p.1 

OAR Box 1828 

Prepped by Ollie Stewart 

Document Number: 

316) IV-B-20 

Docket Number: 

A-83-27 

Printed 11/12/200811:12:59 AM Sheet 316 of 325 
P.2 

9 

n RADIAN A-83-27 

*^|L CORPORATIO N IV-B-20 

MEMORANDUM 

To: Walt Stevenson, EPA/OAQPS/ESED 

From: David White, Radian Corporation 

Date: April 30, 1987 

Subject: Critique of the CIBO Boiler Replacement Survey 

1.0 INTRODUCTION 

In September 1984, the Council of Industrial Boiler Owners (CIBO) 

surveyed a number of industrial boiler owners regarding completed, underway, 

and planned installations of industrial boilers between 1979 and 1988. On 

July 30, 1985, CIBO sent EPA a letter containing their interpretation of the 

survey. Based on these data, CIBO concluded that 1) roughly 80 percent of 

the new boilers were replacements for existing boilers and 2) installation 

of new industrial boilers resulted in a decrease in overall S0? emissions. 

The second conclusion was based on CIBO's finding that most of the new 

boilers replaced older, less efficient boilers that had higher emissions 

than new boilers. 

This memorandum reviews the raw data collected by CIBO and critiques 

the methodology used in its interpretation. The CIBO results are also 

compared to a subsequent survey conducted by EPA. 

2.0 REVIEW OF THE CIBO SURVEY DATA 

Design of the Survey Form 

The CIBO survey form (see Appendix A) consists of a one-page questionnaire divided into three sections: 1) projects finished since 1979 or 

currently under construction (Section A on the form), 2) projects funded but 

not yet constructed (Section B), and 3) projects planned through 1988, but 

not yet funded (Section C) . Only boilers with a capacity of 80,000 lbs 

steam/hr (pph; roughly equal to 100 million Btu/hr heat input) were to be 

listed. Whether the recipients received additional instructions explaining 

how to complete the form is not known. 

Progress Center/3200 E. Chapel Hill Rd./Nelson Hwy./P.O. Box 13000/Research Triangle Park, N.C. 27709/(919)541*9100 
I! 

Review of the survey form suggests that data for new boilers (including 

steam capacity, fuel, and projected annual S02, PM, and NO emissions) were 

to be listed on the left side of the form. Comparable data on existing 

boilers that were replaced by the new boilers were to be listed on the right 

side of the form. A completed form that listed data on both the left and 

right sides would presumably identify a replacement boiler. Expansion 

boilers (i.e., those not replacing an existing boiler) would have data only 

on the left side of the form. The form did not ask for information on why 

the new boilers were installed or what happened to the existing boilers. 

Using only the data contained on the form, classification of boilers as 

replacement versus expansion is uncertain in many situtations. For example, 

a large new boiler installed to meet additional steam demand at an enlarged 

manufacturing plant could be classified as a replacement for an existing 

boiler that was too small to meet the plant's increased steam demand. An 

alternate, and perhaps more appropriate interpretation, would be that the 

new boiler was an expansion boiler installed because of increased steam 

demand. It is also difficult to determine whether a new boiler was 

installed to replace an existing boiler at the same site or to supply steam 

to a new plant which was built to replace an existing plant located 

elsewhere in the country. While the net impact on boiler capacity is 

similar in both cases, knowing why a new boiler was installed is important 

in assessing future boiler sales and emissions. 

Composition of the Sampled Boilers 

Twenty-seven completed survey forms, termed "case histories" by CIBO, 

were included in the CIBO letter to EPA (see Appendix B). How these 27 

respondents were selected or how many additional companies received the 

survey, but did not return it, is unknown. Because such information is 

essential for judging whether a survey is representative of a larger 

population, it is difficult to generalize the CIBO survey results to the 

total number of new boilers installed. 

Review of the Survey Responses 

Boiler information was submitted on 26 of the 27 survey forms (Survey 

#7 indicated that no new boilers were built or planned). Examination of the 
completed forms suggests that not all of the respondents had the same 

understanding of how to complete the survey form. As a result, differences 

exist on the forms which complicate their interpretation. For example, two 

respondents (Surveys #11 and #24) appear to have listed new replacement 

boilers on the right side of the form, rather than the existing boilers that 

were replaced. On another form (Survey #9), Section A lists 44 new coalfired boilers with a total capacity of 8.69 million pph. This total equals 

roughly one-third of the combined capacity of all coal-fired boilers sold in 

the U.S. between 1979 and 1984 based on sales data compiled by the American 

Boiler Manufacturers Association (ABMA). Based on available boiler sales 

data, installation of such a large percentage of total boiler capacity by a 

single respondent seems unlikely and makes interpreting the form difficult. 

