United States
Environmental Protection
Agency
Office of Air Quality
Planning and Standards
Research Triangle Perk NC 27711
EPA-450/3-86-003
October 1986
Air
Fossil and
Nonfossil
Fuel-Fired
Industrial
Boilers —
Background
Information for
Promulgated
PM and  NOx
Standards
Volume  3
             Final
             EIS

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                                   EPA-450/3-86-003
    Fossil and  Nonfossil Fuel-Fired
           Industrial Boilers —
      Background Information for
Promulgated PM and NOx Standards

                 Volume 3

            Emission Standards and Engineering Division
                               U.S. Environmental Protection
                               Region V, Library
                               230 South Dearborn Street
                               Chicago, Illinois 60604 X*
            U.S. ENVIRONMENTAL PROTECTION AGENCY
                 Office of Air and Radiation
            Office of Air Quality Planning and Standards
               Research Triangle Park, NC 27711

                    October 1986

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This report has been reviewed by the Emission Standards and Engineering Division of the Office of Air Quality
Planning and Standards, EPA, and approved for publication. Mention of trade names or commercial products is
not intended to constitute endorsement or recommendation for use. Copies of this report are available through
the Library Services Office (MD-35), U.S.  Environmental  Protection Agency, Research Triangle Park, North
Carolina 27711; or, for a fee, from the National Technical Information Services, 5285 Port Royal Road,
Springfield, Virginia 22161.

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                                            EPA-450/3-86-003
       FOSSIL AND NONFOSSIL FUEL-FIRED

            INDUSTRIAL BOILERS -

         BACKGROUND INFORMATION FOR

      PROMULGATED PM AND N0x STANDARDS

                  VOLUME 3
 Emission Standards and Engineering Division
    U.S. Environmental Protection Agency
         Office of Air and Radiation
Office of Air Quality Planning and Standards
Research Triangle Park, North Carolina  27711
                 April  1986

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                              TABLE OF CONTENTS
1.0  SUMMARY	   1

     1.1  SUMMARY OF IMPACTS OF PROMULGATED ACTION	   1

          1.1.1  Alternatives to Promulgated Action	   2
          1.1.2  Environmental  Impacts of the Promulgated Action	   2
          1.1.3  Energy and Economic Impacts of the Promulgated
                 Action	   5
          1.1.4  Other Considerations	   7

2.0  SUMMARY OF PUBLIC COMMENTS	   9

     2.1  APPLICABILITY OF THE  STANDARD	  20

          2.1.1  General	  20
          2.1.2  Process  Units	  22
          2.1.3  Mixed Fuel-Fired Units	  24
          2.1.4  Fuel Definitions/Exclusions	  25
          2.1.5  Size Cutoff	  28

     2.2  SELECTION/PERFORMANCE OF DEMONSTRATED NO  CONTROL
          TECHNOLOGY	.'	  29

          2.2.1  General	  29
          2.2.2  Coal-Fired Steam Generating Units	  34
          2.2.3  Gas-/Oil-Fired Steam Generating Units	  36
          2.2.4  Other Steam Generating Units	  38

     2.3  STRINGENCY OF THE NO  EMISSIONS LIMITS	  40
                              A
          2.3.1  Gas-/Distillate Oil-Fired Steam Generating Units	  40
          2.3.2  Residual  Oil-Fired Steam Generating Units	  41
          2.3.3  Mass Feed Coal-Fired Steam Generating Units	  42
          2.3.4  Spreader Stoker Coal-Fired Steam Generating Units	  43
          2.3.5  Pulverized Coal-Fired Steam Generating Units	  44
          2.3.6  Multiple Fuel  Units	  44
          2.3.7  Combined Cycle Systems	  46

     2.4  SELECTION/PERFORMANCE OF DEMONSTRATED PARTICULATE MATTER
          CONTROL TECHNOLOGY	  46

     2.5  STRINGENCY OF THE PARTICULATE MATTER EMISSION LIMITS	  49

     2.6  COSTS/COST EFFECTIVENESS OF THE PROPOSED STANDARDS	  52

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                   TABLE OF CONTENTS (CONTINUED)


