Date:		September 9, 2011

Subject: 	Confirmation of Fuels Combusted at Oil-fired Sources during
Maximum Achievable Control Technology (MACT) Floor Performance Testing
and Updated Floor Limits with Potential Source Subcategories for
Oil-fired Generating Units

From:		Jeffrey Cole (RTI International)

To:  		Bill Maxwell

		OAQPS/SPPD/ESG (D243-01)

		U.S. Environmental Protection Agency

		Research Triangle Park, NC 27711

Summary of Technical Directive

The EPA requested that RTI determine what fuel oil type (or other
blended fuel) was combusted during the Mercury Air Toxics Study (MATS)
information collection request (ICR) MACT floor performance tests used
in the floor analysis for “oil-fired units.” The EPA work assignment
manager (WAM) requested confirmation that the remainder of the emissions
data received since proposal (i.e., Puerto Rico and Guam facilities) had
been entered into the MACT floor dataset. The EPA WAM also requested
that RTI produce updated statistical analyses to incorporate the new
data and an analyses to evaluate how establishing potential
subcategories for fuel oil grade (No. 2 and No. 6) and continental
location (i.e., differentiating continental sources located in North
America from non-continental sources) would affect the various MACT
floor limits for oil-fired units.

Background

The EPA received comments from industry advocates for oil-fired EGUs
during the proposed rule’s public comment period that the fuel types
listed for some oil-fired units in the proposed rule’s emissions data
were incorrect. RTI was tasked with contacting all companies
participating in the MATS ICR that had uploaded data from testing of
oil-fired units to confirm the fuels used during MACT floor performance
tests.

Then the EPA requested that once all the missing oil-fired EGU data had
been loaded, RTI conduct a what-if analysis of  a subcategorization
scheme based on fuel oil grade (No. 2 and No. 6) and unit location
(continental or non-continental).  The reason for this analysis was to
determine the validity of concerns expressed by commenters regarding the
inherent differences between fuel grades and fuel sources (i.e.,
continental versus non-continental) that would affect a unit’s ability
to meet a standard based on the combination of fuel grades/sources.

Technical Approach

With regard to the commenter’s assertion that erroneous fuel types
were listed for oil-fired units within the proposal dataset, RTI
identified two sources that were burning atypical fuels during the
oil-fired MACT floor performance tests and excluded those sources from
further analyses. 

With regard to the potential subcategorization scheme based on fuel oil
grade and facility location (continental vs. non-continental),
subsequent MACT floor calculations were completed for the following
groupings of EGUs:

All No. 2 and No. 6 oil-fired, continental, and non-continental sources.

All No. 2 oil-fired, continental sources; there are no non-continental
No. 2 oil-fired EGUs 	meeting the proposed applicability criteria.

All No. 6 oil-fired, continental, and non-continental sources.

All No. 2 and No. 6 oil-fired, continental sources.

All No. 6 oil-fired, non-continental sources; there are no
non-continental No. 2 oil-fired EGUs meeting the proposed applicability
criteria.

The number of sources included in each MACT floor data set for each
potential subcategory was determined based on the number of sources with
available emissions data using the criteria of CAA section 112(d)(3).

Data Collection and Fuel Verification

RTI contacted the operators of the oil-fired units that composed the
MACT floor data set to confirm the fuel(s) used during the MACT floor
performance tests. In confirming the fuel blends for the proposal, RTI
originally determined that there were five units which blended 10
percent or greater natural gas (based on the respondents reporting of
natural gas co-firing) and excluded these five sources from the MACT
floor analyses because inclusion of sources using 10 percent or more
natural gas could bias HAP emissions low and make the floor potentially
unachievable for units firing greater than 90 percent fuel oil. However,
during this post-proposal fuel verification, RTI found two additional
sources that should be excluded from the floor analyses:

C.D. McIntosh, Unit 2 (ORIS Code 676) which averages firing only 30
percent fuel oil with natural gas, and 

Santee Cooper – Jefferies, Unit 2 (ORIS Code 3319) which is operated
as a seasonal peaking and uses approximately 97 percent used motor oil
and 3 percent (No. 2 fuel oil). 

Also, the Guam Power Authority provided comments (Docket ID:
EPA-HQ-OAR-2009-0234-18433) that indicated that natural gas was not
available on the island and confirmed that only residual fuel oil was
used in the largest generating units on the island.

Table 1 shows the fuel types confirmed for all oil-fired units in the
post-proposal review. The units excluded from MACT floor analyses are
listed at the bottom of the table. Table 1 shows both the oil-fired
units that were tested under Part III of the ICR and those that
submitted Hg emissions data under Part II of the ICR.

As shown in Table 1, there are six units located at three continental
U.S. facilities (two units each) that combust No. 2 fuel oil,
exclusively. At one of these three facilities, two of their No. 2,
oil-fired EGUs 

Table 1. Fuel Used During MACT Floor Performance Tests for Oil-fired
Sources

Facility ID	Plant Name	Unit ID	Location	Primary Fuel	Other Fuel(s)	Other
Fuel Description

546	Montville Power	5	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



548	Norwalk Harbor Station	2	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



562	Middletown Power Station	2	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



617	Port Everglades	PPE03	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



617	Port Everglades	PPE04	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



621	Turkey Point	PTF01	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



621	Turkey Point	PTF02	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



638	Suwannee River	Suw_Cfg_2	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



638	Suwannee River	Suw_Cfg_3	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



638	Suwannee River	Suw_Cfg_1	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



667	Northside	3	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



764	Honolulu Power Plant	H8	Outside Continental U.S. (Hawaii)	No. 6 Fuel
Oil (residual or bunker C)



764	Honolulu Power Plant	H9	Outside Continental U.S. (Hawaii)	No. 6 Fuel
Oil (residual or bunker C)



765	Kahe Power Plant	K3	Outside Continental U.S. (Hawaii)	No. 6 Fuel Oil
(residual or bunker C)



765	Kahe Power Plant	K1	Outside Continental U.S. (Hawaii)	No. 6 Fuel Oil
(residual or bunker C)



766	Waiau Power Plant	W6	Outside Continental U.S. (Hawaii)	No. 6 Fuel
Oil (residual or bunker C)



766	Waiau Power Plant	W7	Outside Continental U.S. (Hawaii)	No. 6 Fuel
Oil (residual or bunker C)



990	AES Harding Street	09	Inside Continental U.S.	No. 2 Fuel Oil
(distillate)



990	AES Harding Street	10	Inside Continental U.S.	No. 2 Fuel Oil
(distillate)



991	IP&L Eagle Valley	1, 2 (shared stack)	Inside Continental U.S.	No. 2
Fuel Oil (distillate)



1507	William F Wyman	1	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



1507	William F Wyman	2	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



1564	Vienna	Unit 8	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



1642	West Springfield	Unit 3	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



1682	Cleary Flood	8	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)	No. 2 Fuel Oil (distillate)	7-10% No. 2; 90-93% No. 6