The emissions data on each survey form are another potential source of 

error due to incomplete responses. The survey form asked for annual 

emissions from the new boilers and from the existing boilers that were 

replaced. Information on emissions from the existing boilers after the new 

boilers were installed was not requested. Thus, emissions from existing 

boilers that were kept in service at reduced loads or for peaking purposes 

are not included in the CIBO data. Also, many respondents did not provide 

emissions data at all, while others included estimates only for NO and 

particulate; SO- data are presented on only 10 of the 27 survey forms. 

3.0 CIBO ANALYSIS AND INTERPRETATION OF SURVEY DATA 

CIBO's tabulation of the survey data was contained in its letter to EPA 

(see Appendix C) . These data, organized by survey number and boiler (but 

without consideration of whether the boiler was constructed,' funded, or 

planned), were summed to determine the total number of units, total 

capacity, and total S02 emissions. No effort was made to adjust the totals 

for missing data. 

Review of CIBO's tabulation found a number of apparent classification 

errors and omissions resulting from mishandling and misinterpretation of the 

raw survey data. For example, the 390,000 pph expansion boiler on Survey #5 

was omitted from the tabulation while the 600,000 pph boiler of Survey #25 

was counted three times--twice as an expansion boiler and once as a 
P.5 

replacement boiler. Survey #12 includes two new boilers that are replacing 

five existing boilers; however, all seven boilers were listed as replacement 

boilers in the tabulation. CIBO also classified four boilers on Survey #15 

and three boilers on Survey #22 as replacement boilers, even though the 

survey sheets showed no replaced capacity. The respondent's apparent 

misinterpretation of the survey form on Survey #24 (discussed in Section 2) 

resulted in CIBO classifying all eight new boilers as replacements rather 

than as three expansions and five replacements. Survey #26 was tabulated as 

10 separate boilers totaling 4.9 million pph of capacity; based on the 

footnotes on the survey form, however, it appears there were only 5 new 

boilers totaling roughly 2.5 million pph (the other listings include conversion of an existing boiler from oil to coal and variations in boiler capacity and emission rates for two boilers capable of firing different fuels 

and fuel combinations). Survey #16 was also a conversion of an existing 

boiler from oil to coal, not an installation of a replacement boiler. The 

tablulation also includes several boilers on Surveys #9 and #20 that are 

below the 80,000 pph minimum size limit specified in the survey (and thus 

should not have been included in the analysis). 

There were also problems deciding how to interpret responses on some of 

the survey forms. For example, Surveys #5 and #23 list new boilers which 

are much larger than the boilers they replaced, suggesting that expansion of 

steam supply was probably the primary reason for building the new boilers 

rather than replacement of existing boilers. It is also unclear whether the 

cogeneration boilers listed on Surveys #6 and #20 should be considered 

replacements for the existing process steam boilers or as expansion boilers 

providing steam for new turbines used to generate electricity; CIBO classified them as replacement boilers. Classification of the boilers on Survey 

#9 is also difficult because of uncertainties in how to read the survey form 

and the extremely large number of boilers listed (see Section 2). 

If the above errors are corrected, the percentage of new boilers 

installed as replacements would have been roughly 60 percent, rather than 80 

percent as CIBO concluded. 
P.6 

Sulfur Dioxide Emissions 

The second major conclusion drawn by CIBO was that total S02 emissions 

decreased because of boiler replacements. As stated previously, because of 

missing S02 data on most of the survey forms, this conclusion was based on 

data from just 10 of the 27 surveys. These 10 surveys include data on 31 

new boilers, or roughly 25 percent of the new boilers covered by the survey. 

Of these 31 boilers, CIBO classified 29 (94 percent) as replacements and 2 

(6 percent) as expansions. Based on this high percentage of replacement 

boilers, CIBO's conclusion that installation of new boilers decreases net 

S 02 emissions is understandable. However, as discussed above, CIBO's data 

indicate that installation of new expansion boilers accounts for roughly 40 

percent of new boiler sales rather than 6 percent as represented in the S02 

data. Because new expansion boilers contribute new emissions that are not 

offset by reduced emissions from existing boilers, the under-representation 

of these boilers in the emission data represents a major source of statistical bias in any subsequent analysis of emissions. The CIBO methodology 

also fails to include emissions from the "replaced" boilers that continue 

operating (although frequently at reduced loads) after new boilers are 

installed. Because these omissions result in underestimating total S02 

emissions, the conclusion that total emissions decrease may be simply the 

result of incomplete data. 

4.0 COMPARISON WITH EPA'S BOILER REPLACEMENT SURVEY 

During the summer of 1986, EPA conducted a much larger and more 

2 

detailed survey of industrial boiler sales between 1981 and 1984. The 

survey included 115 boiler projects comprising a total of 155 new boilers 

larger than 100 million Btu/hr and 291 existing boilers. Only projects 

actually built were surveyed. Based on comparison with ABMA sales data, the 

survey reflects essentially 100 percent of the industrial boilers sold in 

this size range during the survey period. 

