
1
March
15,
2005
MEMORANDUM
From:
William
H.
Maxwell
CG/
ESD
(
C439­
01)

To:
CAMR
docket
OAR­
2002­
0056
Subject:
Analysis
of
operating
oil­
fired
electric
utility
steam
generating
units
In
EPA's
February
1998
"
Study
of
Hazardous
Air
Pollutant
Emissions
from
Electric
Utility
Steam
Generating
Units:
Final
Report
to
Congress"
(
RtC;
A­
92­
55,
I­
A­
90),
we
stated
that
the
majority
of
the
137
oil­
fired
plants
in
operation
at
that
time
were
estimated
to
pose
inhalation
cancer
maximum
individual
risks
(
MIR)
less
than
one­
in­
a­
million
(
1
x
10­
6).
However,
up
to
11
of
the
137
oil­
fired
plants
were
estimated
to
potentially
present
inhalation
MIR
for
cancer
above
1
x
10­
6.
As
shown
in
the
tables
below
(
1
and
2),
Ni
was
the
largest
contributor
to
these
cancer
risks
(
see
RtC
at
p.
ES­
12
and
OAR­
2002­
0056­
0173).

Table
1.
Summary
of
high­
end
inhalation
cancer
risk
estimates
based
on
local
analysis
for
oil­
fired
utilities
for
the
year
1990.
(
from
Table
ES­
4
in
RtC)

HAP
Highest
MIR
a
Population
with
lifetime
risk
>
1
x
10­
6
Number
plants
with
MIR
>
1
x
10­
6
Nickel
b
5
x
10­
5
110,000
11
Total
c
(
aggregate)
6
x
10­
5
110,000
11
a
Estimated
lifetime
MIR
due
to
inhalation
exposure
for
the
"
highest
risk"
oil­
fired
plant.
Based
on
an
uncertainty
analysis,
these
estimates
are
considered
reasonable
high­
end
estimates
(
see
RtC
at
section
ES.
7.4
for
discussion).
b
The
estimates
for
Ni
and
total
HAP
are
based
on
the
assumption
that
the
mix
of
Ni
compounds
is
50
percent
as
carcinogenic
as
Ni
subsulfide.
c
Estimated
risk
due
to
inhalation
of
the
aggregate
of
HAP
assuming
additivity
of
risk
for
14
individual
carcinogenic
HAP.
2
Table
2.
Summary
of
plant­
specific
risk
information
for
11
oil­
fired
plants
with
MIR
potentially
above
1
x
10­
6
based
on
local
analysis
for
oil­
fired
utilities
for
the
year
1990
(
See
OAR­
2002­
0056­
0173)

Plant
City
State
Maximum
predicted
risk
Nickel
a
Waiau
Pearl
City
HI
4.8E­
05
Honolulu
Honolulu
HI
1.1E­
05
New
Boston
South
Boston
MA
5.3E­
06
Astoria
Astoriak
NY
2.1E­
06
Mystic
Everett
MA
1.8E­
06
T.
G.
Smith
Lake
Worth
FL
1.8E­
06
Bryan
Bryan
TX
1.7E­
06
Riviera
Riviera
Beach
FL
1.7E­
06
Devon
Millford
CT
1.5E­
06
Alamitos
Long
Beach
CA
1.4E­
06
East
River
New
York
NY
1.3E­
06
a
Assumes
cancer
potency
equals
50
percent
that
of
Ni
subsulfide.