2050	Baxter Wilson	001	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



2378	BL England	3	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



2411	PSEG Sewaren Generating Station	SEWU4E4PT4OS0	Inside Continental
U.S.	No. 6 Fuel Oil (residual or bunker C)



2411	PSEG Sewaren Generating Station	SEWU3E3PT3OS0	Inside Continental
U.S.	No. 6 Fuel Oil (residual or bunker C)



2411	PSEG Sewaren Generating Station	SEWU1E1PT1OS0	Inside Continental
U.S.	No. 6 Fuel Oil (residual or bunker C)



2480	Dynegy Danskammer Generation Station	2	Inside Continental U.S.	No.
6 Fuel Oil (residual or bunker C)



2480	Dynegy Danskammer Generation Station	1	Inside Continental U.S.	No.
6 Fuel Oil (residual or bunker C)



2493	East River	60	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)	other	Natural Gas

2516	Northport	2	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)	other	Natural Gas1

2516	Northport	3	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)	other	Natural Gas1

2517	Port Jefferson	4	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)	other	Natural Gas1

3148	Martins Creek	U3	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



3148	Martins Creek	U4	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



3159	Cromby	Unit 2	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



3181	Mitchell Power Station	1	Inside Continental U.S.	No. 2 Fuel Oil
(distillate)



3181	Mitchell Power Station	3	Inside Continental U.S.	No. 2 Fuel Oil
(distillate)



3804	Possum Point	Unit 5	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)



3809	Yorktown	Unit 3	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



6042	Manatee	PMT01	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



6042	Manatee	PMT02	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



6043	Martin	PMR01	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



6043	Martin	PMR02	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



8054	Gerald Andrus	001	Inside Continental U.S.	No. 6 Fuel Oil (residual
or bunker C)



8906	Astoria	A-S0003	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)



40429	Cabras Power Plant	2	Outside Continental U.S. (Guam)	No. 6 Fuel
Oil (residual or bunker C)



70000	Aguirre	Aguirre 1	Outside Continental U.S. (Puerto Rico)	No. 6
Fuel Oil (residual or bunker C)



70000	Aguirre	Aguirre 2	Outside Continental U.S. (Puerto Rico)	No. 6
Fuel Oil (residual or bunker C)



70002	Costa Sur	Costa Sur 3	Outside Continental U.S. (Puerto Rico)	No. 6
Fuel Oil (residual or bunker C)



70002	Costa Sur	Costa Sur 6	Outside Continental U.S. (Puerto Rico)	No. 6
Fuel Oil (residual or bunker C)



70003	San Juan Plant	San Juan 7	Outside Continental U.S. (Puerto Rico)
No. 6 Fuel Oil (residual or bunker C)



70003	San Juan Plant	San Juan 8	Outside Continental U.S. (Puerto Rico)
No. 6 Fuel Oil (residual or bunker C)



70003	San Juan Plant	San Juan 9	Outside Continental U.S. (Puerto Rico)
No. 6 Fuel Oil (residual or bunker C)



70003	San Juan Plant	San Juan 10	Outside Continental U.S. (Puerto Rico)
No. 6 Fuel Oil (residual or bunker C)



Note: The units below were not used in any MACT Floor analyses because
of their fuel blending.

676	C.D. McIntosh, Jr.	Unit 2	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)	other	Natural Gas2

3161	Eddystone	Unit 3, Unit 4  (shared stack)	Inside Continental U.S.
No. 6 Fuel Oil (residual or bunker C)	other	Natural Gas2

2500	Ravenswood Power Station	20	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)	other	Natural Gas

2500	Ravenswood Power Station	30	Inside Continental U.S.	No. 6 Fuel Oil
(residual or bunker C)	other	Natural Gas2

3319	Santee Cooper-Jefferies	Unit 2	Inside Continental U.S.	Used Motor
Oil	No. 2 Fuel Oil (distillate)	97% Used Motor Oil / 3% No. 2 Fuel Oil
(distillate)

8002	Newington	1	Inside Continental U.S.	No. 6 Fuel Oil (residual or
bunker C)	other	Natural Gas2

share a common stack (IP&L Eagle Valley, Units 1 and 2). In the
statistical spreadsheets, RTI treated data from EGUs sharing a common
stack as separate sources however; the source did not provide a complete
set of metals data. The result in this case was that, while most of the
analyses resulted in a data set of six No. 2 oil-fired sources and a
MACT floor analysis based on the top five sources, complete “total HAP
metals” and cobalt emissions data were available for only four No. 2
oil-fired sources.

RTI is waiting for one company to submit new data to correct a data
entry error that has prevented the update of the HCl and HF acid gas
MACT floor results for oil-fired EGUs. This company operates oil-fired
EGUs outside of the continental U.S. and, since such ICR data is
limited, its inclusion is essential to complete those MACT floor
analyses.

Emission Limit Determinations

In this memorandum, RTI is presenting updated MACT floors for mercury
(Hg), total metals (with and without Hg), and non-mercury HAP metals for
all the oil-fired units that provided complete data submittals under the
MATS ICR. RTI will complete the analysis of the acid gas MACT floors
after these data are received.

After compiling the final set of available oil-fired emissions data
(Group 1), the dataset was divided into the previously mentioned five
potential subcategories. The datasets were sorted and the statistical
analyses for upper predictive limit (UPL) were completed for each of the
potential oil-fired subcategories.  The statistical analysis calculated
the 99th percentile UPL emission limits based on the average emission
rates (in contrast to the individual run data) from all available
oil-fired performance tests. This use of average emission rates was
consistent with how EPA performed its statistical analysis spreadsheets
for the proposed rule’s MACT floors for oil-fired units.

Summary of Findings

It should be noted that when comparing the proposed MACT floors with the
updated MACT floors from this analysis, some differences will be noticed
that are attributed to the rounding conventions utilized for the
proposed rule. In Tables 2 through 53 the data in the “proposed”
rows in each table reflect the rounding conventions used in the proposal
to convert the UPL calculated values to the form of the standard. All
other rows reflect the complete set of updated data without rounding. By
examining the UPL, the reader can determine if the change in value is
due to a data change or to the proposal’s rounding convention.

The results of the subcategorization analysis are presented in a series
of tables with all of the potential subcategories reflected in each
table.  The MACT floor values are presented for each pollutant in a
group of four tables; existing input-based (i.e. lb/MMBtu), existing
output-based (i.e. lb/MW), new output-based (i.e. lb/MW), and a table
describing the data set used to calculate the floor values. 

Subcategorization Analysis Results

Mercury

Tables 2, 3, and 4, show the calculated MACT floors for each of the
potential oil subcategories. Table 5 shows the number of sources with
available emissions data in each potential subcategory and the
respective number of sources used in the floor analysis for the
subcategory.

As shown in the tables, total metals are approximately twice as high for
No. 6 oil as for No. 2 oil. It is noteworthy that Hg emission rates from
the top five No. 2 oil sources are approximately an order of magnitude
higher than the top six residual oil sources. 

Total Metals With and Without Hg

Tables 6, 7, and 8 show the MACT floors calculated for total metals
(including Hg) with subcategories for oil grades and continental
locations. Table 9 shows the number of sources with available emissions
data in each potential subcategory and the respective number of sources
used in the floor analysis for the subcategory.

Tables 10, 11 and 12 show the MACT floors calculated for total metals
only (not including Hg) with subcategories for oil grades and
continental locations. Table 13 shows the number of sources with
available emissions data in each potential subcategory and the
respective number of sources used in the floor analysis for the
subcategory. Note that the low levels of Hg emissions relative to the
other metals make the non-Hg metals MACT floor and the total metals MACT
floor (including Hg) essentially identical.

RTI assured that all performance test averages used in the analyses for
total metals (including Hg) were based on complete sets of all HAP
metals. This criteria generally yielded smaller data sets for the total
metals analyses than for individual metals analyses because any source
test that omitted one or more HAP metals was excluded from the total
metals analyses. As mentioned earlier in this memorandum, the complete
total metals data set criteria removed two of the six No. 2 oil-fired
sources (IP&L Eagle Valley Units 1 and 2) leaving only 4 emission
sources with available data for the total metals analyses for distillate
sources.

The updated results indicate there is a marked difference in total
metals emissions from units firing No. 2 fuel oil versus units firing
No. 6 fuel oil. The updated results also indicate that there is a
substantial difference in total metals emissions from units operated in
the continental U.S. versus non-continental units. The total metals MACT
floors for units outside the continental U.S. are approximately 62 times
greater than the total metals floors for non-continental sources. This
large difference is because all floor units in the continental data set
either burn No. 2 fuel oil (without PM control) or burn No. 6 fuel oil
(with installed ESPs). This is would be expected given the potential for
metals to have been removed during refining of the No. 2 fuel oil and
this phenomenon is evidenced as well in the results reflected below for
the individual metals. If we compare the total metals floors for the
units burning No. 6 fuel oil in the continental U.S. to the oil-fired
units operated outside the continental U.S. (which all burn No. 6 fuel
oil), the uncontrolled, non-continental sources are found to have
emissions approximately 12 times higher than the ESP controlled
continental sources.  

During completion of the updated analyses it was determined that the
original MACT floor data set only had 42 valid total metals data sets.
Similarly, the updated data set only has 42 valid total metals data
sets. Therefore, the MACT floor total metals data set for existing
oil-fired units should have been comprised of only five sources instead
of the seven sources used for the proposed total metals floors. For the
total metals UPL calculations, use of five sources rather than seven
sources in combination with the updated data set resulted in change to
the MACT floor (including variability) of approximately 10 percent;
however this change was not sufficiently large to change the rounded
value that was proposed as the floor.

Antimony

Tables 14, 15, and 16 show the MACT floors calculated for antimony with
subcategories for oil grades and continental locations. Table 17 shows
the number of sources with available emissions data in each potential
subcategory for antimony and the respective number of sources used in
the floor analysis for the subcategory.

The results indicate that there is a marked difference in the antimony
emissions from sources firing No. 2 fuel oil compared to sources firing
No. 6 fuel oil. The MACT floor for the potential No. 6 fuel oil
subcategory is approximately 5 times greater than the No. 2 fuel oil
subcategory for antimony. There is also a notable difference between
antimony emissions from units operated in the continental U.S. as
opposed to units operated outside the continental United States. The
antimony MACT floor for units outside the continental U.S. is
approximately 5 times greater than that of the antimony MACT floor for
units inside the continental United States.