In addition to statistics on boiler size and S02 emissions, EPA also 

collected information on why the new boilers were ordered, the key decision 

variables and economic sensitivity affecting the design of the project, and 

the operational status of the existing boiler(s) after installation of the 
P.7 

new boiler(s). This section briefly reviews the similarities and 

differences between the CIBO and EPA surveys. 

Replacement Versus Expansion Boilers 

The EPA survey asked each respondent to specify the reason for installing a new boiler. Based on these responses, EPA concluded that 50 percent 

of the projects installed new boilers as replacements for existing boilers 

(related to fuel switching and replacement of boilers in poor condition) 

while the balance were for new applications (additional capacity at an 

existing site, construction of a new plant, and cogeneration). This 

compares to CIBO's original estimate of 80 percent and the revised estimate 

of roughly 60 percent. 

Some of the differences between these numbers reflect the uncertainty 

in the CIBO survey data of whether a new boiler recorded as a replacement 

was installed to replace a boiler at the same plant or at a different 

location. EPA's survey limited replacement to mean installation at the same 

plant. If the CIBO data were adjusted for this definitional difference, the 

percentage of replacement boilers in the CIBO survey would probably be 

lower. As a result, it appears the EPA survey and the adjusted analysis of 

the CIBO survey both found that for the time period surveyed, replacement 

boilers represent roughly 50 percent of new boiler sales. 

Change in Sulfur Dioxide Emissions 

The EPA survey concluded that S02 emissions from plants installing new 

boilers between 1981-1984 increased by 68 percent (174,960 annual tons after 

the new boilers were installed versus 103,838 annual tons before). Of the 

total emissions after installation of the new boilers, 73 percent were from 

new boilers while the remaining 27 percent were from continued operation of 

existing boilers at reduced load. Estimated emissions from continued 

operation of the existing boilers were not included in the CIBO analysis. 

If emissions from continued operation of existing boilers were excluded from 

the EPA survey data, S02 emissions would have still increased by 24,498 tons 

(24 percent). Key factors influencing the differences in the overall 

conclusions reached by the CIBO and EPA surveys appear to result from the 

lack of data in the CIBO survey on emissions from new expansion boilers and 

from existing boilers after the new boilers are installed. 
P.8 

5.0 REFERENCES 

1. Letter from William B. Marx (Council of Industrial Boiler Owners) to 

Fred L. Porter (OAQPS/EPA), dated July 30, 1985. 

2. U. S. Environmental Protection Agency, Survey of New Industrial Boiler 

Projects--1981-1984. EPA-450/3-87-006. April 1987. 
P.9 

APPENDIX A 

CIBO SURVEY FORM 
Number and. 

Capacity 

• 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced 

_ SO- PM and NOx Number and. 

Fuel Emissions Capacity Fuel 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

2-Digit SIC 

(If Applicable) 

SO, PM and NOx 

Emissions 

100 MMB) 
p.11 

APPENDIX B 

CIBO SURVEY DATA 
1. 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

SO PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

S02 PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1-350,000 #/HR Bark/Coal/Oil .7 100,000 ff/HR 

4 35,000 #/HR 

75,000 #/HR 

60,000 tf/HR 

#6 Oil 

#6 Oil 

#6 Oil/Bark 

#6 Oil/Bark 

.7 .7 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

26 2-Digit SIC 
2„ 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (IC Applicable 

Number and. 

Capacity Fuel 

SO PM and NOx 

Emissions 

Number and. 

Capacity 

SO PM and NOx 

Fuel Emissions 

1-2 50 KLBS/HR 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

PC 

B. 

1-20 KLB/HR 

1-60 KLB/HR 

1-30 KLB/HR 

1-80 KLB/HR 

1-19 KLB/HR 

INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

N. Gas 

N. Gas 

N. Gas 

N. Gas 

N. Gas 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

26 2-Digit SIC 
3. 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boiler: Boiler(s) Replaced (If Applicable 

Number and. 

Capacity 

SO„ PM and NQx 

Fuel' E missions 

9> Number and. 

Capacity ' Fuel 

S02 PM and NOx 

Emissions 

INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1979 1-150,000 lbs/HR Coal 

1983 1-100,000 lb/HR Coal 

1980 1-150,000 lb/HR Wood 

0.251b/lMM BTUS (PM) 

0.161b/IMM BTUS (PM) 

None 

B. INSTALLATIONS FUNDED 

-None- -NoneC. INSTALLATIONS PROJECTED (To 1988) 

-None- -None-

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

22 2-Digit SIC 
BOILER "EXPANSION-REPLACEMENT" SURVEY * ** 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and, 

Capacity 

SO- PM and NOx 

Fuel Emissions 

Number and. 

Capacity ' Fuel 

S0? PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1-88,000 #/HR Coal 

(105 Btu/hr) 

B. INSTALLATIONS FUNDED (to start-up in 1985) 

1-20,000 U/HR Oil, Gas 

1-10 0,000 #/HR Oil, Gas 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

JLSL 2-Digit SIC 
BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boilcr(s) Replaced (If Applicable) 

Number and. 

