## Achievability of Proposed Oil

Fired MACT Limits Environmental Energy Alliance of New York

## Disclaimer

• The following analysis does not necessarily reflect the final comments of the Environmental Energy Alliance of New York or any of its member companies

. • Purpose of presentation is to present our analysis and answer any clarifying questions EPA may have

• We understand that EPA may be able to provide some clarifying information but, as we are in the public comment period, EPA will not be able to provide detailed responses.

## Environmental Energy Alliance

of New York

• Provides New York State technical support for 

### regulatory and industry policy issues

• Membership includes electric and gas transmission and distribution, and electric 

### generation company members that provide energy services in New York

• Generation company members include: Con 

### Ed, Dynegy, GenOn , LIPA, National Grid, NYPA, NRG, TransCanada and Selkirk CoGen

## Roger Caiazza Background

• Five years experience with EPA consultants including air quality model evaluation

• Started at Niagara Mohawk in 1981 responsible for ambient and meteorological monitoring data submittals

• In 1993 was given responsibility for Part 75 CEMS data submittals and kept doing that at NMPC and NRG until September 2010.

• CEMS emphasis on validating data

• Limited stack testing background

## EEANY’s Oil

- Fired Generation Concern

• NY Oil

- Fired Generation

– Steam turbine oil

- Fired capability is 26.1% of total summer peak capacity (NYISO “Gold Book” 2011)

– Jet engine and combustion turbine another 8.8%

– 1990 23.6% of energy used to produce electricity

– 2006

- 2009 average of 3.2% due to cost

• New York Reliability Issues

– NYC local reliability “Minimum Oil Burn Rule”

– Winter curtailment when gas is needed for heating

– Back up capacity for emergencies

## Achievability

• “ Under section 112(d), EPA must establish emission standards for major sources that ‘‘require the maximum degree of reduction in emissions of the HAP subject to this section that EPA determines is achievable taking into account certain statutory factors .” p 24981 FR May 3 2011

• EEANY Conditions for Achievability

– Positive correlation between parameter fuel content and parameter stack emission rate

– The observed data must indicate that the derived limit could be achieved using available controls

## Methodology

• Correlation

– Calculate regression between fuel content and stack emissions for units without PM controls for metals and all units for acid gases

– Must be significant at 95% level

– Must be positive relationship

• Observations indicate achievability

– Plot observations against the limit

– Document number of tests that do and do not meet the proposed limits

## Regression Results Summary

• No Significant Correlation

– Antimony, Arsenic, Beryllium, Chromium, Cobalt, Lead, Manganese, and Selenium



### • Significant Negative Correlation

– Cadmium



### • Significant Positive Correlation

– Nickel, Hydrogen Fluoride, Hydrogen Chloride, and Total Metals

## Proposed Limits

• Table 11 Existing Units

– 0.000030 lb / mmBtu Total HAPS metals

– 0.00030 lb / mmBtu Hydrogen Chloride (HCL)

– 0.00020 lb / mmBtu Hydrogen Fluoride (HF )



### • No existing units use wet scrubber or dry sorbent injection to control HCL or HF

• Therefore we presume that the expected 

### control option is fuel standards (i.e. limits on the pollutant in the fuel)

## Total Metals

• Assume total metals in fuel = sum of each 

### metal in fuel

• Measured total metals in stack

• Input data from tab “Total Metals Oil” in “SG Floor Analysis Input Data.xls”

## Total Metals

– All Data

## Total Metals

– All Data with Fuel Limits

## Total HAP Metals Achievability

Total HAP Metals Maximum Average Guess Fuel Limit set at 0.0027 0.0010 0.0007 Tests meeting limit 19 10 10 Tests not meeting limit 24 8 5

## Total Metals

– No PM Controls

## Total HAPS Metals Achievability

No PM Controls Tests

No PM Controls Maximum Average Guess Fuel Limit set at 0.0027 0.0008 0.0007 Tests meeting limit 11 8 8 Tests not meeting limit 13 4 4

## HCL

## HCl Achievability

Hydrogen Chloride Maximum Average Guess Fuel Limit set at 0.0162 0.0051 0.0080 Tests meeting limit 15 9 12 Tests not meeting limit 33 14 25

## HF Fuel and Stack

## HF Achievability

Hydrogen Fluoride Maximum Average Guess Fuel Limit set at 0.0043 0.0014 0.0020 Tests meeting limit 24 17 17 Tests not meeting limit 13 10 10

## Implications of Results

• The data do not indicate that oil

- fired units 

### can achieve the proposed limits by limiting concentration of a pollutant in oil

• Very likely a function of both the analytical methods for both fuel oil and stack tests and the inherent variability of HAP composition and amounts in oil

## ICI Boiler MACT

• The inherent variability and unpredictability of the non - mercury metal HAP compositions and amounts in fuel has a material effect on the composition and amount of non

- mercury metal HAP in the emissions from the boiler

. • As a result, establishing individual numerical emissions limits for each non

- mercury HAP metal species is difficult given the level of uncertainty about the individual non

- mercury metal HAP compositions of the fuels that will be combusted.

• Page 15558 of the March 21, 2011 Federal Register

## Caiazza Recommendations

• Eagle Valley 1&2 and Eddystone 3&4 tests 

### should only be counted as a single test

• Sub

- categorize distillate and residual oil

## Identical Stack Tests

• The stack tests at two stations are considered 

### separate tests but the stack test results are identical

.
• Only one test of each should be used to determine the MACT floor levels

## Paired Stack Tests

– Total Metals

• There are 14 pairs of stack tests at the same station (11 with 2 tests and 1 with 3 tests)

• The average difference in the stack concentration measurements was 1.02E

- 4 or 34% of the proposed limit

• The maximum difference in the stack concentration measurements was 2.28E

- 4 or 76% of the proposed limit

• The minimum difference in the stack concentration measurements was 2.32E

- 6 or 1% of the proposed limit

### Sub
- Categorize Distillate and Residual Oil

• Distillate oil is refined (distilled) and is a clear 

### fluid at normal temperatures

• Residual oil is the what is left over, black and has to be heated to be burned

• Not surprisingly the four distillate tests are a disproportionate fraction of the seven MACT 

### floor results in the proposed rule

• Recommend using the ASTM definitions

## Questions?

• Roger Caiazza



### • Environmental Energy Alliance of New York

• 7679 Bay Cir



### • Liverpool, NY 13090

• Roger.Caiazza@gmail.com

• (315) 529

- 6711 EEANY cell