Arsenic

Tables 18, 19, and 20 show the MACT floors calculated for arsenic with
subcategories for oil grades and continental locations. Table 21 shows
the number of sources with available emissions data in each potential
subcategory for arsenic and the respective number of sources used in the
floor analysis for the subcategory.

The results indicate that there is a marked difference in the arsenic
emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 2 fuel oil
arsenic MACT floor is over 2 times greater than that of the No. 6 fuel
oil arsenic MACT floor. There is also a substantial difference between
arsenic emissions from units operated in the continental U.S. as opposed
to units operated outside the continental United States. The arsenic
MACT floor for units outside the continental U.S. is approximately 8
times greater than that of the arsenic MACT floor for units inside the
continental United States.

Beryllium

Tables 22, 23, and 24 show the MACT floors calculated for beryllium with
subcategories for oil grades and continental locations. Table 25 shows
the number of sources with available emissions data in each potential
subcategory for beryllium and the respective number of sources used in
the floor analysis for the subcategory.

The results indicate that there is a little difference in the beryllium
emissions from units firing No. 2 vs. No. 6 fuel oil (approximately 1
percent). However, there is a substantial difference between beryllium
emissions from units operated in the continental U.S. as opposed to
units operated outside the continental United States. The beryllium MACT
floor for units outside the continental U.S. is approximately 8 times
greater than that of the beryllium MACT floor for units inside the
continental United States.

Cadmium

Tables 26, 27, and 28 show the MACT floors calculated for cadmium with
subcategories for oil grades and continental locations. Table 29 shows
the number of sources with available emissions data in each potential
subcategory for cadmium and the respective number of sources used in the
floor analysis for the subcategory.

The results indicate that there is a marked difference in the cadmium
emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 2 fuel oil
cadmium MACT floor is approximately 4 times greater than that of the No.
6 fuel oil cadmium MACT floor. There is also a difference between
cadmium emissions from units operated in the continental U.S. as opposed
to units operated outside the continental United States. The cadmium
MACT floor for units outside the continental U.S. is approximately 2
times greater than that of the cadmium MACT floor for units inside the
continental United States.

Cobalt

Tables 30, 31, and 32 show the MACT floors calculated for cobalt with
subcategories for oil grades and continental locations. Table 33 shows
the number of sources with available emissions data in each potential
subcategory for cobalt and the respective number of sources used in the
floor analysis for the subcategory. It should be noted that RTI did not
receive cobalt data with each of the Method 29 results submitted under
the ICR. This caused some of the cobalt MACT floor data sets to include
fewer sources than the data sets for other individual metals. These
incomplete Method 29 results are also the reason the total metals floors
data sets having fewer sources than other individual metals floor data
sets.

The results indicate that there is a substantial difference in the
cobalt emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 2
fuel oil cobalt MACT floor is approximately 7 times greater than that of
the No. 6 fuel oil cobalt MACT floor. There is also a substantial
difference between cobalt emissions from units operated in the
continental U.S. as opposed to units operated outside the continental
United States. The cobalt MACT floor for units outside the continental
U.S. is approximately 54 times greater than that of the cobalt MACT
floor for units inside the continental United States. This large
difference is because the floor units inside the continental U.S. MACT
floor are all burning No. 2 fuel oil. If we compare cobalt emissions for
the units burning No. 6 fuel oil in the continental U.S. (i.e., the No.
6 fuel only cobalt MACT floor) as opposed to units operated outside the
continental U.S. (which all burn No. 6 fuel oil) a difference of
18 times is found. While this factor is less than the 54 times
calculated above, it should be also noted that the No. 6 fuel only MACT
floor (for cobalt emissions from sources within the continental U.S.)
contains five sources that are all controlled by ESPs.

During completion of the updated analyses it was determined that the
original MACT floor data set only had 44 valid cobalt data sets.
Similarly, the updated data set only has 44 valid cobalt data sets.
Therefore, the MACT floor cobalt data set for existing oil-fired units
should have been comprised of only five sources instead of the seven
sources used for the cobalt proposed floors. This reduced number of data
averages was due to incomplete data submittals. For the cobalt UPL
calculations, use of five sources rather than seven sources combined
with the updated data set resulted in change to the MACT floor
(including variability) of approximately 10 percent; however this change
was not sufficiently large to change the rounded value that was proposed
as the floor.

Chromium

Tables 34, 35, and 36 show the MACT floors calculated for chromium with
subcategories for oil grades and continental locations. Table 37 shows
the number of sources with available emissions data in each potential
subcategory for chromium and the respective number of sources used in
the floor analysis for the subcategory.

The results indicate that there is a marked difference in the chromium
emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 2 fuel oil
chromium MACT floor is approximately 2 times greater than that of the
No. 6 fuel oil chromium MACT floor. There is also a difference between
chromium emissions from units operated in the continental U.S. as
opposed to units operated outside the continental United States. The
chromium MACT floor for units outside the continental U.S. is
approximately 3 times greater than that of the chromium MACT floor for
units inside the continental United States.

Lead

Tables 38, 39, and 40 show the MACT floors calculated for lead with
subcategories for oil grades and continental locations. Table 41 shows
the number of sources with available emissions data in each potential
subcategory for lead and the respective number of sources used in the
floor analysis for the subcategory.

The results indicate that there is a substantial difference in the lead
emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 2 fuel oil
lead MACT floor is approximately 6 times greater than that of the No. 6
fuel oil lead MACT floor. There is also a small difference between lead
emissions from units operated in the continental U.S. as opposed to
units operated outside the continental United States. The lead MACT
floor for units outside the continental U.S. is approximately 1.3 times
greater than that of the lead MACT floor for units inside the
continental United States.

Manganese

Tables 42, 43, and 44 show the MACT floors calculated for manganese with
subcategories for oil grades and continental locations. Table 45 shows
the number of sources with available emissions data in each potential
subcategory for manganese and the respective number of sources used in
the floor analysis for the subcategory.

The results indicate that there is a marked difference in the manganese
emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 6 fuel oil
manganese MACT floor is approximately 2.5 times greater than that of the
No. 2 fuel oil manganese MACT floor. There is also a substantial
difference between manganese emissions from units operated in the
continental U.S. as opposed to units operated outside the continental
United States. The manganese MACT floor for units outside the
continental U.S. is approximately 7 times greater than that of the
manganese MACT floor for units inside the continental United States.

Nickel

Tables 46, 47, and 48 show the MACT floors calculated for nickel with
subcategories for oil grades and continental locations. Table 49 shows
the number of sources in each subcategory for nickel and the respective
number of sources used in the floor analysis for the subcategory.

The results indicate that there is a substantial difference in the
nickel emissions from units firing No. 2 vs. No. 6 fuel oil. The No. 6
fuel oil nickel MACT floor is approximately 9 times greater than that of
the No. 2 fuel oil nickel MACT floor. There is also a very substantial
difference between nickel emissions from units operated in the
continental U.S. as opposed to units operated outside the continental
United States. The nickel MACT floor for units outside the continental
U.S. is approximately 94 times greater than that of the nickel MACT
floor for units inside the continental United States. This large
difference is because all floor units in the continental data set burn
No. 2 fuel oil (without PM control). If we compare nickel floors for the
units burning No. 6 fuel oil in the continental U.S. to the oil-fired
units operated outside the continental U.S. (which all burn No. 6 fuel
oil), the uncontrolled, non-continental sources are found to have
emissions approximately 10 times higher than the ESP controlled
continental sources. 

Selenium

Tables 50, 51, and 52 show the MACT floors calculated for selenium with
subcategories for oil grades and continental locations. Table 53 shows
the number of sources in each subcategory and the respective number of
sources used in the floor analysis for the subcategory.

The results indicate that there is little difference in the selenium
emissions from units firing No. 2 vs. No. 6 fuel oil (approximately 7
percent). There is a difference between selenium emissions from units
operated in the continental U.S. as opposed to units operated outside
the continental United States. The selenium MACT floor for units outside
the continental U.S. is approximately 2 times greater than that of the
selenium MACT floor for units inside the continental United States.

Conclusions

Approximately 90 percent of oil-fired sources responding to the ICR burn
almost exclusively No. 6 fuel oil. Approximately 12 percent of the No. 6
oil fired sources are controlled by ESPs only and about17 percent
controlled by multiclones only. As shown in the following table, nickel
and manganese are the predominant metal emitted from No. 6 oil-fired
units that are controlled by ESPs. For No. 2 oil-fired units without PM
controls, the predominant metals emitted are cobalt and lead. A
comparison of the total metals emissions indicates that the
best-controlled No. 6 oil units (controlled by ESPs) emitted
approximately 60 percent more total metals than uncontrolled No. 2 oil
units. 