Capacity 

SO- PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

SO PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1 - 390,000 #/HR Coal if 100% Coal 24-43' 228 1596 None 

& (1232) 

Wood- if 100% WW 0 270 1961 

waste 

1 - 770,000 #/HR Pulv. Coal 4329 359 2165 1-145,000 8/HR #6 Oil 2094 76 296 

B. INSTALLATIONS fruN^ED-300 */"*- *6 0i l 16fi5 60 234 

None 

C. INSTALLATIONS PROJECTED (To 1988) 

None 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

26 _2-Digit SIC 
G: 

Boiler "Expansion-Replacement" Survey 

New Boilers Boilers Replaced 

No. and Capacit y ( D 

A. Installations 

Finishe d 

1-Gas turbine/HRSG 

36 MW, 180,00 0 lb/hr 

steam 

B. installation s 

Funded 

1-Gas turbinc/HRSG 

45 MW, 300,00 0 lb/ht 

steam 

C. projected 

Installations 

Gas turbine/HRSG 

95 MW/500,000 lb/hr . 

steam (4 units) 

i 

Gas turbine/HRSG 

95 MW/125,000 lb/hr . 

3team (4 units) 

Fuel 

Gas 

Gas 

Coal/ 

Wood 

Coal/ 

Wood 

S 0 2 

0 

0 

1020 

68 0 

PM 

15 

5 

124 

186 

NOx 

342 

719 

928 

928 

No. and Capacit y ( 1) 

2-300,00 0 lb/hr.stm . 

» 

2-300,00 0 lb/hr.stm . 

2-550,00 0 lb/hr . stm. 

2-wood 

6-oil/ga s 

1,030,00 0 lb/hr . stm. 

Fue l 

Gas/ 

O il 

Gas/ 

O il 

Gas/ 

oil 

Gas/ 

O il 

Wood 

SO 2 

328 

28 

1421 

1613 

PM 

39 

8 

113 

422 

NOx 

49 3 

406 

891 

164 2 

(1) Total capacity lbs/hr steam 

SIC 26 
/. 

m 

DOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boiler3 Boiler(s) Replaced (If Applicable) 

Number and, _ SO PM and NOx Number and, SO. PM and NOx 

Capacity Fuel Emissions Capacity Fuel Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

>80,000 »/HR None 

B. INSTALLATIONS PUNDED »• 

>80,000 l/HR . None 

C. INSTALLATIONS PROJECTED (To 1988) 

Unknown. Possible conversion to coal/ 

liquid slurry for 1-2 Boi1, 'is in this 

size range. Dependent upon available 

technology. 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

20. 10. Tfi 2-Dlqit SIC 
BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and, _ S02 PM and NOx Number and, SO_ PM and NOx 

Capacity Fuel Emissions Capacity Fuel Emissions

 3 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

NO - .42 lbs/106 BTU 

2-75,000 #/HR Coal Paift. - .058 lbs/106 BTU 2-42,000#/HR Oil/Gas No Test Data 

(.8 Sulphur) 1 1/2-2% Sulphur 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

Start Up Jan Or Feb 1985 

1-150,000 S/HR Coal 3-100,00 #/HR Oil/Gas No Test Data 

(.8 Sulphur) ! 1/2-2 1/2% Sulphur 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

22 2-Digit SIC 
BOILER "EXPANSION-REPLACEMENT" SURVEY * 

t 

New Boilers Boiler(s) Replaced (If Applicable) 

i 

Number and, _ S0„ PM and NOx Number and, S0_ PM and NOx 

Capacity Fuel Emissions Capacity Fuel Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

9-150,000 Coal 

2-300,000 Coal 

4- 60,000 Coal 

15-240,000 Coal 

1-300,000 Coal 

13-200,000 Coal 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

13-240,000 

2-240,000 

1-300,000 

13-200,000 

Coal 

Oil, Gas 

Coal 

. Coal 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

37 2-Digit SIC 
10 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

_ SO_ PM and NOx 

Fuel Emissions 

Number and. 

Capacity

 J Fuel 

S0? PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

No. 1 Coal Boiler Bituminous SO = 3041 No. 1 Power Boiler 60,000 No. 6 SO = 8990 

450,000 pph Coal PM = 253 No. 2 Power Boiler 100,000 pph Fuel PM = 1339 

NO = 1776 No. 3 Power Boiler 300,000 pph Oil 

x No. 4 Power Boiler 125,000 pph 

NO = 950 

x 

, i 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

26 2-Digit SIC 
-11 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

S02 PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

SO„ PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

B. 

2-185 MPPH 

INSTALLATIONS FUNDED 

2-100 MPPH 

C. INSTALLATIONS PROJECTED*

 U-C¥c-d

 3$ftitf)eirs } 

PM 

/v--80TPY/Blr (? 

