0226.04.020 

## 1 MEMORANDUM

TO: Jim Eddinger, U.S. Environmental Protection Agency, OAQPS (C439-01)

FROM: Graham Gibson, ERG

DATE: April 2010

SUBJECT: New Unit Analysis Industrial, Commercial, and Institutional Boilers and Process

Heaters National Emission Standards for Hazardous Air Pollutants – Major

Source

1.0 INTRODUCTION

This memorandum describes the estimation of new major source boilers and process

heaters projected to be built by 2013 and 2015 from the baseline year of 2008. The results of

this analysis are used to estimate costs and impacts for new sources for a national emission

standard for hazardous air pollutants (NESHAP) for industrial/commercial/institutional boilers

and process heaters. The years 2013 and 2015 were selected because they are five years from

the expected proposal and promulgation dates of the boiler NESHAP.

This memorandum is separated into the following sections:

1.0 Introduction

2.0 Data Sources

3.0 Methodology for Estimating New Units

4.0 Results

5.0 References

Appendix A – Distribution of Model Units between Industrial and Commercial Sectors0226.04.020 

## 2 2.0 DATA SOURCES

The existing units reported in the 2008 Combustion Survey were subcategorized into

model units in order to project future units 1 

## . Units were subcategorized based on fuel, size

category, and whether the facility is in the commercial or industrial sector. Specific fuels were

categorized into one of the following categories: Coal, Bagasse, Wet Biomass, Dry Biomass,

Heavy (Residual) Liquid, Light (Distillate) Liquid, Process Gas (Gas 2), Natural Gas and Other

Non-Process Gases (Gas 1), Other Fuels, and Wast e. The development of these fuel categories

and the individual fuels they characterize are detailed in another memorandum 2 

## . For the purpose

of this analysis the Biomass fuel category incl udes Bagasse, Wet Biomass, and Dry Biomass. It

was assumed that all new boilers and process heaters designed to burn non-process gases would

only burn natural gas and no other fuels associated with the Natural Gas and Other Non-Process

Gases fuel category. To assign each facility to either the commercial or industrial sector, we

used the three digit NAICS code that was reported for the facility in the 2008 Combustion

Survey. Then, an average design capacity and annual hours of operation were calculated based

on all the units within each group in order to obtain general operational estimates for each

model. The energy consumption forecasts were provided by the Energy Information

Administration (EIA) of the U.S. Department of Energy 3 

## . The EIA provides forecasts of the fuel

consumption of coal, renewable energy (including biomass), residual oil, distillate oil, and

natural gas according to sector and source.

3.0 METHODOLOGY FOR ESTIMATING NEW UNITS

The methodology involved in this analysis was consistent with a previous analysis

completed for the 2004 vacated boiler NESHAP and consists of two parts: 1) Calculating the

predicted percent changes in fuel consumption in the industrial and commercial/institutional

sectors, and 2) Calculating the expected fuel c onsumption in future in boilers and heaters and

predicting the number of new units required to fire a particular fuel 4 

## . Since the 2008

Combustion survey represents the inventory of affected boilers and process heaters, the base year

for this analysis is 2008. The steps required to perform this analysis are described below.0226.04.020 

## 3 3.1 Calculating Percent Change in Fuel Consumption

Existing boilers and process heaters were grouped into one of the following fuel types:

coal, biomass, residual liquid, distillate liquid, process gas, and natural gas. Projected fuel

consumption by the industrial and commercial sectors for each of these fuels for 2013 and 2015

could then be used to calculate percent differences in fuel consumption 2 

## . The EIA fuel

consumption projections, along with calculated percent differences for 2013 and 2015, are given

in Table 3-1. These calculations were performed as follows:

 EIA data was gathered for industrial and commercial fuel use in 2008, 2013, and 2015 in

the following fuel categories: coal (all, including Coke), residual liquids, distillate

liquids, natural gas and renewable energy. The renewable energy definition at the EIA

includes consumption of energy produced from hydroelectric, wood and wood waste, and

other biomass sources, excluding ethanol ble nds. Renewable energy was used to project

the future rate of increase in biomass fuels since biomass is assumed to follow the same

growth rates of other renewable resources. Biomass energy consumption was not

available as a distinct fuel consumption category within the EIA fuel consumption

projections by sector data.