Pollutant	No. 2 Fuel Only 

Floor value (lb/TBtu)	No. 6 Fuel Only 

Floor value (lb/TBtu)	Comparison of Mean Emission Rates with Variability
(UPL)

As	2.479E+00	1.146E+00	Uncontrolled No. 2 Oil Higher

Be	7.000E-02	7.000E-02	Essentially No Difference

Cd	3.952E-01	1.105E-01	Uncontrolled No. 2 Oil Higher

Co	1.925E+01	2.746E+00	Uncontrolled No. 2 Oil Higher

Cr	4.944E+00	2.387E+00	Uncontrolled No. 2 Oil Higher

Mn	5.071E+00	1.272E+01	ESP Controlled No. 6 Oil Higher

Pb	1.593E+01	2.466E+00	Uncontrolled No. 2 Oil Higher

Sb	2.261E-01	1.216E+00	ESP Controlled No. 6 Oil Higher

Se	1.370E+00	1.473E+00	ESP Controlled No. 6 Oil Higher

Nickel	5.541E+00	5.008E+01	ESP Controlled No. 6 Oil Higher

Pollutant	No. 2 Fuel Only 

Floor value (lb/MMBtu)	No. 6 Fuel Only 

Floor value (lb/MMBtu)	Comparison of Mean Emission Rates with
Variability (UPL)

Total Metals + Hg	6.148E+01	9.933E+01	ESP Controlled No. 6 Oil Higher



While the data in the preceding table supports the premise in a number
of public comments that a well controlled No.6 oil-fired unit cannot
achieve the total metals emission rate of an uncontrolled No. 2
oil-fired unit, the data indicates that ESP-controlled No. 6 oil sources
can approach the total metals emission rates achieved by uncontrolled
No. 2 oil-fired sources and in some cases achieve lower emission rates
of individual metals. 

Some commenters suggested that the EPA should establish a subcategory
based on the continental location of a unit due to differences in the
metals content of the oil from continental versus non-continental
sources. The public comments from several companies that operate No. 6
oil-fired units, however, focused on the difference between the total
metals contents of No. 2 oil and No. 6 oil and not on the difference
between the mercury content of the different oil grades.

With regard to mercury, RTI found that based on the fuel analyses
received, mercury makes up less than one percent of the metals content
of fuel oils used during performance testing and our analysis here
indicates that the correlation between mercury content and fuel grade is
not as clear as the relationship between the other metals content and
fuel grade. 

As noted in the work of Wilhelm (see Appendix A), more than half of the
crude oil that is processed in the United States is imported so the
long-term average concentrations in domestic fuel oils are likely to
approach the world wide average. The ICR data for uncontrolled No. 6
oil-fired sources supports Wilhelm’s assertion because the average of
all emission rates for uncontrolled, non-continental sources was within
a 98 percent agreement with the average of the uncontrolled continental
sources. 

The data in the preceding summary table indicates that effective PM
controls can mitigate emissions of trace constituents (such as metals)
from No.6 oil-fired sources. However, there are no sources outside of
the continental United States equipped with any form of PM control or
that burn any No. 2 fuel oil. This lack of PM controls on the
non-continental sources is the primary factor accounting for the higher
emissions from non-continental sources, and not the origin of the crude
oil. Based on this data analysis, it is our opinion that
subcategorization by fuel oil type may be warranted; however,
subcategorization by continental location due to crude oil source would
not be warranted.

Mercury

Table 2. Existing Mercury (Hg) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Mercury (Proposed, 3/16/11)	1.9880E-08	4.8170E-08	7	0.05	lb/TBtu

Mercury (Updated)	1.8708E-08	4.5807E-08	7	0.05	lb/TBtu

Mercury (Updated, No. 2 Fuel Oil Only)	1.3987E-07	3.3913E-07	5	0.34
lb/TBtu

Mercury (Updated, No. 6 Fuel Oil Only)	1.7331E-08	4.5986E-08	6	0.05
lb/TBtu

Mercury (Updated, Inside Continental U.S.)	1.8432E-08	5.9878E-08	5	0.06
lb/TBtu

Mercury (Updated, Outside Continental U.S.)	2.4958E-08	4.3820E-08	5	0.04
lb/TBtu



Table 3. Existing Mercury (Hg) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Mercury (Proposed, 3/16/11)	2.2752E-07	6.1287E-07	7	0.0007	lb/GWh

Mercury (Updated)	1.9251E-07	4.8248E-07	7	0.0005	lb/GWh

Mercury (Updated, No. 2 Fuel Oil Only)	1.8549E-06	4.5684E-06	5	0.005
lb/GWh

Mercury (Updated, No. 6 Fuel Oil Only)	1.7745E-07	4.8226E-07	6	0.0005
lb/GWh

Mercury (Updated, Inside Continental U.S.)	2.2616E-07	8.2568E-07	5
0.0008	lb/GWh

Mercury (Updated, Outside Continental U.S.)	2.4618E-07	4.4299E-07	5
0.0004	lb/GWh



Table 4. New Mercury (Hg) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Mercury (Proposed, 3/16/11)	6.4837E-08	9.3613E-08	1	0.0001	lb/GWh

Mercury (Updated)	6.4837E-08	9.3613E-08	1	0.0001	lb/GWh

Mercury (Updated, No. 2 Fuel Oil Only)	1.2567E-06	5.3601E-06	1	0.005
lb/GWh

Mercury (Updated, No. 6 Fuel Oil Only)	6.4837E-08	9.3613E-08	1	0.0001
lb/GWh

Mercury (Updated, Inside Continental U.S.)	6.4837E-08	9.3613E-08	1
0.0001	lb/GWh

Mercury (Updated, Outside Continental U.S.)	1.6618E-07	1.8700E-06	1
0.002	lb/GWh



Table 5. Number of Data Averages in Each Subcategory and Number of Units
in Each Mercury (Hg) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Mercury (Updated)	58 (all data)	7

Mercury (Updated, No. 2 Fuel Oil Only)	6	5

Mercury (Updated, No. 6 Fuel Oil Only)	52	6

Mercury (Updated, Inside Continental U.S.)	44	5

Mercury (Updated, Outside Continental U.S.)	14	5



Total Metals + Mercury (Hg) and Total Metals Only

Table 6. Existing Total Metals + Mercury (Hg) MACT Floors for Oil-Fired
Units (Input Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Total Metals + Hg (Proposed, 3/16/11)	1.1024E-05	2.1337E-05	7	0.00003
lb/MMBtu

Total Metals + Hg (Updated)	1.0259E-05	2.4225E-05	5	0.00002	lb/MMBtu

Total Metals + Hg (Updated, No. 2 Fuel Oil Only)	1.4738E-05	6.1478E-05	4
0.00006	lb/MMBtu

Total Metals + Hg (Updated, No. 6 Fuel Oil Only)	2.8607E-05	9.9329E-05	5
0.0001	lb/MMBtu

Total Metals + Hg (Updated, Inside Continental U.S.)	8.8728E-06
1.7094E-05	4	0.00002	lb/MMBtu

Total Metals + Hg (Updated, Outside Continental U.S.)	6.5341E-04
1.2286E-03	5	0.00123	lb/MMBtu



Table 7. Existing Total Metals + Mercury (Hg) MACT Floors for Oil-Fired
Units (alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Total Metals + Hg (Proposed, 3/16/11)	1.3679E-04	2.8745E-04	7	0.0003
lb/MWh

Total Metals + Hg (Updated)	1.2695E-04	3.3597E-04	5	0.0003	lb/MWh

Total Metals + Hg (Updated, No. 2 Fuel Oil Only)	2.0620E-04	8.7628E-04	4
0.0009	lb/MWh

Total Metals + Hg (Updated, No. 6 Fuel Oil Only)	3.0014E-04	1.0779E-03	5
0.0011	lb/MWh

Total Metals + Hg (Updated, Inside Continental U.S.)	1.0481E-04
1.7459E-04	4	0.0002	lb/MWh

Total Metals + Hg (Updated, Outside Continental U.S.)	6.8071E-03
1.2518E-02	5	0.0125	lb/MWh

Table 8. New Total Metals + Mercury (Hg) MACT Floors for Oil-Fired
Units (Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Total Metals + Hg (Proposed, 3/16/11)	8.7795E-05	3.3172E-04	1	0.0003
lb/MWh