.1 lb/MM Btu 

Pulv Coal ^1 7 TPY/Blr @ 

Actual Emissioi 

Rate 

NOx 

—580TPY/Blr Q 

.7 lb/MM Btu 

No.6 Oil NOX 

276 TPY Total 

Permitted 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

28 2-Digit SIC 
Number andL 

Cai 

None 

BOILER 

RR "EXPANSION-REPLACEMENT" SURVEY * 

p^ilprts) Re] 

New Boilers 

• S0? PM and NCjx 

2 Emissions 

Number and^ 

Cai 

>laced (If Applicable) 

S02 PM and tjOx 

Emissions 

A. wsssiffiffiHLHHisaffi^EJiL 

PR0CESS_(BtCK^T0a2m 

None 

None 

(2J-125 

. (Wit h a boU« capacity SO 000 lbs./hr. i - i — 

1. ^fu"^^^/^ - iSlvid-V fuels 

2

3- ronsTe^year^'each pollatant 

28 2-Digit SIC 

28 2-Digit SIC 

I t t n ,r.^A r-r-. Droliminar v desiqi l dat a 
14 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

2

 S0 ? P M an d N 9X 

Fuel Emissions 

Number and. 

Capacity Fuel 

S 0 2 PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

A 2 x 100,000 (250 MMB) Bituminous 1806-33-468 

Coal 

2 x 35,000 

1 x 54,000 

1 x 100,000 

Bitminous 2524-311-705 

Bituminous 

3.4% S #6 Oil 

B. INSTALLATIONS FUNDED 

B 2 x 150,000 (SCB) 

B .2 x 250,000 (SCB) 

C. INSTALLATIONS PROJECTED (To 1988) 

Anthracite 

Culm 

Coal 

514-51-514 

420-74-750 

* 

1. 

2. 

3. 

0.3% S #6 Oil 

Natural Gas 

2-100,000 

2-60,000 

1-70,000 

1-90,000 

1-104,000 

1-110,000 

(With a boiler capacity > 80,000 lbs./hr. i.e. input 

In thousands of pounds/hr. steam 

Include mixtures, denoting individual fuels 

Tons per year of each pollutant 

Sub Bituminous 1428-127-NA 

Coal 

459-142-538 

100 MMB) 

28 2-Digit SIC 

A -Replacement in kind - no additional process steam requirement. 

B - Replacement in kind, but with net additional steam produced for cogeneration condensing 

..•_.__ M „ „,-•.,-•.• •. ,• .-.n-^x process "st-pam rpnui rpmenfc . 
15 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boilcr(s) Replaced (IC Applicable) 

Number and. 

Capacity 

2 SO PM and NOx 

Fuel Emissions 

Number and1 

Capacity Fuel 

SO PM and NOx 

Emissions 

1-120,000 Stoker 

1-150,000 Stoker 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

Coal 

Coal 

PM 19 

21 

B. 

ton 

yr. 

ton 

yr. 

NO 

X 

378 ton 

yr. 

» 

412 ton 

yr. 

INSTALLATIONS FUNDED 

1-120,000 Stoker 

1-100,000 Stoker 

C. INSTALLATIONS PROJECTED (To 1988) 

Coal PM 19 ton NO 

yr. 

378 ton 

yr. 

Coal 

* 

1. 

2. 

3. 

(With a boiler capacity > 80,000 lbs./hr. i.e. input 

In thousands of pounds/hr. steam 

Include mixtures, denoting individual fuels 

Tons per year of each pollutant 

100 MMB) 

28 2-Digit SIC 
16'. 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and, 2 S02 PM and NOx Number and, S02 PM and NOx 

Capacity Fuel Emissions Capacity Fuel Emissions

 3 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1-150 Coal 440 1 464 1 |6 Oil 440 60 498 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

21 2-Digit SIC 'Conversion 
17 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity

 J Fuel 

S02 PM and NOx 

Emissions 

Number and. 

Capacity Fuel 

S0? PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

One (1) 200,000 #/HR Oil & Gas Fired Package Boiler 

to replace four (4) old G & O Fired Package Boilers 

aggregating 360,000 l/HR. 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

28 2-Digit SIC 
1*8 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity ' Fuel' 

SO_ PM and NOx 

Emissions 

Number and. 

Capacity ' Fuel 

S0? PM and NOx 

Emissions 

2- 220,000 PPH 

each 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

Pulverized 

Coal 

Gas Ignitors 

6490 T/Yr. S02 

.7 lbs./MMBTU NO 

*5 - 75,000 PPH Stoker 

each Coal 

6490 T/Yr. S02 

NO NA 

x 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

26 2-Digit SIC 

* Max permitted 
19 

BOILER "EXPANSION-REPLACEMENT" SURVEY * * * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

S02 PM and NOx 

Fuel Emissions 

Number and. 

Capacity ' Fuel 

S02 PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1 - 110,000 #/hr Coal 3 - 60,000 #/hr Oil.Gas 

B. INSTALLATIONS FUNDED 

C INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

28 2-Digit SIC 

** Telephone Report 
P.30 

2 0 . 