 Equation 1 was applied to the EIA data to calculate the percent change from 2008 to the

target years.

o PC TY 

## = 100 * (EIA TY 

## – EIA 2008 

## ) / EIA 2008 

## Equation 1

o Where:

o PC TY 

## = Percent change in consumption of fuel for target year (2013 or 2015)

o EIA TY 

## = Consumption of fuel from EIA data for the target year (2013 or 2015)

o EIA 2008 

## = Consumption of fuel from EIA data for 2008

EIA fuel consumption data was not available for process gases, so it was assumed that

the natural gas fuel consumption projections applied to all gaseous fuels. Fuels with negative

percent changes were assumed to have no new units projected to come on-line by the end of

target years 2013 or 2015.0226.04.020 

## 4 Table 3-1. Expected Fuel Consumption Differences by Sector 3



### Industrial Sector Fuel Consum ption (Quadrillion Btu per year) Percent Difference from 2008

Fuel 2008 2013 2015 2013 2015

Natural Gas 6.83 6.76 6.62 -1.2% -3.1%

Coal 1.84 1.71 1.80 -7.2% -2.2%

Residual oil 0.22 0.16 0.16 -23.4% -25.9%

Distillate oil 1.20 1.22 1.19 1.7% -0.8%

Biomass* 1.66 1.57 1.56 -5.9% -6.0%

Commercial Sector Fuel Consumption (Quadrillion Btu per year) Percent Difference from 2008

Fuel 2008 2013 2015 2013 2015

Natural Gas 3.22 3.25 3.29 0.8% 2.1%

Coal 0.07 0.06 0.06 -2.0% -2.0%

Residual oil 0.07 0.08 0.08 19.1% 24.0%

Distillate oil 0.38 0.36 0.35 -5.1% -8.9%

Biomass* 0.12 0.12 0.12 0.0% 0.0%

*Based on renewable energy fuel consumption.



## 3.2 Fuel Consumption and New Boiler Forecasting

To predict the number of new boilers and process heaters in operation by 2013 and 2015,

the percent difference for each fuel calculated in Table 3-1 was applied to the fuel consumption

represented by the generated models in the industrial and commercial sectors. This was done

using the following steps:0226.04.020 

## 5  First, all existing boilers were determined to be at a commercial or industrial facility.

This classification was based on the reporte d North American Industry Classification

System (NAICS) code for the facility. Existing major source boilers and process heaters

were subcategorized into model groups by sector, fuel, and size classification. Size

classifications were based on the reported design capacity of the combustion unit.

Categories were generated for the following sizes, based on the various size thresholds

that would be expected to affect compliance requirements. For example, units greater

than 100 million Btu per hour (MMBtu/hr) are required to install continuous emissions

monitors for CO, and units greater than 250 MMBtu/hr are required to install continuous

emission monitors for PM. The following size thresholds were used to develop model

units:

o Less than 10 MMBtu/hr

o Greater than or equal to 10 to 100 MMBtu/hr

o Greater than 100 to 250 MMBtu/hr

o Greater than 250 MMBtu/hr

 Next, the annual fuel consumption from 2008 (MMBtu/yr) was calculated for each model

group using Equation 2.

FC 2008 

## = DC

avg 

## * Op hours,avg 

## * N i 

## Equation 2

Where:

FC 2008 

## = Fuel consumption in 2008, MMBtu/yr

DC

avg 

## = Average design capacity for all units in model subcategory, MMBtu/hr

Op hours,avg 

## = Average annual hours of operation for all units in model subcategory

N i 

## = Number of existing units in model subcategory

The fuel consumption values calculated for the model units in this step were then used as

the 2008 basis for new unit predictions.

 Forecasts of annual fuel consumption for each subcategory were calculated for the target

years (2013 or 2015) by applying the percent differences calculated in Table 3-1 to the

2008 fuel consumption calculated above using Equation 3.

FC TY 

## = FC 2008 

## * [1 + (PC TY 

## / 100)] Equation 3

Where:

FC TY 

## = Projected fuel consumption in target year (2013 or 2015), MMBtu/yr

FC 2008 

## = Fuel consumption in 2008, MMBtu/yr

PC TY 

## = Percent change in consumption of fuel for target year (2013 or 2015)0226.04.020 

## 6  The number of units in the target year (2013 or 2015) was calculated using Equation 4.

N TY 

## = [ (FC TY 

## - FC 2008 

## ) / DC

avg 

## ] / Op hours,avg 

## Equation 4

Where:

N TY 

## = Projected number of units in the target year (2013 or 2015)

FC TY 

## = Projected fuel consumption in target year (2013 or 2015), MMBtu/yr

FC 2008 

## = Fuel consumption in 2008, MMBtu/yr

DC

avg 

## = Average design capacity for all units in model subcategory, MMBtu/hr

Op hours,avg 

## = Average annual hours of operation for all units in model subcategory, hr/yr

Values were rounded up to the nearest integer because it was assumed that fractions of

units would equate to a new unit operating at a fraction of the design capacity. If the resultant

value was negative, it was assumed no new units for that subcategory would be in operation in

the target year.