Total Metals + Hg (Updated)	8.7795E-05	3.3172E-04	1	0.00033	lb/MWh

Total Metals + Hg (Updated, No. 2 Fuel Oil Only)	1.0046E-04	2.6415E-04	1
0.00026	lb/MWh

Total Metals + Hg (Updated, No. 6 Fuel Oil Only)	8.7795E-05	3.3172E-04	1
0.00033	lb/MWh

Total Metals + Hg (Updated, Inside Continental U.S.)	8.7795E-05
3.3172E-04	1	0.00033	lb/MWh

Total Metals + Hg (Updated, Outside Continental U.S.)	5.0411E-03
6.2527E-03	1	0.00625	lb/MWh



Table 9. Number of Data Averages in Each Subcategory and Number of Units
in Each Total Metals Mercury (Hg) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Total Metals + Hg (Updated)	42 (all data)	5

Total Metals + Hg (Updated, No. 2 Fuel Oil Only)	4	4

Total Metals + Hg (Updated, No. 6 Fuel Oil Only)	38	5

Total Metals + Hg (Updated, Inside Continental U.S.)	35	4

Total Metals + Hg (Updated, Outside Continental U.S.)	7	5



Table 10. Existing Total Metals MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Total Metals (Proposed, 3/16/11)	1.0905E-05	2.1072E-05	7	0.00003
lb/MMBtu

Total Metals (Updated)	1.0148E-05	2.3899E-05	5	0.00002	lb/MMBtu

Total Metals (Updated, No. 2 Fuel Oil Only)	1.4559E-05	6.0841E-05	4
0.00006	lb/MMBtu

Total Metals (Updated, No. 6 Fuel Oil Only)	2.8547E-05	9.9293E-05	5
0.0001	lb/MMBtu

Total Metals (Updated, Inside Continental U.S.)	8.7881E-06	1.7044E-05	4
0.00002	lb/MMBtu

Total Metals (Updated, Outside Continental U.S.)	6.5338E-04	1.2285E-03	5
0.00123	lb/MMBtu



Table 11. Existing Total Metals MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Total Metals (Proposed, 3/16/11)	1.3527E-04	2.8348E-04	7	0.0003	lb/MWh

Total Metals (Updated)	1.2551E-04	3.3081E-04	5	0.0003	lb/MWh

Total Metals (Updated, No. 2 Fuel Oil Only)	2.0370E-04	8.6725E-04	4
0.0009	lb/MWh

Total Metals (Updated, No. 6 Fuel Oil Only)	2.9952E-04	1.0774E-03	5
0.0011	lb/MWh

Total Metals (Updated, Inside Continental U.S.)	1.0375E-04	1.7195E-04	4
0.0002	lb/MWh

Total Metals (Updated, Outside Continental U.S.)	6.8068E-03	1.2517E-02	5
0.0125	lb/MWh



Table 12. New Total Metals MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Total Metals (Proposed, 3/16/11)	8.7194E-05	3.3099E-04	1	0.0004	lb/MWh

Total Metals (Updated)	8.7194E-05	3.3099E-04	1	0.00033	lb/MWh

Total Metals (Updated, No. 2 Fuel Oil Only)	9.9204E-05	2.6671E-04	1
0.00027	lb/MWh

Total Metals (Updated, No. 6 Fuel Oil Only)	8.7194E-05	3.3099E-04	1
0.00033	lb/MWh

Total Metals (Updated, Inside Continental U.S.)	8.7194E-05	3.3099E-04	1
0.00033	lb/MWh

Total Metals (Updated, Outside Continental U.S.)	5.0408E-03	6.2521E-03	1
0.00625	lb/MWh



Table 13. Number of Data Averages in Each Subcategory and Number of
Units in Each Total Metals MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Total Metals (Updated)	42 (all data)	5

Total Metals (Updated, No. 2 Fuel Oil Only)	4	4

Total Metals (Updated, No. 6 Fuel Oil Only)	38	5

Total Metals (Updated, Inside Continental U.S.)	35	4

Total Metals (Updated, Outside Continental U.S.)	7	5



Non-Mercury Metals

Table 14. Existing Antimony (Sb) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Sb (Proposed, 3/16/11)	8.6708E-08	1.9652E-07	7	0.2	lb/TBtu

Sb (Updated)	8.6708E-08	1.9652E-07	7	0.20	lb/TBtu

Sb (Updated, No. 2 Fuel Oil Only)	7.8694E-08	2.2608E-07	5	0.23	lb/TBtu

Sb (Updated, No. 6 Fuel Oil Only)	4.3134E-07	1.2157E-06	6	1.22	lb/TBtu

Sb (Updated, Inside Continental U.S.)	7.5487E-08	2.0859E-07	5	0.21
lb/TBtu

Sb (Updated, Outside Continental U.S.)	5.9078E-07	1.3066E-06	5	1.31
lb/TBtu



Table 15. Existing Antimony (Sb) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Sb (Proposed, 3/16/11)	1.1052E-06	2.4682E-06	7	0.003	lb/GWh

Sb (Updated)	1.1052E-06	2.4682E-06	7	0.002	lb/GWh

Sb (Updated, No. 2 Fuel Oil Only)	1.0610E-06	2.9642E-06	5	0.003	lb/GWh

Sb (Updated, No. 6 Fuel Oil Only)	4.5100E-06	1.2627E-05	6	0.01	lb/GWh

Sb (Updated, Inside Continental U.S.)	9.7455E-07	2.6780E-06	5	0.003
lb/GWh

Sb (Updated, Outside Continental U.S.)	6.1239E-06	1.2681E-05	5	0.01
lb/GWh



Table 16. New Antimony (Sb) MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Sb (Proposed, 3/16/11)	3.1152E-07	1.0740E-06	1	0.002	lb/GWh

Sb (Updated)	3.0233E-07	1.0423E-06	1	0.001	lb/GWh

Sb (Updated, No. 2 Fuel Oil Only)	3.0233E-07	1.0423E-06	1	0.001	lb/GWh

Sb (Updated, No. 6 Fuel Oil Only)	9.9974E-07	6.5591E-06	1	0.01	lb/GWh

Sb (Updated, Inside Continental U.S.)	3.0233E-07	1.0423E-06	1	0.001
lb/GWh

Sb (Updated, Outside Continental U.S.)	4.6207E-06	7.7015E-06	1	0.01
lb/GWh



Table 17. Number of Data Averages in Each Subcategory and Number of
Units in Each Antimony (Sb) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Sb (Updated)	58 (all data)	7

Sb (Updated, No. 2 Fuel Oil Only)	6	5

Sb (Updated, No. 6 Fuel Oil Only)	52	6

Sb (Updated, Inside Continental U.S.)	43	5

Sb (Updated, Outside Continental U.S.)	15	5



Table 18. Existing Arsenic (As) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

As (Proposed, 3/16/11)	2.7023E-07	5.4091E-07	7	0.6	lb/TBtu

As (Updated)	2.7023E-07	5.4091E-07	7	0.54	lb/TBtu

As (Updated, No. 2 Fuel Oil Only)	6.0625E-07	2.4786E-06	5	2.48	lb/TBtu

As (Updated, No. 6 Fuel Oil Only)	3.8533E-07	1.1458E-06	6	1.15	lb/TBtu

As (Updated, Inside Continental U.S.)	2.3288E-07	4.7926E-07	5	0.48
lb/TBtu

As (Updated, Outside Continental U.S.)	2.8634E-06	3.9554E-06	5	3.96
lb/TBtu



Table 19. Existing Arsenic (As) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

As (Proposed, 3/16/11)	3.2301E-06	6.8826E-06	7	0.007	lb/GWh

As (Updated)	3.2301E-06	6.8826E-06	7	0.007	lb/GWh

As (Updated, No. 2 Fuel Oil Only)	7.7817E-06	3.0341E-05	5	0.03	lb/GWh

As (Updated, No. 6 Fuel Oil Only)	3.9555E-06	1.1480E-05	6	0.01	lb/GWh

As (Updated, Inside Continental U.S.)	2.7544E-06	6.1604E-06	5	0.006
lb/GWh

As (Updated, Outside Continental U.S.)	2.8726E-05	3.8322E-05	5	0.04
lb/GWh





Table 20. New Arsenic (As) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

As (Proposed, 3/16/11)	1.4986E-06	1.5529E-06	1	0.002	lb/GWh

As (Updated)	1.6590E-06	1.7190E-06	1	0.002	lb/GWh

As (Updated, No. 2 Fuel Oil Only)	3.1052E-06	1.2174E-05	1	0.01	lb/GWh

As (Updated, No. 6 Fuel Oil Only)	1.6590E-06	1.7190E-06	1	0.002	lb/GWh

As (Updated, Inside Continental U.S.)	1.6590E-06	1.7190E-06	1	0.002
lb/GWh

As (Updated, Outside Continental U.S.)	2.5646E-05	6.9465E-05	1	0.07
lb/GWh



Table 21. Number of Data Averages in Each Subcategory and Number of
Units in Each Arsenic (As) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