BSIIU sissv 

sue m:u. 

r, ib.v 

KOI/ 

Subtotal Kcu 

Sublctsl lft[*la:c.-.er.t 

Subtotal Ccgentralion 

IOTRL' 

Fulurj Projects 

S-blcUl KJW 

Si-Metal Fe:h:v.er.t 

S-.Mclal Cc;twalie s 

IDlPi 

MO Jepiacewnt 

39 Ha« 

28 Pc?!a:er:inl 

S J *;?! ardent 

83 Gfj-Iawsnl 

30 J:r!a.-i-.ent 

110 8e;!/Ccjep(7iV70) 

2W Etplacwtnl 

80 Seplarcrent 

60 Re-jlacsienl 

70 Peplecr.snt 

30 

iii 

70 

IJT 

SIHIU? 

HIE 

nn ria 

KPLKEO 

3-91 'Jasle wood Kitural oas 

11-51 S-vA-st ' Rone 

2-82 Ind uasie Ecal 

2-?2 L'sstc hiUna l gas) Katural gas 

12-82 Ueste ujod Natural gas 

6-EJ Office Irash Katural cas 

7-63 Uaste uood Katural gas 

7-83 Uasie uood fel gas/Ho. t f.0. 

11-S3 Uasie hu!(na t gas) Hatural gas 

1-21 Uosle ucod Ra. ( LO. 

6-85 Uasie healOwl oas) Kalura! gas 

3.21X 

83.32X 

7.151 (tr/.-.ti uiiliiy capacity) 

ico.es: 

ICO CtploC*n;nt 

60 Etpla:t-.snt 

-100 fep!a::.ienl 

150 Eeptasient 

170 *?e?l/C:?R(2B/l5fl) 

170 r.;!/tc;:.«.(50/12O) 

'Jasle uwd Katural gas 

L'aste heaKnat gas) ? 

Coal Coal 

Uasie uood ? 

l'aste heaKnal gas) Kstural gas 

Uaste heaKnat gas) Kattral gas 

0 

ISO 

270 

O.OSX 

tt. so: 

37.SCZ <>";pla:es utility capacity) 

720 100.021 

ICIfiLS - FiCrsHsiut VUV.) t-i F/L'ECIEO 

Subtotal tr. I. 1.811 

S-.t'.clal f.;'..:.rv.[ l.'ES 77.££I 

5-XicUl Cc;tr t.-aliort HO 20.il! '.-iiU'.ti utilily cc;-a:ity) 

.;;.>'. ITTRL uss 

SIC 26 

1K.C3I 
21 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

2 SO, PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

S02 PM and NOx 

Emissions 

(2) 120,000 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

Coal SO - 1141 

PM - 61 

NO - 582 

x 

*(3) 150,000 No. 6 Fuel 

B. 

(one unit wax complete) 

INSTALLATTO^^JNDED 

None 

C. INSTALLATIONS PROJECTED (To 1988) 

S02 - 2110 

PM - 148 

NO - 596 

x 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

29 2-Digit SIC 
IX 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable 

Number and. 

Capacity 

' SO- PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

• SO. PM and N Ox 

.12 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

*1-306X10~" BTU/hr Coal PM=11.6 Ton/Year Actual (40 Ton/year allowable) 

g (N.G. Ignit.)NOx = 280 Ton/year actual (280 ton/year allowable) 

4-248X10 BTU/hrleach] Coal PM=100 Ton/year Projected Actual(Allowable = 155 Ton/year) 

(Propane Ig) NOx=1540 Ton/year Projected Actual (Allowable 2311 Ton/year) 

B. INSTALLATIONS FUNDED 

None 

C. INSTALLATIONS PROJECTED (To 1988) 

2-150X10 BTU/hrleach] Coal PM = 20 Ton/year Project Actual (Allowable = 40 Ton/year) 

(N.G. Ighit.)NOx=273 Ton/year Projected vctual (Allowable = 546 Ton/year) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

21 2-Digit SIC 

*This is a new boiler addition and not a replacement; however, it was installed primarily to replac* 

existing boiler capacity while four older boilers are taken out of service sequentially for 
2J 

BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity ' 

2 S02 PM and NOx 

Fuel Emissions 

Number and. 

Capacity Fuel 

S02 PM and NOx 

Emissions 

275,000 l/HR 

420,000 l/HR 

ON LINE 1982 (NOTE: 70% REPLACEMENT CAPACITY) 

Coal PM-70 T/Yr 

Wood SO2-1100 T/Yr. 

Sludge NOx-1100 T/Yr. 

90,000 «/HR 

66,000 i/HR 

SO_ -80 

Coal/Gas PM -20 T/Yr, 

Cool/Sludge NOx 260 

Bark 

Coal PM -: ? 

Wood SO-- 2870 

NOx- 1670 

NOTE: Added load; old boiler burned gas. 

