p.1 

OAR Box 1828 

Prepped by Ollie Stewart 

Document Number: 

136) ll-K-(B)-135 

Docket Number: 

A-83-27 

Printed 11/12/2008 11:12:53 AM Sheet 136 of 325 
P.2 

ENERGY AND ENVIRONMENTAL ANALYSIS, INC. 

April 4, 1984 

Mr. Robert Short 

Economic Analysis Branch 

U.S. Environmental Protection Agency 

Mail Drop-12 

Research Triangle Park, NC 27711 

Subject: Revised Beet Sugar Industry Update for 

Industrial Boiler NSPS EPA #68-02-3536, 

Work Assignment #34 

Dear Mr. Short: 

Enclosed is an update of phone conversations which Joan McGovern 

made to beet sugar companies in 1982. Calls were made to determine if 

any in the industry had reevaluated their 1982 position on new boiler 

investments. This most recent survey was added to the sheets which Joan 

prepared or additional sheets were supplemented if needed. Company 

names are deleted so that these summaries are treated as confidential. 

The followup conversations indicated that two companies who were 

not planning to replace boilers in 1982 had now decided to go ahead with 

coal conversions. They cited the long-range benefit of burning the 

cheaper fuel i.e., coal rather than gas/oil. Other companies who have-* 

considered coal conversions have still not made any plans to convert, 

citing high capital investment costs as their major constraint. One 

company recently acquired by a new owner is planning to expand facilities 

in 1987 and will add one or two coal high pressure boilers to its existing 

facilities. Of all the companies planning investments in new boilers, 

the preference is to burn coal. 

If you have any questions, please call. 

Sincerely, 

Patrick Ryan 

PR/ce 

Enclosure 

cc: Al Wehe 

Economic s / Engineerin g 
P.3 

Company #1 

EEA Contact: Joan McGovern 

Date of Conversation: May 17, 1982 

Summary of points discussed: 

• The company has six plants: five are coal-fired, one (at Hillsboro, ND) is oil-fired. 

• Refining season has averaged 180 days over a five-year period. 

• In 1979, the company had plans to replace its 3- 100,000 pph, 

oil-fired boilers at the Hillsboro plant, with 2- 175,000 pph 

coal-fired units. It has since "shelved" those plans because 

interest rates are high and sugar prices low. ESP's would 

have been installed for PM control. 

• ESP's are used for PM control at all five coal-fired plants. 

Had previously installed multitube cyclones but they were not 

effective. These plants fall below the three lb SO- SIP. 

• Instead of replacing with new boilers, the company has recently 

made efficiency improvements. It has installed a computerized 

boiler control system to reduce fuel oil intake. 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 13, 1984 

Summary of points discussed: 

• Company is looking to replace 3- 100,000 pph, oil-fired boilers 

with 2- 150,000 pph coal-fired boilers pending authorization from 

Board of Directors in June, 1984. Their concern is the long 

range economics of fuel use. Coal is seen as the best investment 

despite moderation of oil prices. The instability of oil prices 

in the past is a major reason for the switch. 

• Control methods have not been considered and are not a factor in 

the company's decision to replace the boilers. The benefit of 

coal over shadows any control consideration. 
P.4 

Company #2 

EEA Contact: Joan McGovern 

Date of Conversation: May 13, 1982 

Summary of points discussed: 

• The company has five plants; however, it is in the process of closing 

one of its plants. The area surrounding the plant gradually turned 

residential and it had to contract with growers outside the area in 

the process incurring transportation costs. The company decided to 

cease beet sugar operations and instead will probably use the plant 

for some other operation. 

• Refining season lasts nine months. Boilers are run at full load 

during refining season. 

• All plants are natural gas/oil-fired: 

Plant A 2 natural gas/oil boilers each rated 

at 110,000 pph. Built in 1968. 

Plant B 2 natural gas/oil boilers each rated 

at 110,000 pph. Built in 1965. 

Plant C 3 natural gas/oil boilers each rated 

at 75,000 pph. Built in 1950. 

Plant D 1 natural gas/oil boiler at 220,000 

pph. Built in 1963. 