As (Updated)	59 (all data)	7

As (Updated, No. 2 Fuel Oil Only)	6	5

As (Updated, No. 6 Fuel Oil Only)	53	6

As (Updated, Inside Continental U.S.)	45	5

As (Updated, Outside Continental U.S.)	14	5





Table 22. Existing Beryllium (Be) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Be (Proposed, 3/16/11)	2.7199E-08	5.6981E-08	7	0.06	lb/TBtu

Be (Updated)	3.0197E-08	6.4029E-08	7	0.06	lb/TBtu

Be (Updated, No. 2 Fuel Oil Only)	2.8429E-08	7.3418E-08	5	0.07	lb/TBtu

Be (Updated, No. 6 Fuel Oil Only)	4.3308E-08	7.3545E-08	6	0.07	lb/TBtu

Be (Updated, Inside Continental U.S.)	2.5382E-08	5.4599E-08	5	0.05
lb/TBtu

Be (Updated, Outside Continental U.S.)	1.3391E-07	4.1480E-07	5	0.41
lb/TBtu



Table 23. Existing Beryllium (Be) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Be (Proposed, 3/16/11)	3.2934E-07	6.2782E-07	7	0.0007	lb/GWh

Be (Updated)	3.6186E-07	6.8646E-07	7	0.0007	lb/GWh

Be (Updated, No. 2 Fuel Oil Only)	3.8370E-07	9.3304E-07	5	0.001	lb/GWh

Be (Updated, No. 6 Fuel Oil Only)	4.5301E-07	7.9249E-07	6	0.001	lb/GWh

Be (Updated, Inside Continental U.S.)	3.1961E-07	6.4112E-07	5	0.001
lb/GWh

Be (Updated, Outside Continental U.S.)	1.3316E-06	3.8244E-06	5	0.004
lb/GWh

Table 24. New Beryllium (Be) MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Be (Proposed, 3/16/11)	2.2836E-07	6.7882E-07	1	0.0007	lb/GWh

Be (Updated)	2.2836E-07	6.7882E-07	1	0.0007	lb/GWh

Be (Updated, No. 2 Fuel Oil Only)	2.2836E-07	6.7882E-07	1	0.0007	lb/GWh

Be (Updated, No. 6 Fuel Oil Only)	2.8769E-07	8.5966E-07	1	0.001	lb/GWh

Be (Updated, Inside Continental U.S.)	2.2836E-07	6.7882E-07	1	0.0007
lb/GWh

Be (Updated, Outside Continental U.S.)	7.7019E-07	2.2522E-06	1	0.002
lb/GWh

 

Table 25. Number of Data Averages in Each Subcategory and Number of
Units in Each Beryllium (Be) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Be (Updated)	59 (all data)	7

Be (Updated, No. 2 Fuel Oil Only)	6	5

Be (Updated, No. 6 Fuel Oil Only)	53	6

Be (Updated, Inside Continental U.S.)	45	5

Be (Updated, Outside Continental U.S.)	14	5





Table 26. Existing Cadmium (Cd) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Cd (Proposed, 3/16/11)	4.3958E-08	9.2940E-08	7	0.1	lb/TBtu

Cd (Updated)	4.3958E-08	9.2940E-08	7	0.09	lb/TBtu

Cd (Updated, No. 2 Fuel Oil Only)	9.0057E-08	3.9523E-07	5	0.40	lb/TBtu

Cd (Updated, No. 6 Fuel Oil Only)	4.6710E-08	1.1054E-07	6	0.11	lb/TBtu

Cd (Updated, Inside Continental U.S.)	3.9378E-08	1.0123E-07	5	0.10
lb/TBtu

Cd (Updated, Outside Continental U.S.)	8.9237E-08	1.8774E-07	5	0.19
lb/TBtu



Table 27. Existing Cadmium (Cd) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Cd (Proposed, 3/16/11)	4.8715E-07	1.0240E-06	7	0.002	lb/GWh

Cd (Updated)	4.8534E-07	1.0167E-06	7	0.001	lb/GWh

Cd (Updated, No. 2 Fuel Oil Only)	1.2120E-06	5.4326E-06	5	0.005	lb/GWh

Cd (Updated, No. 6 Fuel Oil Only)	4.7749E-07	1.1018E-06	6	0.00	lb/GWh

Cd (Updated, Inside Continental U.S.)	4.3667E-07	1.1130E-06	5	0.001
lb/GWh

Cd (Updated, Outside Continental U.S.)	8.8216E-07	1.8769E-06	5	0.002
lb/GWh





Table 28. New Cadmium (Cd) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Cd (Proposed, 3/16/11)	1.2994E-07	3.8828E-07	1	0.0004	lb/GWh

Cd (Updated)	1.2994E-07	3.8828E-07	1	0.0004	lb/GWh

Cd (Updated, No. 2 Fuel Oil Only)	5.3245E-07	2.2762E-06	1	0.002	lb/GWh

Cd (Updated, No. 6 Fuel Oil Only)	1.2994E-07	3.8828E-07	1	0.0004	lb/GWh

Cd (Updated, Inside Continental U.S.)	1.2994E-07	3.8828E-07	1	0.0004
lb/GWh

Cd (Updated, Outside Continental U.S.)	6.0290E-07	1.0847E-06	1	0.001
lb/GWh



Table 29. Number of Data Averages in Each Subcategory and Number of
Units in Each Cadmium (Cd) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Cd (Updated)	60 (all data)	7

Cd (Updated, No. 2 Fuel Oil Only)	6	5

Cd (Updated, No. 6 Fuel Oil Only)	54	6

Cd (Updated, Inside Continental U.S.)	45	5

Cd (Updated, Outside Continental U.S.)	15	5



Table 30. Existing Cobalt (Co) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Co (Proposed, 3/16/11)	5.8610E-07	2.0215E-06	7	3	lb/TBtu

Co (Updated)	3.9971E-07	1.8317E-06	5	1.83	lb/TBtu

Co (Updated, No. 2 Fuel Oil Only)	2.0418E-06	1.9250E-05	5	19.25	lb/TBtu

Co (Updated, No. 6 Fuel Oil Only)	9.9346E-07	2.7461E-06	5	2.75	lb/TBtu

Co (Updated, Inside Continental U.S.)	2.5284E-07	9.4275E-07	4	0.94
lb/TBtu

Co (Updated, Outside Continental U.S.)	2.5696E-05	5.0270E-05	5	50.27
lb/TBtu

 

Table 31. Existing Cobalt (Co) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Co (Proposed, 3/16/11)	6.1582E-06	1.9352E-05	7	0.02	lb/GWh

Co (Updated)	4.4948E-06	1.8090E-05	5	0.018	lb/GWh

Co (Updated, No. 2 Fuel Oil Only)	2.9010E-05	2.7427E-04	5	0.274	lb/GWh

Co (Updated, No. 6 Fuel Oil Only)	9.6700E-06	2.5926E-05	5	0.03	lb/GWh

Co (Updated, Inside Continental U.S.)	3.1618E-06	1.1629E-05	4	0.012
lb/GWh

Co (Updated, Outside Continental U.S.)	2.7479E-04	5.0567E-04	5	0.51
lb/GWh



Table 32. New Cobalt (Co) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Co (Proposed, 3/16/11)	1.1416E-06	5.7337E-06	1	0.02	lb/GWh

Co (Updated)	1.1416E-06	5.7337E-06	1	0.006	lb/GWh

Co (Updated, No. 2 Fuel Oil Only)	1.1416E-06	5.7337E-06	1	0.006	lb/GWh

Co (Updated, No. 6 Fuel Oil Only)	3.4404E-06	2.0932E-05	1	0.021	lb/GWh

Co (Updated, Inside Continental U.S.)	1.1416E-06	5.7337E-06	1	0.006
lb/GWh

Co (Updated, Outside Continental U.S.)	1.9888E-04	2.5213E-04	1	0.25
lb/GWh



Table 33. Number of Data Averages in Each Subcategory and Number of
Units in Each Cobalt (Co) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Co (Updated)	44 (all data)	5

Co (Updated, No. 2 Fuel Oil Only)	4	5

Co (Updated, No. 6 Fuel Oil Only)	40	5

Co (Updated, Inside Continental U.S.)	37	4

Co (Updated, Outside Continental U.S.)	7	5





Table 34. Existing Chromium (Cr) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Cr (Proposed, 3/16/11)	7.8696E-07	1.5677E-06	7	2	lb/TBtu