500,000 l/HR 

ON LINE 1985 

Coal 

Wood 

Sludge 

PM -? 

SO--935 T/Yr. 

NOX-2125 T/HR 

250,000 #/HR 

170,000 #/Hr 

170,000 #/HR 

Oil SO--4952 T/Yr. 

NOx-935 T/Yr. 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

26 2-Digit SIC 

i i 
24. -

'BOILER "EXPANSION-REPLACEMENT" SURVEY * 

i 

New Boilers Boiler(s) Replaced (If Applicable) 

t . , -.

 (b ) 

Number and.ta' 2 SO- PM and NOx lc) Number and, SO- PM and NOx (c 

Capacity Fuel Emissions Capacity Fuel ' Emissions

 3 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

2/232 Klb/hr ea Coal 127 890 1/199 Klb/Hr Coal n o 765 

1/144 Klb/hr 16 Oil 24 110 1/185 Klb/Hr Coal 50 710 

i/100 Klb/Hr Coal 35 

20 

B. INSTALLATIONS FUNDED 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 100 MMB) 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

2-Digit SIC 

350 

C. INSTALLATIONS PROJECTED (To 1988) 

2/90 Klb/Hr ea. Coal 20 34 5 

a) These are not the manufacturer guarantees, but the permitted maximum assuming 1250 BTU/lb steam 

b) Replacements are coal in place of natural gas or residual oil 

_*. *o_.* -r-i ,,„^ ar-o t-hp maximum legal allowables, not actuals, for each unit. 
25. 

"BOILER "EXPANSION-REPLACEMENT" SURVEY * 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity ' 

2 SO- PM and NOx 

Fuel Emissions 

Number and. 

Capacity ' 

, S02 PM and NOx 

Fuel ' Emissions 

(1) 600,000 lb/HR 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

Coal SO2-3,750 T.P.Y. (6) 600,000 lb/HR Coal 

PM - 60 T.P.Y. 

NOx- 2,050 T.P.Y. 

B. INSTALLATIONS FUNDED 

None 

C. INSTALLATIONS PROJECTED (To 1988) 

None 

S02 - . 5250 T.I 

PM - 262 T.P.Y. 

NOx - No Data 

Available 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

28 2-Digit SIC 

Note: The six boilers were not dismantled, but rather placed in standby status until load 

increases dictate they be placed in service. 
•;i 

CIBO NSPS BOILER "EXPANSION-REPI^CEMENT" SURVEY* 

j$>-

Name 

New Boilers 

Capacity 

Replaced Boilers 

Bmissions" 

Fuel4 PM NO. 

> 

». 

•2 . 

• i . 

400-

500' 

500 ' 

500 ' 

400' 

wood 

COil 

oil 

ccnbina 

tion 

future 

peat 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

1 tryr\& 2 5 1 

30? 

391 

700* 

1288V 

770t 

890J 

40TM 2240k 

Replaced oil firing in several boilers of 

approx. 400,000 pph avg. rate. 

Shutdown 1 or 2 old boilers. 

Reduced load on others in standby status. 

• ). 

.r' 

"500" 

500 ' 

ipo 

600 

500** 

co-il 

oil (standby) 

VODd 

codf* 

oil ~ 

cc.it ination 

127^ 273$ 

13(T 2155J 

10S~ 1050* 

127a 27ia 

Notes: 

*CF°r boiler capacity >80,000 lbs/hr, i.e. heat input >100 

million Btu/hr) 

For multi-fuel boilers steam rate in thousands of lbs/hr 

for each fuel. 

2Includc mixtures, denoting individual fuels. 

3Toni per year of each pollutant. 

^Ccnments in lieu of data. 

aActual based on 8760 hours. 

^Assumed same as combination. 

cExpected based on electroscrubber performance measured 

Fuel conversion on existing boiler to replace 

500,000 pph on oil. 

New plant. 

dAssume 820 x IO6 Btu/hr heat input and 0.6» MV10 6 Btu 

and 8760 hr/yr operation. . 

eAssumes 800 x 10° Btu/hr input and 0.031/10° Btu for 

r8760 hrs. 

fAssume 0.3I/106 Btu. 

-^Measured at 0.25»/106 Btu. 

^Measured at 0.44#/10J? Btu. 

iMeasured at 0.27K/106 Btu. 

^Measured avg. of 0.264/106 Btu. 

Estimated at 0,801/10° Btu. 

'Actual test data. 

.•"Estimate. 
Name 

New Boilers 

Capacity Fuel 

Replaced Boilers <!6 

Emissions 

PM NO. 

B.••INSTALLATIONS FUNDED 

None. 

600 

500 

300 

CJ' INSTALLATIONS PROJECTED'(TO 1988) 

ecal or 480a 3360b 

cc-al/wood 

(vith gas/oil 

standby) 

365c 615d 

red liquor 240a 1680° 

black 

liquor 

Replaces *1 Power Boiler rated 700,000 pph 

on gas/oil. 