• The company plans no boiler investments for the near future. Initial 

capital costs are too high. The company plans instead to make efficiency improvements. 
, *• ' » "* * 

t 

Company #2 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 13, 1984 

Summary of points discussed: 

• The company is not planning to replace or install any boilers 

because of the capital investment involved which they feel outweighs any savings in fuel prices by burning coal. Their efforts 

are more concerned with the process aspect of sugar making than 

with building steam. 

P.5 
P.6 

Company #3. 

EEA Contact: Joan McGovern 

Date of Conversation: May 25, 1984 

Summary of points discussed: 

• Company has 13 plants, three of which are temporarily not 

operating. 

• Refining season averages 120 days. During the season, boilers 

are run at 80 percent load. 

• Plants represent a range of boiler sizes: 

Operating Plants 

#1 3 natural gas boilers, each rated ^100,000 pph 

#2 1 natural gas boiler at 150,000 pph 

#3 3 natural gas boilers, ranging from 60,000-

100,000 pph 

#4 1 natural gas at 100,000 pph; 3 coal at 100,000 

pph 

#5 2 coal, each at 150,000 pph 

#6 2 coal, each at 150,000 pph 

#7 2 coal, each at 150,000 pph 

#8 6 coal, each at 20,000 pph (old boilers, c. 1915) 

#9 6 coal, each at 20,000 pph (old boilers, c. 1915) 

#10 2 coal, one at -\*150,000 pph and at ^50,000 pph 

Non-operating Plants 

#11 7 natural gas, each at ^20,000 pph 

#12 7 coal, each at ^20,000 pph 

#13 2 coal, each at 'vlOO.OOO pph; 1 natural gas 

at 100,000 pph 

• Presently have Venturi scrubbers on coal-fired plants requiring 

control. 

• The company is not planning boiler replacements but if it did replace boilers, they would tend to be coal-fired between 100,000 

and 200,000 pph controlled with baghouses, not the Venturi scrubbers that they currently have in use. 
P.7 

Company #3 

1984 Update: 

EEA Contact; Patrick Ryan 

Date of Conversation: March 14, 1984 

Summary of points discussed: 

• Company has no plans to replace any boilers although they 

have explored the option of coal conversion several times. 

Even though they feel coal would be cheaper in the long-run 

they are not willing to make the initial investment. The 

instability of the industry was cited as the major factor 

holding back any conversion from gas to coal. The company 

is keeping aware of the implications of coal conversion, 

and if conditions are favorable they will consider it. 
P.8 

Company #4 

EEA Contact: Joan McGovern 

Date of Conversation: May 12, 1982 

Summary of points discussed: 

• Company has seven plants. 

• Refining season averages 120 days during season boiler load, is 

approximately 77 percent. 

• At a "typical plant" there are three natural gas/oil-fired boilers, 

each rated 150,000 pph. (Presently firing #6 oil.) One of these 

boilers is a standby unit. 

• Would rather make boiler efficiency improvements than purchase new 

boilers at the present time. 

• Employs approximately 400 during refining season and 50-100 in the 

off-season. 
P.9 

Company #4 

EEA Contact: Joan McGovern 

Date of Conversation: May 25, 1982 (Clarifications to earlier, May 12, 

1982 conversation) 

Summary of points discussed: 

• All seven plants are oil/gas-fired. 

• The company is considering replacing with coal-fired boilers. 

Would tend to purchase one coal-fired boiler of 175,000 -

200,000 pph and not have any standby boilers. The company is 

not sure of the control device to install, but it is tending 

towards baghouses. 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 19, 1984 

Summary of points discussed: 

• Company is presently undergoing a major conversion from gas 

back to coal. One plant will have replced four boilers and 

another plant two boilers by fall, 1984. The first plant 

will install baghouses while the other plant will use wet 

scrubbers for control. Conversions of their other plants 

are planned and will begin sometime following completion of the 

two plants mentioned. 
P.10 

Company #5 

EEA Contact: Joan McGovern 

Date of Conversation: May 13, 1982 

Summary of points discussed: 

• The company operates four plants. 

• Refining season averages four and one-half months. During 

that time, boilers run at full load. 

• Company employs 1,000 during the season and 350 full-time. 