Since
issuance
of
the
February
1998
Report
to
Congress,
we
have
learned
that
a
number
of
the
11
plants
have
reduced
or
eliminated
their
Ni
emissions
through
unit
closures
or
fuel
switching
(
OAR­
2002­
0056­
2046;
OAR­
2002­
0056­
5998).
Of
the
42
units
that
made
up
the
11
plants,
12
units
have
permanently
ceased
operation
or
are
out
of
service
(
OAR­
2002­
0056­
2046
at
pp.
12
­
13;
OAR­
2002­
0056­
5998).
Six
units
have
reported
to
the
U.
S.
Department
of
Energy
(
DOE)
that
their
fuel
mix
now
includes
natural
gas,
which
was
not
reported
in
the
earlier
data
(
OAR­
2002­
0056­
5998).
An
additional
five
units
report
using
a
mix
of
natural
gas
and
distillate
oil
(
rather
than
residual
oil)
in
2003
(
OAR­
2002­
0056­
5998).
Five
units
have
changed
their
fuel
mixture
to
natural
gas
exclusively
since
the
data
for
the
February
1998
report
were
obtained
(
OAR­
2002­
0056­
2046
at
pp.
12
­
13;
OAR­
2002­
0056­
5998).
Finally,
2
units
fire
a
residual
oil/
natural
gas
mixture
and
have
limited
their
residual
oil
use
through
permit
restrictions
to
no
greater
than
10
percent
of
the
fuel
consumption
between
April
1
and
November
15,
with
natural
gas
being
used
for
at
least
90
percent
of
total
fuel
consumption
(
OAR­
2002­
0056­
2046
at
p.
13).
These
changes
mean
that
30
of
the
original
42
units
have
taken
steps
to
reduce
or
eliminate
their
Ni
emissions;
only
2
of
the
original
11
plants,
both
in
Hawaii,
have
units
that
appear
not
to
have
taken
any
actions
that
would
result
in
reduced
Ni
emissions.
Of
the
12
units
that
appear
to
not
have
taken
steps
to
reduce
or
eliminate
their
Ni
emissions,
only
the
eight
units
at
the
two
Hawaiian
plants
report
using
only
oil.
The
remaining
four
units
report
firing
both
oil
and
natural
gas
(
as
was
also
reported
in
the
RtC).
The
11
plants,
along
with
their
fuel
mix
and
operational
status
in
1994
and
2003,
are
provided
in
Table
3.
3
4
Table
3.
Summary
of
information
for
11
oil­
fired
plants
listed
in
previous
table.

Plant
Unit
City
State
Fuel
mix/
operational
status
a
1994
b
2003
c
Waiau
Waiau
3
Pearl
City
HI
Oil
RFO
Waiau
Waiau
4
Pearl
City
HI
Oil
RFO
Waiau
Waiau
5
Pearl
City
HI
Oil
RFO
Waiau
Waiau
6
Pearl
City
HI
Oil
RFO
Waiau
Waiau
7
Pearl
City
HI
Oil
RFO
Waiau
Waiau
8
Pearl
City
HI
Oil
RFO
Honolulu
Honolulu
8
Honolulu
HI
Oil
RFO
Honolulu
Honolulu
9
Honolulu
HI
Oil
RFO
New
Boston
New
Boston
1
South
Boston
MA
NG/
Oil
NG
New
Boston
New
Boston
2
South
Boston
MA
Oil
Not
operating
Astoria
Astoria
1
Astoriak
NY
NG/
Oil
Not
operating
Astoria
Astoria
2
Astoriak
NY
NG/
Oil
NG
Astoria
Astoria
3
Astoriak
NY
Oil
RFO/
NG
Astoria
Astoria
4
Astoriak
NY
NG/
Oil
RFO/
NG
Astoria
Astoria
5
Astoriak
NY
Oil
RFO/
NG
Mystic
Mystic
4
Everett
MA
Oil
Not
operating
Mystic
Mystic
5
Everett
MA
Oil
Not
operating
Mystic
Mystic
6
Everett
MA
Oil
Not
operating
Mystic
Mystic
7
Everett
MA
NG/
Oil
RFO/
NG
T.
G.
Smith
T.
G.
Smith
S1
Lake
Worth
FL
Oil
NG/
RFO
T.
G.
Smith
T.
G.
Smith
S2
Lake
Worth
FL
Oil
Out
of
service
T.
G.
Smith
T.
G.
Smith
S3
Lake
Worth
FL
Oil
NG/
RFO
T.
G.
Smith
T.
G.
Smith
S4
Lake
Worth
FL
Oil
Out
of
service
Bryan
Bryan
3
Bryan
TX
Oil
NG/
DFO
Bryan
Bryan
4
Bryan
TX
Oil
NG/
DFO
Bryan
Bryan
5
Bryan
TX
Oil
NG/
DFO
Bryan
Bryan
6
Bryan
TX
NG/
Oil
NG/
DFO
Bryan
Bryan
7
Bryan
TX
Oil
NG/
DFO
Riviera
Riviera
3
Riviera
Beach
FL
NG/
Oil
RFO/
NG
Riviera
Riviera
4
Riviera
Beach
FL
NG/
Oil
RFO/
NG
Devon
Devon
3
Millford
CT
Oil
Not
operating
Devon
Devon
4
Millford
CT
Oil
Not
operating
Devon
Devon
5
Millford
CT
Oil
Not
operating
Devon
Devon
6
Millford
CT
Oil
Not
operating
Devon
Devon
7
Millford
CT
Oil
RFO/
NG
Devon
Devon
8
Millford
CT
Oil
RFO/
NG
Alamitos
Alamitos
2
Long
Beach
CA
NG/
Oil
NG
Alamitos
Alamitos
4
Long
Beach
CA
NG/
Oil
NG
Alamitos
Alamitos
5
Long
Beach
CA
NG/
Oil
NG
5
East
River
East
River
5
New
York
NY
Oil
Not
operating
East
River
East
River
6d
New
York
NY
Oil
RFO/
NG
East
River
East
River
7d
New
York
NY
Oil
RFO/
NG
a
RFO
­
Residual
fuel
oil
DFO
­
Distillate
fuel
oil
NG
­
Natural
gas
b
RtC;
OAR­
2002­
0056­
0173
c
Existing
Generating
Units
in
the
United
States
by
State,
Company
and
Plant,
2003;
existing
generating
units
as
of
January
1,
2004
(
OAR­
2002­
0056­
5998)
d
Agreement
limits
fuel
oil
use
to
less
than
10
percent
of
fuel
consumption
between
April
1
and
November
15.
Natural
gas
used
for
at
least
90
percent
of
fuel
consumption
(
OAR­
2002­
0056­
2046)

