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OAR Box 1865 

Prepped by Charmelle Mathews 

Document Number: 

155) VI-E-4 

Docket Number: 

A-83-27 

Printed 12/3/2008 3:22:21 PM Sheet 155 of 198 
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UNITED STATES ENVIRONMENTAL PROTECTION / A-83-27 

, 0 Office of Air Quality Planning and Standards 

"/ Research Triangle Park, North Carolina 27711 VI-E-4 

\ 

2 2 SEP 1988 

MEMORANDUM 

SUBJECT: American Paper Institut e Meeting - Industria l Boile r SO2 NSPS 

FROM: Fred Porter '^r , ^. v~r^b ~ 

Standards Development Branch, ESD (MD-13) 

TO: Docket A-83-27 

At the request of the American Paper Institute (API), a meeting was 

held on September 13 to discuss their Petition to Reconsider the new source 

performance standards (NSPS) limiting sulfur dioxide (SO2) emissions from 

new industrial-commerical-institutional steam generating units with a heat 

input of more than 100 million Btu per hour. The following individuals 

attended the meeting: 

EPA API 

Jerry Emison 

John O'Connor 

Jack Farmer 

Fred Porter 

Bil l Maxwell 

Mike Winer (by phone) 

Chris Herman (by phone) 

Lisa Ryan (by phone) 

Mathew Van Hook 

James Walpole 

O.B. Burns 

John Pinkerton 

Peter Chamberlain 

API opened the meeting by stating that, as discussed in their Petition 

for Reconsideration, their major concern is the lack of provisions in the 

NSPS permitting increased emissions of SO2 during periods of start-up, 

shut-down, and malfunction of the SO2 control system installed to meet the 

standards on coal-fired boilers. They feel that the use of natural gas or 

very low sulfur oil (ie., 0.3 lb SO2/MM Btu) during these periods, which 

would be necessary in their opinion to comply with the standards as they 

are currently drafted, is unreasonable. Natural gas and very low sulfur 

oil are either unavailable or too expensive. 

API then turned to a discussion of natural gas demand charges for 

noninterruptible gas. Demand charges are an annual surcharge or fee one 

must pay to ensure that a certain supply of natural gas will be avavilabe 

upon demand at any time. These charges must be paid whether one actually 

uses any gas or not and are in addition to the cost of any gas actually 

used. 
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These annual demand charges are fairly uniform across the U.S. and 

generally range from as low as 7 dollars per million Btu per hour per month 

(ie., 7 $-hr/MM Btu-month) to as much as 12 dollars per million Btu per 

hour per month. API felt that an average of 9 $-hr/MM Btu-month was a 

good average to use in any calculations examining this aspect of the cost 

impacts associated with the standards. 

This discussion of annual demand charges was then followed by discussion 

of the use of spare modules or spare equipment to increase the reliabilty of 

the S02 control systems installed to comply with the standards. API felt 

that the costs associated with this approach were also unreasonable. 

The discussion then turned briefly to the use of very low sulfur oil. 

API felt that the amount of oil they would need to store on site and the 

tankage necessary for this oil, in addition to the costs involved, also 

made this approach unreasonable. The meeting concluded with a brief mention 

of the use of liquified petroleum gas (LPG) during periods of start-up, 

shut-down, and malfunction. API indicated that they were not aware of 

anyone using LPG as a back-up or stand-by fuel.