Cr (Updated)	7.8696E-07	1.5677E-06	7	1.6	lb/TBtu

Cr (Updated, No. 2 Fuel Oil Only)	1.4164E-06	4.9444E-06	5	4.94	lb/TBtu

Cr (Updated, No. 6 Fuel Oil Only)	9.8380E-07	2.3867E-06	6	2.39	lb/TBtu

Cr (Updated, Inside Continental U.S.)	7.3324E-07	1.7877E-06	5	1.79
lb/TBtu

Cr (Updated, Outside Continental U.S.)	1.9744E-06	5.1772E-06	5	5.18
lb/TBtu



Table 35. Existing Chromium (Cr) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Cr (Proposed, 3/16/11)	8.9730E-06	1.8550E-05	7	0.02	lb/GWh

Cr (Updated)	8.9730E-06	1.8550E-05	7	0.019	lb/GWh

Cr (Updated, No. 2 Fuel Oil Only)	1.9224E-05	7.0424E-05	5	0.070	lb/GWh

Cr (Updated, No. 6 Fuel Oil Only)	1.1160E-05	3.1241E-05	6	0.03	lb/GWh

Cr (Updated, Inside Continental U.S.)	8.2181E-06	2.0241E-05	5	0.020
lb/GWh

Cr (Updated, Outside Continental U.S.)	2.0497E-05	5.1813E-05	5	0.05
lb/GWh





Table 36. New Chromium (Cr) MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Cr (Proposed, 3/16/11)	3.9709E-06	1.1692E-05	1	0.02	lb/GWh

Cr (Updated)	4.3637E-06	1.2849E-05	1	0.013	lb/GWh

Cr (Updated, No. 2 Fuel Oil Only)	6.8809E-06	3.6806E-05	1	0.037	lb/GWh

Cr (Updated, No. 6 Fuel Oil Only)	4.3637E-06	1.2849E-05	1	0.013	lb/GWh

Cr (Updated, Inside Continental U.S.)	4.3637E-06	1.2849E-05	1	0.013
lb/GWh

Cr (Updated, Outside Continental U.S.)	9.3654E-06	1.2084E-05	1	0.012
lb/GWh



Table 37. Number of Data Averages in Each Subcategory and Number of
Units in Each Chromium (Cr) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Cr (Updated)	60 (all data)	7

Cr (Updated, No. 2 Fuel Oil Only)	6	5

Cr (Updated, No. 6 Fuel Oil Only)	54	6

Cr (Updated, Inside Continental U.S.)	45	5

Cr (Updated, Outside Continental U.S.)	15	5



Table 38. Existing Lead (Pb) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Pb (Proposed, 3/16/11)	6.4748E-07	1.9103E-06	7	2	lb/TBtu

Pb (Updated)	6.4748E-07	1.9103E-06	7	1.91	lb/TBtu

Pb (Updated, No. 2 Fuel Oil Only)	3.6861E-06	1.5931E-05	5	15.93	lb/TBtu

Pb (Updated, No. 6 Fuel Oil Only)	7.5350E-07	2.4657E-06	6	2.47	lb/TBtu

Pb (Updated, Inside Continental U.S.)	5.6323E-07	2.2959E-06	5	2.30
lb/TBtu

Pb (Updated, Outside Continental U.S.)	1.2505E-06	2.9406E-06	5	2.94
lb/TBtu



Table 39. Existing Lead (Pb) MACT Floors for Oil-Fired Units (alternate
Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Pb (Proposed, 3/16/11)	7.2271E-06	2.0418E-05	7	0.03	lb/GWh

Pb (Updated)	7.2271E-06	2.0418E-05	7	0.02	lb/GWh

Pb (Updated, No. 2 Fuel Oil Only)	4.9808E-05	2.1064E-04	5	0.211	lb/GWh

Pb (Updated, No. 6 Fuel Oil Only)	7.8624E-06	2.6019E-05	6	0.026	lb/GWh

Pb (Updated, Inside Continental U.S.)	6.4819E-06	2.4811E-05	5	0.025
lb/GWh

Pb (Updated, Outside Continental U.S.)	1.2794E-05	2.8317E-05	5	0.03
lb/GWh





Table 40. New Lead (Pb) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Pb (Proposed, 3/16/11)	1.2618E-06	5.3277E-06	1	0.006	lb/GWh

Pb (Updated)	1.3867E-06	5.8548E-06	1	0.006	lb/GWh

Pb (Updated, No. 2 Fuel Oil Only)	7.4773E-06	2.2520E-05	1	0.023	lb/GWh

Pb (Updated, No. 6 Fuel Oil Only)	1.3867E-06	5.8548E-06	1	0.006	lb/GWh

Pb (Updated, Inside Continental U.S.)	1.3867E-06	5.8548E-06	1	0.006
lb/GWh

Pb (Updated, Outside Continental U.S.)	7.8624E-06	2.3734E-05	1	0.024
lb/GWh



Table 41. Number of Data Averages in Each Subcategory and Number of
Units in Each Lead (Pb) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Pb (Updated)	60 (all data)	7

Pb (Updated, No. 2 Fuel Oil Only)	6	5

Pb (Updated, No. 6 Fuel Oil Only)	54	6

Pb (Updated, Inside Continental U.S.)	45	5

Pb (Updated, Outside Continental U.S.)	15	5





Table 42. Existing Manganese (Mn) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Mn (Proposed, 3/16/11)	1.4568E-06	4.3093E-06	7	5	lb/TBtu

Mn (Updated)	1.4568E-06	4.3093E-06	7	4.31	lb/TBtu

Mn (Updated, No. 2 Fuel Oil Only)	1.7673E-06	5.0708E-06	5	5.07	lb/TBtu

Mn (Updated, No. 6 Fuel Oil Only)	3.7452E-06	1.2719E-05	6	12.72	lb/TBtu

Mn (Updated, Inside Continental U.S.)	1.0346E-06	2.8039E-06	5	2.80
lb/TBtu

Mn (Updated, Outside Continental U.S.)	9.4323E-06	1.9942E-05	5	19.94
lb/TBtu



Table 43. Existing Manganese (Mn) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Mn (Proposed, 3/16/11)	1.8763E-05	5.9894E-05	7	0.06	lb/GWh

Mn (Updated)	1.8763E-05	5.9894E-05	7	0.06	lb/GWh

Mn (Updated, No. 2 Fuel Oil Only)	2.3512E-05	6.9395E-05	5	0.07	lb/GWh

Mn (Updated, No. 6 Fuel Oil Only)	3.8913E-05	1.3287E-04	6	0.13	lb/GWh

Mn (Updated, Inside Continental U.S.)	1.2565E-05	3.6932E-05	5	0.04
lb/GWh

Mn (Updated, Outside Continental U.S.)	9.8582E-05	2.1457E-04	5	0.21
lb/GWh





Table 44. New Manganese (Mn) MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Mn (Proposed, 3/16/11)	4.8608E-06	2.4490E-05	1	0.03	lb/GWh

Mn (Updated)	5.3417E-06	2.6912E-05	1	0.03	lb/GWh

Mn (Updated, No. 2 Fuel Oil Only)	1.1962E-05	4.5895E-05	1	0.05	lb/GWh

Mn (Updated, No. 6 Fuel Oil Only)	5.3417E-06	2.6912E-05	1	0.03	lb/GWh

Mn (Updated, Inside Continental U.S.)	5.3417E-06	2.6912E-05	1	0.03
lb/GWh

Mn (Updated, Outside Continental U.S.)	6.7081E-05	9.3682E-05	1	0.09
lb/GWh



Table 45. Number of Data Averages in Each Subcategory and Number of
Units in Each Manganese (Mn) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Mn (Updated)	59 (all data)	7

Mn (Updated, No. 2 Fuel Oil Only)	6	5

Mn (Updated, No. 6 Fuel Oil Only)	53	6

Mn (Updated, Inside Continental U.S.)	44	5

Mn (Updated, Outside Continental U.S.)	15	5





Table 46. Existing Nickel (Ni) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Nickel (Proposed, 3/16/11)	2.3887E-06	7.2536E-06	7	8.00	lb/TBtu

Nickel (Updated)	2.3887E-06	7.2536E-06	7	7.25	lb/TBtu

Nickel (Updated, No. 2 Fuel Oil Only)	1.7195E-06	5.5413E-06	5	5.54
lb/TBtu

Nickel (Updated, No. 6 Fuel Oil Only)	1.5940E-05	5.0079E-05	6	50.08
lb/TBtu

Nickel (Updated, Inside Continental U.S.)	1.7195E-06	5.5413E-06	5	5.54
lb/TBtu

Nickel (Updated, Outside Continental U.S.)	4.2402E-04	5.2232E-04	5
522.32	lb/TBtu