It
is
likely
that
this
same
mix
of
unit
retirements
and
fuel
mixture
changes
have
been
occurring
throughout
the
oil­
fired
segment
of
the
electric
utility
industry
in
the
past
decade.
The
number
of
operational
oil­
fired
electric
utility
units
has
declined
substantially
between
1994
and
2003.
The
risk
determination
reported
in
February
1998
was
based
on
309
units
at
137
plants
(
RtC;
OAR­
2002­
0056­
0173);
the
inventory
of
oil­
fired
units
in
2003
has
decreased
to
142
units
(
18
of
which
are
listed
as
being
either
"
out
of
service"
or
"
on
standby"
and
some
of
which
may
not
meet
the
definition
of
an
"
electric
utility
steam
generating
unit")
at
74
plants
(
OAR­
2002­
0056­
5998).
This
decreasing
trend
in
the
number
of
oil­
fired
units
is
expected
to
continue.
The
latest
DOE/
EIA
projections
(
OAR­
2002­
0056­
5999)
estimate
no
new
utility
oil­
fired
generating
capacity
and
decreasing
existing
oil­
fired
generating
capacity
through
2025,
with
an
additional
29.2
gigawatts
of
combined
oil­
and
natural
gas­
fired
existing
capacity
being
retired
by
2025.

Further,
during
the
public
comment
period,
a
number
of
commenters
(
OAR­
2002­
0056­
2046,
­
2910,
­
2912,
­
5282,
­
5284)
provided
EPA
with
information
indicating
that
the
level
of
sulfidic
Ni
(
the
form
of
nickel
considered
to
have
greatest
carcinogenic
potency)
emissions
from
oil­
fired
utility
units
is
less
than
had
been
estimated
in
the
RtC.

In
summary,
at
the
time
of
the
RtC,
MIR
estimates
for
Ni
emissions
at
11
coal­
fired
utilities
were
greater
than
1
x
10­
6,
with
the
highest
plant
MIR
being
5
x
10­
5.
Many
of
these
11
units
now
either
no
longer
operate
or
currently
use
natural
gas,
from
which
there
are
negligible
Ni
emissions.
As
for
the
remaining
units,
available
projections
indicate
a
continued
decrease
in
generating
capacity
(
with
some
uncertainty
as
the
projections
include
oil­
and
gas­
fired
units
in
the
same
category),
a
lack
of
new
capacity,
and
the
increasing
retirement
of
units.

Because
of
(
1)
the
dramatic
reductions
in
the
total
nationwide
inventory
of
oil­
fired
electric
utility
steam
generating
units
(
more
so
than
we
had
envisioned
previously);
(
2)
the
changing
fuel
mixtures
being
used
at
the
remaining
units;
and
(
3)
the
reduced
levels
of
sulfidic
Ni
likely
being
emitted
from
oil­
fired
utility
units,
current
levels
of
oil­
fired
utility
Ni
emissions
are
believed
to
pose
substantially
lower
risk
than
the
1998
analysis
(
RtC)
had
concluded.
