-reate-.sieam for Must ry's process 

us^s. space r.ealinj p.ad electricity produc-

tion They burn nol only fossil fuels but also 

plant-generated wastes and account for 

about two thirds of the fuel burned h\ indus-

try. 

The proposal discriminates against indus-

try $>) rrquwins; il lo mm.. pfirrnt sulfur 

reduction regardless of the fuel's sulfur con-

tent, while earlier NSI'S allowed utilities 

burning low-sulfur coal lo redure emissions 

by only 70 percent, CIBO says Utility boilers 

are about 30 times as bi£ as industrial units, 

and hence emit more. 

CIBO aLso comments that utility boilers 

have economies of scale that industrial units 

lack, making scrubbers proportionate less 

costly for them, and that utilities do not need 

the same reliability industry needs in boilers 

because utilities have interconnections 

through v. hich to get emergency povi er in the 

event that a boiler scrubber breaks down, as 

they often do. 

CIBO proposes She following ftSPS re-

quirements • Continuatio

n of the current emissions 

limit ot I 2 pounds sulfur per million Blu heat 

input for industrial boilers larger than 250 

million Btu 

o A new. emissions limit of 1 6 oounds sul-

fur per million Btu for small boilers (100 

million lo 250 million Btu) 

o No percentage reduction requirement, 

thereby allowing industry the freedom to 

choose the most economic fuel sources and 

most appropriate emission control technolo-

gies — including emerging technologies — to 

meet the emissions caps. 

"This NSPS fails lo meet criteria under the 

Clean Air Act — reaffirmed in court — Jor 

EPA to base its regulation ©n a cost-effec-

tive, achievable, reliable and adequately 

demonstrated control technology." Mr Mant 

concludes. 
INDUSTRIAL BOILER

 ± L 

NEW SOURCE PERFORMANCE STANDARD 

introduction 

Acid rain proposals have been a feature of the congressional 

scene for several years, the most recent being the SikorskiWaxman Bill, H.R. 4 567, now before the House Energy and Commerce 

Committee. This proposal would impose stringent emissions controls on virtually the entire range of industrial combustors, 

whether existing or new: boilers, heaters, kilns, furnaces and 

ovens, as well as additional controls on utility boilers. LESS 

KNOWN TO THE BUSINESS COMMUNITY, HOWEVER, THE ENVIRONMENTAL 

PROTECTION AGENCY HAS JUST PROPOSED STANDARDS FOR THE CONTROL OF 

S02 EMISSIONS FROM NEW INDUSTRIAL BOILERS, EVEN MORE STRINGENT 

THAN THE CURRENT UTILITY BOILER STANDARD. THUS AMERICAN MANUFACTURERS ARE FACING THE DOUBLE WHAMMY OF A STANDARD FOR NEW 

BOILERS ON TOP OF THE THREAT OF AN ADDITIONAL STANDARD REQUIRING 

EXPENSIVE CONTROL OF EXISTING UNITS. 

Background 

The standard proposed by EPA in June (Federal Regi ster 

6/19/86) would require expensive utility type control equipment 

on all industrial boilers above a certain size (heat input 

capacity of 100 million BTU/hr) even though their mean size is 

less than l/30th that of utility steam generators. This piece of 

regulatory overkill unfortunately, also ignores these facts: 

° Industrial boilers do not enjoy the economies of scale 

so that the American consumer ttfill pay up to 5x the cost 

per ton of pollutant removed, as compared to the less 

expensive utility control? 
Sndustsria l Boiler-NSP S ~~—:

 ; 

page 2 

* Industrial boilers serve many functions, experience a 

range of service loads, ©nd must be able to burn a wide 

variety of fuels, including process-generated wastes; 

° Industrial boilers do not have access to the back-up 

available to utility generators, i.e. the electrical 

grid, and thus demand a higher standard of boilercontrol equipment system reliability; 

° Industry operates in a competitive marketplace and can 

suffer irreparable financial damage when subject to 

unwarranted severe regulation; 

° Industrial boiler emissions are insignificant; even 

without further regulation would contribute less than 

1.5% of the total U.S. sulfur dioxide emissions. 

Importance of Industrial Steam; Industrial Energy Dse and Bmissions 

The importance of industrial steam is clear: approximately 

2/3 of all fuel burned by U.S. industry is consumed to raise 

steam. Virtually our entire manufacturing base depends on 

steam to produce its products, either for process use, to drive 

mechanical equipment, for space heating, or for on-site electricity generation. Because of these many steam uses, industry is 

able to use the maximum amount of heat present and this fact, 

together with vigorous industrial energy conservation, means that 

overall industrial energy efficiency is twice that of the utilities. 

Thus total industrial energy consumption has actually 

decreased from 1972-1984, according to the Department of Energy. 

Concurrently* industrial SO2 emissions in the same period havs 

p.12 
. P.13 

Industrial Boiler NSPS 

page 3 

declined 465, «a fact noted by the "Joint Report of the Special 

Envoys on Acid Rain.91 

Finally, industry does not believe that Congress intended 

the 1977 Clean Air Act precent reduction requirement to apply to 

industrial units, nor does the proposal meet the standards of 

cost-effectiveness and reliability cited by the courts. 

The frjeeds of Industry and the Public Interest 

No single domestic energy source has contributed more than 

coal towards American energy (and national) security, and yet 

as proposed, these New Source Performance Standards (NSPS) will 

stop industrial coal use for new boilers pushing industry once 

again towards insecure energy sources. To compete in international markets, industry must be assured a reliable supply of 

competitive fossil fuels, thus providing essential fuel flexibility; with promulgation of this standard and the consequent 

forclosing of the coal option, industry will lose this flexibility. 

Today much of U.S. industry has excess steam-generating 

capacity, and will add new boilers largely on a replacement 

basis. These new units will retire existing boilers, the net 

effect being a flat or declining U.S. boiler inventory in the 

near future. 

Thus investment in most new installations will be made only 

•v/hen sound financially. Because these boilers will generally 

be less polluting than those they replace, an automatic emissions 

reduction will be achieved. It is important„ therefore, that. 

regulation be cost-effective so that this process not ha 
„..„„ _ . _

 p14 

pagc 4 

'impeded. 

In most cases the present proposal will force the fuel 

switching referred to above, counter to the nation's energy 

policy. Khere a company wishes to burn coal, it smay be forced 

to use flue gas desulfurization (FGD or "scrubber") systems, 

which do not meet the 98% reliability criterion routinely 

demanded by industry. An unfortunate side result will be a 

drying up of funds for the development of promising emerging 

control technologies, which may be more cost-effective when 

brought to the commercial stage. 

Conclusion 

Sec. Ill of the Clean Air Act requires the EPA Administrator 

to establish NSPS "taking into consideration the cost of 

achieving such emission reduction". The District of Columbia 

Circuit Court has said that "... ..EPA... .must exercise its discretion to choose an achievable emission level which represents the 

best balance of economic, environmental and energy considerations..." Industry believes that in proposing these regulations 

EPA has clearly failed to achieve this balance and in so doing, 

added an unnecessary regulatory burden to the nation's basic 

industries,, now facing unprecedented competitive threats in the 

world marketplace. 

This proposal should be vigorously opposed by the industrial 

community.