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OAR Box 1865 

Prepped by Charmelle Mathews 

Document Number: 

154) VI-E-3 

Docket Number: 

A-83-27 

Printed 12/3/2008 3:22:21 PM Sheet 154 of 198 
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% / 4 ^ \ UNITED STATES ENVIRONMENTAL PROTECTION / w * • • 

v f r^jgK** |* Office of Air Quality Planning and Standards V I F , 

<A \\|4 Z < Research Triangle Park, North Carolina 27711

 J 

2 5 AUG 1988 

MEMORANDUM 

SUBJECT: Council of Industrial Boiler Owners (CIBO) Meeting to 

Discuss the Industrial Boiler Sulfur Dioxide (SO2) New 

New Source Performance Standards (NSPS) 

r;p=~-t

 {C^ -4—7 

FROM: Fred Porter, Chief V^ A *-

 N <^KX-'~ 

Regulations Development Section, SDB (MD-13) 

TO: Docket (A-83-27) 

A meeting was held on Wednesday, August 10, with CIBO as a follow-up 

to the July 14, meeting between CIBO and Administrator Thomas. The 

following people attended this meeting: 

EPA CIBO 

Don Clay John O'Connor Bill Marx Jan Vlcek 

Jerry Emison Jack Farmer Jim Beatty Harry Cameron 

Rob Brenner Chris Herman Lawren Laabs Carol Emery 

Fred Porter Lydia Wegman John Stier 

Following introductions, Don Clay stated that the Agency was reviewing 

the material CIBO submitted at the last meeting. He also indicated that 

much of this material duplicated materials CIBO had submitted in the past 

and went on to ask if CIBO planned to submit any additional information. 

Jim Beatty of CIBO agreed that much of the material submitted at the last 

meeting had been submitted in the past and stated that CIBO had no plans 

to develop or submit additional information. 

Jim Beatty then asked if Don Clay's observation implied that the 

Agency felt that CIBO's concerns with the NSPS had little merit. Don Clay 

responded that the Agency's conclusions would be laid out in a formal 

response to CIBO's Petition for Reconsideration. 

Jim Beatty then indicated that CIBO had a proposal they would like 

the Agency to consider, at which point the attachment was distributed. 

Before outlining CIBO's proposal, Jim Beatty stated that if the Agency 

would amend the industrial boiler NSPS along the lines of CIBO's proposal, 

then CIBO would drop all litigation. 
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In the ensuing discussion of CIBO's proposal, CIBO made the following 

points: 

1. Percent reduction is not required under Section 111 if the Agency 

considers the potential impacts of standards requiring percent reduction 

to be unreasonable. Thus, the fundamental question is whether the impacts 

of a standard requiring percent reduction were considered unreasonable. 

2. CIBO felt that ample evidence exists on each of the following 

points which clearly indicates that the impacts of a percent reduction 

standard are unreasonable: 

a. A percent reduction imposes extremely high costs. 

b. The technology necessary to achieve a percent reduction has not 

been demonstrated to be able to achieve a percent reduction on a continuous 

and reliable basis. 

c. The resulting shift in industrial fuel use from coal to natural 

gas, as a result of the high costs and lack of demonstrated technology to 

meet percent reduction standards, imposes unreasonable constraints on 

industry's ability to develop fuel flexibility to guard against future 

changes in fuel prices and fuel shortages. 

3. CIBO also felt that their proposal was superior to the current 

NSPS from an environmental viewpoint for the following reasons: 

a. CIBO's proposal would not result in generation of substantial 

quantities of liquid and/or solid wastes. 

b. Most new boilers are replacements for existing boilers and this 

results in a gradual decrease in existing emission levels, since new 

boilers have lower emissions than existing boilers. Percent reduction 

requirements will discourage this replacement process, thus effectively 

resulting in an emissions increase. CIBO's proposal, on the other hand, 

would not inhibit this replacement process and emissions would continue 

to decrease as new boilers replaced existing boilers. 

Attachment 
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L 

Gilo® 

COUNCIL OF INDUSTRIAL BOILER OWNERS 

PRESIDENT 

WjlliamBMan

 INDUSTRIAL BOILER NSPS 

For Coal Primary Fuel Fired Boilers: 

1.2 lb S02/MM BTU (greater than 100 MM BTU/hr) and no 

percent reduction 

exclusion from emission limits during periods of startup, shut-down, and malfunction 

no continuous emission monitoring for SO2 and NOx; use 

monthly average fuel analyses (as mined) 

NOx limit for preheated air units (less than 70,000 

BTU/hr/ft3) of 0.4 for gas and 0.6 for oil 

For Oil Primary Fuel Fired Boilers: 

0.8 lb S02/MM BTU (greater than 100 MM BTU/hr) and no 

percent reduction 

exclusion from emission limits during periods of startup, shut-down, and malfunction 

no continuous emission monitoring for S02 and NOx; use 

monthly average fuel analyses 

For Emerging Technologies: 

correct to be consistent with above 

Technical corrections: 

exclude recovery boilers 

modify the definitions of coal, natural gas, distillate 

oil, residual oil, and wood 

opacity exception of 27% for one-6 minute period per hr 

exemption from continuous opacity monitoring for wet 

scrubbers 

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