Achievability of Proposed OilFired 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 0.00510.0080

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