4.0 RESULTS

The results of the new boiler analysis by model and year for the industrial and

commercial sectors are presented in Appendices A-1 and A-2, respectively. The combined total

number of new boilers for 2013 is expected to be 46. Likewise, the total number of new

industrial, commercial, and institutional boilers for 2015 is 86. The majority of all new boilers

and process heaters are expected to be gas-fired, wh ich is true for both target years. No new coal

or biomass fired boilers are projected to come online by 2015.0226.04.020 

## 7 5.0 REFERENCES

1. Survey Database containing Results of the 2008 Questionnaire for Boilers, Process

Heaters, & Other Combustion Units (ICR No. 2286.01).

2. Amanda Singleton and Graham Gibson, ERG. Memorandum to Jim Eddinger, U.S.

Environmental Protection Agency, OAQPS. Development of Baseline Emission Factors

for Boilers and Process Heaters at Commercial, Industrial, and Institutional Facilities

. April, 2010.

3. U.S. Department of Energy. Energy Information Administration. Annual Energy

Outlook 2009. Table 2. Energy Consumption by Sector and Source. Available on-line

at: http://www.eia.doe.gov/oiaf/aeo/aeoref_tab.html

4. Jason Huckaby, ERG. Memorandum to Jim Eddinger, U.S. Environmental Protection

Agency, OAQPS. New Unit Analysis for Industrial, Commercial, and Institutional

Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants.