• Three of the plants are coal-fired, the fourth is oil/gasfired: 

#1 (slices 1,800 tons beets/day). Two coal-fired boilers rated at 

^60,000 pph. Btu content of coal used at all plants is 13,000 Btu/ 

lb. Plant also has one 90,000 pph oil/gas package boiler which is 

not in use. 

#2 (slices 3,500 tons beets/day). Two coal-fired boilers at -^60,000 

pph. One standby oil/gas package boiler at 90,000 pph, fired at 

60,000 pph load. 

#3 (slices 2,800 tons beets/day). Two coal-fired boilers at 60,000 

+ pph. One standby oil/gas package boiler at 90,000 pph and fired 

at a 30,000 pph load. 

#4 one oil/gas-fired boiler at 120,000 pph. 

• Particulates are controlled with mechanical dust collectors. The 

boilers are fired with low sulfur coal. 

• Sugur yield is 240-250 lbs sugar per ton of beets sliced. 

• The company has no plans to replace boilers. In fact, it may close 

the oil/gas-fired plant instead of replacing it with coal-fired 

boilers. 
p.11 

Company #5 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 13, 1984 

Summary of points discussed: 

• Operations are the same as they were in 1982. They now have no 

plans to close the oil/gas-fired plant and no plans to replace 

or install only boilers. 
P.12 

Company #6 

EEA Contact: Joan McGovern 

Date of Conversation: May 17, 1982 

Summary of points discussed: 

• The cooperative operates one plant. 

• Refining season averages 180-200 days. 

• Employs 250 during refining season and 150 during the 

off-season. 

• In 1977, the company replaced 3- 100,000 pph oil-fired boilers 

with 2- 175,000 pph lignite-fired units. The control type used 

is a wet scrubber. Two boilers are operated at a combined load 

of 280,000 pph during refining season. 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 13, 1984 

Summary of points discussed: 

• The plant is still operated as it was in 1982 and no plans have 

been made to replace or install new boilers. The company is 

satisfied with the boilers it installed in 1977 and the wet 

scrubbers used for control. 
P.13 

Company #7 

EEA Contact: Joan McGovern 

Date of Conversation: May 12, 1982 

Summary of points discussed: 

• Company has one plant. 

• Refining season averages four months (October 1 - January 31). 

Boiler load during the season is between 81 percent and 87 

percent. 

• Plant has four coal-fired boilers, each with rated capacity of 

80,000 pph. Low sulfur coal is burned. The plant controls 

particulates with a "fly ash collector". Three of the boilers 

were built in the 1940's, the fourth boiler in 1962. 

• No boiler replacements planned. Boiler investments depend on 

sugar prices, interest rates, and regulations. The tendency 

now is to build larger coal-fired boilers. 

• The company employs 300 during refining season, 80 during offseason, and 20 corporate officials. 

• Plant slices an average 4,300 tons of beets per day. A tenyear average sugar yield is 235 pounds of sugar per ton of beets 

sliced. 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 14, 1984 

Summary of points discussed: 

• New owner is planning expansion in 1987 and wants to supplement 

existing low pressure boilers with one or two high pressure 

boilers. The plant will continue to burn coal or may use coal 

dust in the new boilers. 
P.14 

Company #8 

EEA Contact: Joan McGovern 

Date of Conversation: May 20, 1982 

Summary of points discussed: 

• The company has one plant. 

• Refining season typically lasts six months. The boiler is 

operating at 85 percent load during the season. 

• The plant has three boilers. The one that is used exclusively 

is rated 350,000 pph and fires pulverized lignite. It was built 

in 1975 and has an ESP. The second, 50,000 pph boiler is a standby, oil-fired unit that is rarely used. The third boiler of 

25,000 pph rated capacity is used for space heating. 

• The company plans no boiler replacements since the 350,000 unit 

was recently installed. However, if it did choose to replace 

it would prefer two smaller coal boilers of approximately 200,000 

pph each. 

• The company employs 400 during refining season and 100 in the offseason. 

1984 Update: 

EEA Contact: Patrick Ryan 

Date of Conversation: March 13, 1984 

Summary of points discussed: 

• The company is operating the same as it was in 1982, still preferring coal because it is the most economical. They have no 

plans to install or replace any boilers.