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OAR Box 1828 

Prepped by Ollie Stewart 

Document Number: 

319) IV-B-23 

Docket Number: 

A-83-27 

Printed 11/12/2008 11:12:59 AM Sheet 319 of 325 
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-«-> 

1 * RADIAN A-83-27 

CORPORATION IV-B-23 

MEMORANDUM 

DATE: June 15, 1987 

TO: Walt Stevenson, EPA/OAQPS/ESED 

FROM: David White, Radian Corporation 

SUBJECT: Impact of a 90 Percent SOp Reduction Standard on Annual SOEmissions 

1.0 INTRODUCTION 

Changes in SO- emissions resulting from new industrial boilers equal to 

or larger than 100 million Btu/hour heat input capacity were examined in 

Survey of New Industial Boiler Projects 1981-1984. The report concluded 

that although SOp emission rates (i.e., lbs SOp/million Btu of heat input) 

from the surveyed, new coal- and oil-fired boilers were 40 to 50 percent 

lower than from existing boilers firing the same fuel, total annual 

emissions from the surveyed plants increased from 103,838 tons prior to 

installation of the new boilers to 174,960 afterward--an increase of 68 

percent. This increase resulted from 1) installation of additional boiler 

capacity at new and existing plants, 2) increases in the use of coal 

relative to natural gas, and 3) continued operation of many existing boilers 

(although frequently at reduced load) after the new boilers were installed. 

This memorandum uses the data contained in Section 5 and 6 of the 

report to estimate reductions in SO, emissions that might have occurred if a 

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90 percent SO- reduction standard, similar to that proposed in June 1986, 

had been in place. This standard was modeled by assuming an average S0? 

emission rate of 0.2 lbs/million Btu for coal and 0.1 lbs/million Btu for 

oil. These rates were based on recent model boiler cost studies that found 

the least cost option (including both fuel and scrubbing costs) for 

compliance with a 90 percent standard was to use a coal with a controlled 

SO- emission rate between 0.07 lbs/million Btu (in Region VIII) to 0.22 (in 

Regions III and V) and an oil with a controlled emission rate of roughly 

3 

0.07 lbs/million Btu. The emission rates of 0.2 and 0.1 used for modeling 

therefore give a conservative estimate of potential emission reductions. 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park. N.C. 27709/(919)541-9100 
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Because a 90 percent reduction standard may have caused changes in the 

fuel choice, size, or overall design of the new boiler, or cancellation of 

the entire project, the magnitude of the projected emission changes on an 

annual tonnage basis is probably overstated. In an effort to account for 

this overestimation, the memorandum examines changes in estimated SOemissions resulting from deletion of "discretionary" projects (defined as 

projects undertaken for the primary purpose of fuel switching and 

cogeneration). These projects were determined by the above referenced 

survey of new boilers to be the most sensitive to project economics and, 

therefore, the most likely to be affected by an SO- reduction standard. 

2.0 RESULTS 

All Projects 

Annual SO- emissions from all of the surveyed boiler projects that 

contained at least one boiler of 100 million Btu/hour heat input capacity 

or larger are shown in Table 1. Emission rates and annual emissions under 

the existing standards (i.e., actual emissions from the surveyed boilers) 

are shown in the top half of the table; these data were taken directly from 

Tables 9 and 10 of Reference 1. The quantity of fuel used in billion Btu 

per year (MMMBtu/year) was "back calculated" based on the emission rate and 

annual emission data. 

As discussed earlier, the survey data indicate that installation of the 

new boilers increased total annual SO- emissions from these plants by 71,122 

tons (68 percent) relative to the level of emissions prior to their installation. By comparison, a 90 percent reduction standard would have reduced 

annual SO- emissions by 40,432 tons (39 percent) relative to their original 

level (assuming none of the new boiler projects would have been altered or 

cancelled as discussed above). The net decrease in annual emissions between 

the actual levels and those projected for a 90 percent reduction standard is 

111,554 tons. 

Exclusion of Fuel Switching Projects 

Because of changes in the relative prices of coal, oil, and natural gas 

since the time period covered by the survey (i.e., 1981-1984), fewer new 

boilers are likely to be constructed in the future for the purpose of 
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switching from oil or natural gas to coal than during the survey period. 

Table 2 summarizes projected emissions if all the new boilers constructed 

for the primary purpose of fuel switching are excluded from the analysis. 

It was assumed that the emission rates for these boilers are similar to the 

rates for all the boilers surveyed; as a result, the baseline emission rates 

are the same as for all the boilers. 

Elimination of fuel switching projects reduces total annual emissions 

from existing boilers prior to installation of new boilers to 73,801 tons. 

Under the existing standards, installing the new boilers resulted in an 

emissions increase of 27,262 tons per year (37 percent). A 90 percent 

standard would have lowered annual emissions by 21,937 tons (30 percent) 

relative to those prior to the new boilers. The net decrease 1n annual 

emissions from the new boiler projects resulting from the 90 percent 

reduction standard is 49,199 tons. 

Exclusion of Fuel Switching and Cogeneration Projects 

Although less cost sensitive than projects installed for the primary 

purpose of fuel switching, installation of cogeneration boilers may also be 

reduced by current energy prices and utility regulatory policies which make 

cogeneration less economically attractive than during the survey period. 