October, 2002.Appendix A-1: Calculation of Projected Number of New Industrial Boilers and Process Heaters in 2013 and 2015Annual EnergyConsumption(MMBtu/yr)Number ofExisting UnitsProjectedAnnual EnergyConsumption(MMBtu/yr)EstimatedNumber of NewUnitsProjectedAnnual EnergyConsumption(MMBtu/yr)EstimatedNumber of NewUnitsIndBagasseBlr1Industrial Biomass 3,903 229.0 >100 to 2508.94E+0518.41E+05 - 8.40E+05 -IndBagasseBlr2Industrial Biomass 4,668 478.9 >2503.35E+07153.16E+07 - 3.15E+07 -IndCoalBlr2Industrial Coal 5,946 68.4 10 to 1003.82E+07943.55E+07 - 3.74E+07 -IndCoalBlr3Industrial Coal 6,753 187.6 >100 to 2502.71E+082142.52E+08 - 2.65E+08 -IndCoalBlr4Industrial Coal 7,721 545.3 >2507.37E+081756.83E+08 - 7.20E+08 -IndDryBmassBlr1Industrial Biomass 7,319 3.8 <103.63E+05133.42E+05 - 3.42E+05 -IndDryBmassBlr2Industrial Biomass 7,187 47.3 10 to 1004.82E+071424.54E+07 - 4.54E+07 -IndDryBmassBlr3Industrial Biomass 7,646 166.5 >100 to 2506.11E+07485.75E+07 - 5.74E+07 -IndDryBmassBlr4Industrial Biomass 8,421 491.5 >2501.24E+08301.17E+08 - 1.17E+08 -IndGas1Blr1Industrial Natural Gas 8,196 5.1 <101.67E+084,0111.65E+08 - 1.62E+08 -IndGas1Blr2Industrial Natural Gas 6,955 43.7 10 to 1008.35E+082,7488.25E+08 - 8.09E+08 -IndGas1Blr3Industrial Natural Gas 6,855 167.8 >100 to 2509.31E+088099.20E+08 - 9.02E+08 -IndGas1Blr4Industrial Natural Gas 7,695 423.6 >2501.21E+093701.19E+09 - 1.17E+09 -IndGas2Blr1Industrial Process Gas 4,469 8.1 <103.64E+0413.60E+04 - 3.52E+04 -IndGas2Blr2Industrial Process Gas 6,650 45.5 10 to 1002.03E+07672.00E+07 - 1.96E+07 -IndGas2Blr3Industrial Process Gas 7,202 177.7 >100 to 2506.14E+07486.07E+07 - 5.95E+07 -IndGas2Blr4Industrial Process Gas 8,094 434.4 >2502.50E+08712.47E+08 - 2.42E+08 -IndHvyLiqBlr1Industrial Residual Liquid 5,133 5.3 <108.21E+0436.29E+04 - 6.08E+04 -IndHvyLiqBlr2Industrial Residual Liquid 6,325 49.3 10 to 1004.21E+071353.23E+07 - 3.12E+07 -IndHvyLiqBlr3Industrial Residual Liquid 5,296 174.1 >100 to 2507.01E+07765.37E+07 - 5.20E+07 -IndHvyLiqBlr4Industrial Residual Liquid 5,367 629.4 >2501.45E+08431.11E+08 - 1.08E+08 -IndLtLiqBlr1Industrial Distillate Liquid 4,554 4.3 <108.83E+05458.98E+05 1 8.76E+05 -IndLtLiqBlr2Industrial Distillate Liquid 4,864 45.4 10 to 1002.83E+071282.88E+07 3 2.81E+07 -IndLtLiqBlr3Industrial Distillate Liquid 3,578 177.7 >100 to 2503.88E+07613.94E+07 2 3.85E+07 -IndLtLiqBlr4Industrial Distillate Liquid 5,246 430.5 >2506.77E+07306.89E+07 1 6.72E+07 -IndWetBmassBlr1Industrial Biomass 6,486 4.4 <101.14E+0541.07E+05 - 1.07E+05 -IndWetBmassBlr2Industrial Biomass 8,205 53.3 10 to 1003.24E+07743.05E+07 - 3.04E+07 -IndWetBmassBlr3Industrial Biomass 7,829 186.6 >100 to 2504.68E+07324.40E+07 - 4.39E+07 -IndWetBmassBlr4Industrial Biomass 8,218 585.9 >2502.99E+08622.81E+08 - 2.81E+08 -Total 5.56E+099,5505.34E+0975.32E+0902008 2013 2015Model Indentifier SectorStandard FuelCategoryAverageAnnualOperationHoursAverage DesignCapacity(mmBtu/hr)Design CapacitySize Category(mmBtu/hr)Page 1 of 2Appendix A-2: Calculation of Projected Number of New Commercial Boilers and Process Heaters in 2013 and 2015Annual EnergyConsumption(MMBtu/yr)Number ofExisting UnitsProjectedAnnual EnergyConsumption(MMBtu/yr)EstimatedNumber of NewUnitsProjectedAnnual EnergyConsumption(MMBtu/yr)EstimatedNumber of NewUnitsComCoalBlr1Commercial Coal 5,162 79.0 10 to 1001.26E+07311.24E+07 - 1.24E+07 -ComCoalBlr2Commercial Coal 5,994 163.7 >100 to 2504.51E+07464.42E+07 - 4.42E+07 -ComCoalBlr3Commercial Coal 7,832 439.0 >2506.19E+07186.07E+07 - 6.07E+07 -ComGas1Blr1Commercial Natural Gas 7,910 4.9 <101.21E+083,1311.22E+08 27 1.23E+08 67ComGas1Blr2Commercial Natural Gas 5,064 34.7 10 to 1006.51E+073716.57E+07 4 6.65E+07 8ComGas1Blr3Commercial Natural Gas 4,291 158.0 >100 to 2505.49E+07815.54E+07 1 5.61E+07 2ComGas1Blr4Commercial Natural Gas 1,732 318.2 >2504.96E+0695.00E+06 1 5.07E+06 1ComGas2Blr1Commercial Process Gas 7,591 37.8 10 to 1002.58E+0692.60E+06 1 2.64E+06 1ComGas2Blr2Commercial Process Gas 5,334 146.3 >100 to 2502.34E+0632.36E+06 1 2.39E+06 1ComHvyLiqBlr1Commercial Residual Liquid 500 6.0 <103.00E+0313.57E+03 1 3.72E+03 1ComHvyLiqBlr2Commercial Residual Liquid 4,736 51.3 10 to 1002.43E+06102.89E+06 2 3.01E+06 3ComHvyLiqBlr3Commercial Residual Liquid 2,980 196.0 >100 to 2502.92E+0653.48E+06 1 3.62E+06 2ComLtLiqBlr1Commercial Distillate Liquid 5,145 2.3 <102.37E+061962.25E+06 - 2.16E+06 -ComLtLiqBlr2Commercial Distillate Liquid 5,132 37.1 10 to 1001.46E+07771.39E+07 - 1.33E+07 -ComLtLiqBlr3Commercial Distillate Liquid 5,150 184.2 >100 to 2501.23E+07131.17E+07 - 1.12E+07 -ComLtLiqBlr4Commercial Distillate Liquid 4,652 776.4 >2501.08E+0731.03E+07 - 9.87E+06 -ComBmassBlr1Commercial Biomass 8,760 60.0 10 to 1005.26E+0515.26E+05 - 5.26E+05 -Total 4.16E+084,0054.15E+08394.17E+08862008 2013 2015Model Indentifier SectorStandard FuelCategoryAverageAnnualOperationHoursAverage DesignCapacity(mmBtu/hr)Design CapacitySize Category(mmBtu/hr)Page 2 of 2