Table 47. Existing Nickel (Ni) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Nickel (Proposed, 3/16/11)	2.8419E-05	7.8157E-05	7	0.08	lb/GWh

Nickel (Updated)	2.8419E-05	7.8157E-05	7	0.078	lb/GWh

Nickel (Updated, No. 2 Fuel Oil Only)	2.3335E-05	7.8849E-05	5	0.079
lb/GWh

Nickel (Updated, No. 6 Fuel Oil Only)	1.6172E-04	5.1256E-04	6	0.51
lb/GWh

Nickel (Updated, Inside Continental U.S.)	2.1876E-05	6.8953E-05	5	0.069
lb/GWh

Nickel (Updated, Outside Continental U.S.)	4.0618E-03	6.1361E-03	5	6.14
lb/GWh





Table 48. New Nickel (Ni) MACT Floors for Oil-Fired Units (Output-Based
Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Nickel (Proposed, 3/16/11)	1.1470E-05	3.7526E-05	1	0.04	lb/GWh

Nickel (Updated)	1.1132E-05	3.6419E-05	1	0.04	lb/GWh

Nickel (Updated, No. 2 Fuel Oil Only)	1.1132E-05	3.6419E-05	1	0.04
lb/GWh

Nickel (Updated, No. 6 Fuel Oil Only)	3.3038E-05	2.0944E-04	1	0.21
lb/GWh

Nickel (Updated, Inside Continental U.S.)	1.1132E-05	3.6419E-05	1	0.04
lb/GWh

Nickel (Updated, Outside Continental U.S.)	3.5205E-03	7.4115E-03	1	7.4
lb/GWh



Table 49. Number of Data Averages in Each Subcategory and Number of
Units in Each Nickel (Ni) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Nickel (Updated)	60 (all data)	7

Nickel (Updated, No. 2 Fuel Oil Only)	6	5

Nickel (Updated, No. 6 Fuel Oil Only)	54	6

Nickel (Updated, Inside Continental U.S.)	45	5

Nickel (Updated, Outside Continental U.S.)	15	5

Table 50. Existing Selenium (Se) MACT Floors for Oil-Fired Units (Input
Based Standard)

Pollutant	Mean (lb/MMBtu)	UPL (lb/MMBtu)	Number of sources in the floor
Floor value	Units

Se (Proposed, 3/16/11)	5.0320E-07	1.0922E-06	7	2	lb/TBtu

Se (Updated)	5.0320E-07	1.0922E-06	7	1.09	lb/TBtu

Se (Updated, No. 2 Fuel Oil Only)	5.1970E-07	1.3698E-06	5	1.37	lb/TBtu

Se (Updated, No. 6 Fuel Oil Only)	7.1192E-07	1.4734E-06	6	1.47	lb/TBtu

Se (Updated, Inside Continental U.S.)	4.3962E-07	1.1212E-06	5	1.12
lb/TBtu

Se (Updated, Outside Continental U.S.)	1.1564E-06	2.1122E-06	5	2.11
lb/TBtu



Table 51. Existing Selenium (Se) MACT Floors for Oil-Fired Units
(alternate Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Se (Proposed, 3/16/11)	6.1244E-06	1.3004E-05	7	0.02	lb/GWh

Se (Updated)	6.1244E-06	1.3004E-05	7	0.013	lb/GWh

Se (Updated, No. 2 Fuel Oil Only)	6.8780E-06	1.7632E-05	5	0.018	lb/GWh

Se (Updated, No. 6 Fuel Oil Only)	7.5148E-06	1.4973E-05	6	0.015	lb/GWh

Se (Updated, Inside Continental U.S.)	5.4858E-06	1.4199E-05	5	0.014
lb/GWh

Se (Updated, Outside Continental U.S.)	1.1661E-05	2.0950E-05	5	0.021
lb/GWh





Table 52. New Selenium (Se) MACT Floors for Oil-Fired Units
(Output-Based Standard)

Pollutant	Mean (lb/MW)	UPL (lb/MW)	Number of sources in the floor	Floor
value	Units

Se (Proposed, 3/16/11)	2.5693E-06	3.8753E-06	1	0.004	lb/GWh

Se (Updated)	2.5693E-06	3.8753E-06	1	0.004	lb/GWh

Se (Updated, No. 2 Fuel Oil Only)	2.5693E-06	3.8753E-06	1	0.004	lb/GWh

Se (Updated, No. 6 Fuel Oil Only)	4.0341E-06	1.4859E-05	1	0.015	lb/GWh

Se (Updated, Inside Continental U.S.)	2.5693E-06	3.8753E-06	1	0.004
lb/GWh

Se (Updated, Outside Continental U.S.)	7.6945E-06	1.7693E-05	1	0.018
lb/GWh



Table 53. Number of Data Averages in Each Subcategory and Number of
Units in Each Selenium (Se) MACT Floor for Oil-Fired Units Floor

Pollutant	Number of sources in subcategory	Number of sources in the
floor

Se (Updated)	60 (all data)	7

Se (Updated, No. 2 Fuel Oil Only)	6	5

Se (Updated, No. 6 Fuel Oil Only)	54	6

Se (Updated, Inside Continental U.S.)	45	5

Se (Updated, Outside Continental U.S.)	15	5





Appendix A

Discussion on Fate of Mercury 

During Distillation of Crude Oil



With regard to crude oil sources in the world-wide market and the
variability of mercury content in grades of fuel oil, Wilhelm states the
fate of mercury during distillation of crude oil depends on several
factors:

“…Crude oil contains both dissolved and suspended mercury compounds.
A typical analysis for total mercury in crude oil yields the sum of both
forms, but the suspended amount is not necessarily reflective of the
reservoir concentration. The sampling and analytical protocols for
differentiation of the various forms of mercury in hydrocarbon liquids
have been only recently applied, but the variations seen in THg [total
mercury] from particular fields are due more to variation in the
suspended fraction as opposed to the truly dissolved fraction.

For example, order of magnitude differences in total mercury
concentration can be obtained for the same crude oil between samples
taken upstream and downstream of separators and desalters. Crude oil
sampled from tankers typically comes from the top of the tank where
suspended forms can be lower in concentration due to settling in
transit”.

Wilhelm also states that “[t]he fates of dissolved and suspended forms
of mercury in the refining process … are different. The suspended
forms (mostly HgS) are nonvolatile and tend to remain in the residuum in
the primary and vacuum distillations. Dissolved forms (mostly Hg0) are
volatile and are more likely to transfer to lighter products. Organic
forms, if present, may be converted to Hg0 by hydrotreating.”

  Accounting for <10 percent of the total heat content of the blended
fuel mixture.

  Accounting for >10 percent of the total heat content of the blended
fuel mixture.

  As noted in the memorandum’s text, this use of used motor oil for
fuel was deemed by the EPA to be incomparable with other oil-fired EGUs
in these MACT Floor analyses. 

 The data set only contains 42 data averages (see Table 9); therefore,
the proposed Total Metals + Hg MACT floor for existing oil-fired units
should have only included five emission averages instead of just seven. 

 The data set only contains 42 data averages (see Table 9); therefore,
the proposed Total Metals + Hg MACT floor for existing oil-fired units
should have only included five emission averages instead of just seven. 

 The data set only contains 42 data averages (see Table 13); therefore,
the proposed Total Metals + Hg MACT floor for existing oil-fired units
should have only included five emission averages instead of just seven. 

 The data set only contains 42 data averages (see Table 13); therefore,
the proposed Total Metals + Hg MACT floor for existing oil-fired units
should have only included five emission averages instead of just seven. 

 The data set only contains 44 data averages (see Table 33); therefore,
the proposed cobalt MACT floor for existing oil-fired units should have
only included five emission averages instead of just seven. 

 The data set only contains 44 data averages (see Table 33); therefore,
the proposed cobalt MACT floor for existing oil-fired units should have
only included five emission averages instead of just seven. 

 S. Mark Wilhelm, Estimate of Mercury Emissions to the Atmosphere from
Petroleum. Environmental Science and Technology, Vol. 35, No. 24, 2001.
American Chemical Society.

  PAGE   \* MERGEFORMAT  40 

  PAGE   \* MERGEFORMAT  1 

Table 1. Fuel Used During MACT Floor Performance Tests for Oil-fired
Sources (cont’d)

  PAGE   \* MERGEFORMAT  39 