Table 3 summarizes the emission changes if both fuel switching and 

cogeneration projects are excluded from the analysis. 

Eliminating these boilers decreases total emissions from existing 

boilers to 70,748 tons per year. Based on the survey data, the emissions 

increase from new boiler installations was 12,519 tons per year 

(18 percent). A 90 percent standard would have reduced annual emissions by 

an estimated 23,074 tons (33 percent) relative to the level prior to installation of the new boilers. The net decrease in annual emissions from the 

new boiler projects resulting from the 90 percent reduction standard is 

35,593 tons. 

3.0 CONCLUSIONS 

While this analysis is not intended as a precise forecast of future 

SO- emissions, it does provide insight into the relative impact of a 90 

percent reduction standard. Depending on whether fuel switching and 
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cogeneration boilers are included in the analysis, actual emissions from 

new boiler projects installed between 1981 and 1984 increased by 18 to 68 

percent. Based on the above analysis, annual emissions resulting from a 

90 percent reduction standard would have been 25 to 31 percent below the 

original emissions total. Relative to the projected annual emissions from 

new projects under existing regulatory programs, the projected emissions 

associated with the 90 percent reduction standard are an estimated 40 to 59 

percent lower. 

4.0 REFERENCES 

1. U.S. Environmental Protection Agency. Survey of New Industrial Boiler 

Projects 1981-1984. Publication No. EPA-450/3-87-006. Research 

Triangle Park, NC 27711. 

2. 51 Federal Register. 22385, June 19, 1986. 

3. Memorandum for Martinez, J. A., and E. F. Aul, Radian Corporation, to 

Porter, F. L., and W.H. Stevenson, EPA/OAQPS/ESED, May 15, 1987. 

Assumptions and Procedures Used to Generate Model Industrial Boiler 

Cost and Cost Effectiveness Estimates. 
< > -\ 

TABLE 1. COMPARISON OF S02 EMISSIONS FROM ALL PROJECTS 

MMBtu/year 

Standard Boiler Type Fuel Before After 

lb S02/MMBtu 

Before After 

Tons of S02 

Before After Change 

Existing New Coal 0 

Oil 0 

Existing Coal 42,841 

Oil 42,144 

Total 256,390 

155,514 

24,619 

34,549 

3,760 

440,151 

0.00 

0.00 

2.89 

1.99 

0.81 

1.47 

1.14 

2.49 

1.92 

0.80 

0 

0 

61,905 

41,933 

103,838 

114.303 

14,033 

43,014 

3,610 

174,960 71,122 

90% Reduction New 

Existing 

Total 

Coal 

Oil 

Coal 

Oil 

0 

0 

42,841 

42,144 

256,390 

155,514 

24,619 

34,549 

3,760 

440,151 

0.00 

0.00 

2.89 

1.99 

0.81 

0.20 

0.10 

2.49 

1.92 

0.33 

0 

0 

61,905 

41,933 

103,838 

15,551 

1,231 

43,014 

3,610 

63,406 -40,432 
TABLE 2. COMPARISON OF S02 EMISSIONS EXCLUDING FUEL SWITCHING PROJECTS 

MMBtu/year 

Standard Boiler Type Fuel Before After 

lb S02/MMBtu 

Before After 

Tons of S02 

Before After Change 

Existing New 

Existing 

Total 

Coal 

Oil 

Coal 

Oil 

0 

0 

42,841 

11,956 

182,225 

72,771 

5,749 

34,549 

1,339 

254,247 

0.00 

0.00 

2.89 

1.99 

0.81 

1.47 

1.14 

2.49 

1.92 

0.80 

0 

0 

61,905 

11,896 

73,801 

53,487 

3,277 

43,014 

1,285 

101,063 27,262 

90% Reduction New 

Existing 

Total 

Coal 

Oil 

Coal 

Oil 

0 

0 

42,841 

11,956 

182,225 

72,771 

5,749 

34,549 

1,339 

254,247 

0.00 

0.00 

2.89 

1.99 

0.81 

0.20 

0.10 

2.49 

1.92 

0.44 

cn 

0 

0 

61,905 

11,896 

73,801 

7,277 

287 

43,014 

1,285 

51,864 -21,937 

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TABLE 3. COMPARISON OF S02 EMISSIONS EXCLUDING FUEL SWITCHING AND COGENERATION PROJECTS 

MMBtu/year lb S02/MMBtU Tons of SO. 

Standard Boiler Type Fuel Before After Before After Before After Change 

Existing New 

Existing 

Total 

Coal 0 

Oil 0 

Coal 40,958 

Oil 11,621 

174,686 

51,384 

5,700 

32,905 

1,338 

209,477 

0.00 

0.00 

2.89 

1.99 

0.81 

1.47 

1.14 

2.49 

1.92 

0.80 

0 

0 

59,185 

11,563 

70,748 

37,767 

3,249 

40,967 

1,284 

83,267 12,519 

90% Reduction New 

Existing 

Total 

Coal 0 

Oil 0 

Coal 40,958 

Oil 11,621 

174,686 

51,384 

5,700 

32,905 

1,338 

209,477 

0.00 

0.00 

2.89 

1.99 

0.81 

0.20 

0.10 

2.49 

1.92 

0.48 

0 

0 

59,185 

11,563 

70,748 

5,138 

285 

40,967 

1,284 

47,674 -23,074 

Tl 

00