New plant ^ 

Replaces oil in one or more existing boilers 

and burns liquor now wasted. r 

aAssume 0.1I/106

 Btu. 

bAssune 0.7I/106

 Btu. 

cAssume 0.044 gr/sdef . 81 0^ 

dAssume 70 ppm NOx and 800 x IO6

 Btu/hr. 

SIC 2 6 

to 
BOILER "EXPANSION-REPLACEMENT" SURVEY * 27 

New Boilers Boiler(s) Replaced (If Applicable) 

Number and. 

Capacity 

SO. PM and NOx 

Fuel Emissions 

Number andCapacity Fuel 

S0? PM and NOx 

Emissions 

A. INSTALLATIONS FINISHED OR IN PROCESS (BACK TO 1979) 

3-600 Waste S02 3578 

NOx 1960 

7-145 Oil, Gas SO2 - 3000 

NOx - 3200 

B. INSTALLATIONS FUNDED 

C. INSTALLATIONS PROJECTED (To 1988) 

* (With a boiler capacity > 80,000 lbs./hr. i.e. input 

1. In thousands of pounds/hr. steam 

2. Include mixtures, denoting individual fuels 

3. Tons per year of each pollutant 

100 MMB) 

29 2-Digit SIC 
P.39 

APPENDIX C 

CIBO TABULATION OF SURVEY DATA 
P.40 

COUNCIL OF INDUSTRIAL BOILER OWNERS 

BOILER REPLACEMENT SURVEY 

The information tabulated below is derived from a CIBO 

survey conducted in September 1984, to determine the replacement/ 

expansion ratio of new boiler installations. The information 

covers: a) installations finished or in process back to 1979; b) 

installations not yet completed but for which funds have been appropriated; c) future installations projected to 1988. 

The responses show a 4:1 replacement/expansion ratio; 

i.e., approximately 80% of hew boilers are for replacement purposes. The fuels of the replaced and new boilers, and the number 

of boilers involved, are as follows: 

From 

Fuel "Conversions" 40 

43 

7 

6 

5 

11 

5 

Oil 

Coal 

Oil 

Oil 

Wood 

Coal 

Gas 

To 

Coal 

Coal 

Wood 

Gas 

Wood 

Wood 

Coal 

22 

21 

3 

2 

2 

11 

1 

Totals 117 62 

Thus, 117 boilers are being replaced by 62 new units, a decrease 

of 55 boilers. Over 95% of the boilers that are being retired 

fire fuels other than natural gas. 

The data from the 9 companies providing emissions data 

show that the replacement process, by itself, will result in a 

decrease in S02 emissions, independent of any NSPS: 

No. of Boilers 

Aggregate Capacity 

lbs/hr X 1000 

Aggregate Input 

MMBTU/hr 

Total SO_ Emissions, 

tons/yr 

Replaced 

54 

7,080 

8,300 

36,382 

New 

r 

29-

7,630 

8,870 

26,856 

Net Result 

(Decrease) 

(25) 

550 

570 

(9,526) 

July 1985 
Case f Units 

1. 

2. 

3. 2 

1 

4. 

5. 

6. 

7. 0 

8. 

9. 9 

2 

4 

10. 

11. 

12. 

13. 

* - In thousands of 

BOILER EXPANSION-REPLACEMENT SURVEY 

EXPANSION REPLACEMENT 

pounds 

Capacity* Units 

1 

1 

150 

100 

1 

1 

1 

1 

4 

4 

0 

2 

1 

150 15 

300 1 

60 13 

1 

2 

2 

4 

1 

1 

per hour of boiler steaming capacity each. 

Capacity* 

350 

250 

88 

770 

180 

300 

500 

125 

-

75 

150 

240 

300 

200 

450 

185 

125 

80 

100 

675 

y » 

• -> 

r 
Case! Units Capacity* Units 

14. 2 

2 

2 

15. 2 

1 

1 

16. 1 

17. 1 

18. 2 

19. 1 

20. 1 30 16 

21. 2 

22. 4 210 1 

2 

23. 1 420 1 

1 

24. 2 

1 

1 

1 

* In thousands of pounds per hour of boiler steaming capacity each. 

** , This is aggregate capacity of 16 units. 

Capacity* 

100 

150 ! 

250 

120 

150 

100 

150 

200 

220 

110 

1626** 

120 

258 

125 

275 

500 

232 

144 

199 

185 

./ ** 

"»• • 

2 . •* «t> 

% 

f 

*> 
Case I 

24. 

25. 

26. 

27. 

Units Capacity* 

2 

2 

600 

500 

Units 

1 

2 

1 

2 

5 

1 

3 

Capacity* 

100 1 

90 

600 

400 

500 

600 

600 

Totals 28 

Grand Total 

6080 

143 32,594 

115 26,514 

3.. 

* -J.n thousands of pounds per hour of boiler steaming capacity each.