




MEMORANDUM

TO:	Mary Johnson, U.S. Environmental Protection Agency, OAQPS/SPPD

FROM:	Eastern Research Group, Inc.

DATE:	June 30, 2016

SUBJECT:	Review of Emissions and Sulfur Content Information for Liquid Fuel Boilers



1.0	INTRODUCTION

      The EPA received a petition asserting that the public lacked an opportunity to comment on a new provision in the February 2013 final amendments to the Area Source Boilers Rule (40 CFR part 63 subpart JJJJJJ) that specified that new or reconstructed oil-fired boilers with heat input capacity of 10 million Btu per hour (MMBtu/hr) or greater that combust only oil that contains no more than 0.50 weight percent sulfur or a mixture of 0.50 weight percent sulfur oil with other fuels not subject to a PM emission limit under this subpart and that do not use a post-combustion technology (except a wet scrubber) to reduce PM or sulfur dioxide emissions meet generally available control technology (GACT) for particulate matter (PM), providing the type of fuel combusted is monitored and recorded on a monthly basis. In the January 21, 2015 proposed notice of reconsideration, the EPA solicited comment on the February 2013 provision as well as on an alternative provision based on burning ultra-low-sulfur liquid fuel (ULSLF) (i.e., distillate oil that has less than or equal to 15 ppm sulfur).
      The following sources were used to assess the appropriateness of an alternate PM standard: 1) Emissions and fuel analysis data submitted through Information Collection Requests (ICRs) (approved under OMB Control No. 2060-0616) and 2) Performance tests results submitted to EPA's WebFIRE database.

2.0	DATA TABLES
      
      The following data tables in the appendix to this memo were used to assess PM emissions levels from boilers combusting oil and control of urban metal HAP for which PM serves as a surrogate in area source oil-fired boilers (i.e., Hg, arsenic, beryllium, cadmium, lead, chromium, manganese, nickel):
 Liquid-Fired Area Source Boilers Filterable PM Emissions and Sulfur Content; Data Source ICR
 Area Source Boiler Firing ULSLF; Data Source WebFIRE 
 All Liquid-Firing Area Source Boilers; Data Source WebFIRE
 Estimated PM Emissions from Fuel Analysis and Commenter Equation
 Adjusted Sales of Distillate Fuel Oil by End Use; Data Source EIA
 Estimated PM Emissions from AP-42 Compilation of Air Pollutant Emission Factors
 Major Source Boiler Firing ULSLF; Data Source WebFIRE
 Major Sources Boilers Fired Low Sulfur Fuel Oil with Metallic HAP Fuel Analysis; Data Source ICR
 ULSLF - Fired Major Sources Boiler (Merck Sharp & Dohme Corp.) with Mercury Fuel Analysis; Data Source WebFIRE