                                                                 Page

2.7  MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS	'.  57

     2.7.1  Continuous NO  Emission Monitoring Systems	  57
     2.7.2  Opacity	  60
     2.7.3  Data Collection	  63
     2.7.4  Reporting Requirements	  64
     2.7.5  Exemptions	  65
     2.7.6  Enforcement/Permitting	  66

2.8  EMISSION CREDITS FOR COMBINED CYCLE SYSTEMS	  67

2.9  ENERGY, ENVIRONMENTAL, AND ECONOMIC IMPACTS	  68

     2.9.1  Energy Impacts	  68
     2.9.2  Environmental Impacts	  69
     2.9.3  Economic Impacts	  71

2.10  MISCELLANEOUS COMMENTS	  71

2.11  NO  EMISSION LIMITS FOR WOOD RESIDUE AND NATURAL
      GAS-FIRED UNITS	  74

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                                1.0  SUMMARY







     On June 19, 1984, the Environmental  Protection Agency (EPA) proposed



standards of performance limiting emissions of particulate matter and



nitrogen oxides (NO )  from industrial-commercial-institutional steam
                   /\


generating units with  heat input capacities greater than 29 MW (100 million



Btu/hour) (49 FR 25102; Subpart Db) under authority of Section 111 of the



Clean Air Act.  Public comments were requested on the proposal in the



Federal Register.  There were 62 commenters, composed mainly of industries,



trade associations, and State and local regulatory agencies.  Also



commenting were environmental groups and one U.S. Government agency.  The



comments that were submitted to the docket (A-79-02) are summarized in this



document.  Revisions were made to the proposed regulations in response to



these comments.  A description of these revisions and the rationale for the



final actions taken by the Administrator are presented in the preamble to



the promulgated regulations.



     On December 2, 1985, EPA proposed an amendment to the standards of



performance for fossil fuel-fired steam generating units (Subpart D) that



would revise the NO  emission limit for units firing mixtures of natural gas
                   /\


and wood (50 FR 49422).  Public comments were requested in the Federal



Register.  There were three commenters, composed of trade associations and



one industry.  The comments that were submitted are also included in



Docket A-79-02 and are summarized in this document.

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1.1  SUMMARY OF IMPACTS OF PROMULGATED ACTION



1.1.1  Alternatives to Promulgated Action



     Regulatory alternatives considered during the development of the.



proposed standards are discussed in Chapter 6 of "Fossil  Fuel-Fired



Industrial Boilers - Background Information Document for  Proposed Standards"



(EPA-450/3-82-006), referred to as the background information  document



(BID).  These regulatory alternatives reflected different levels of emission



control.  After proposal, the Agency reviewed the public  comments and



consequently revised the emission limits for particulate  matter and NO .
                                                                      /\


The Agency has recalculated the environmental, energy, and economic impacts



of the final standards, as discussed below.



1.1.2  Environmental Impacts of the Promulgated Action



     The environmental impacts of the proposed regulation were presented in



the preamble to the proposed standards (49 FR 25102, June 19,  1984) and in



Chapter 10 of the BID.  Additional background on the environmental impacts



of the proposed standards can be found in the docket in two documents



entitled "Regulatory Analysis of Recommended Particulate  Matter New Source



Performance Standard for Industrial Fossil Fuel-Fired Boilers" and



"Documentation of National Impacts for Industrial-Commercial-Institutional



Steam Generating Units."  The environmental impacts of the final regulation



are presented in two additional documents, which are contained in the



docket.  These two documents are "Projected Environmental, Cost and Energy



Impacts of Alternative NSPS for Industrial Fossil Fuel-Fired Boilers" and



"National NO  Impacts."  The analysis of environmental impacts presented in
            /\

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these documents, as modified by the changes described below, is the final



environmental impact statement for this action.



     It is projected that 725 new industrial-commercial-institutional .steam



generating units subject to 40 CFR Part 60 Subpart Db will  be constructed  in



the 5 years following the promulgation.  The environmental  impacts of



reducing particulate matter and NO  emissions from these steam generating
                                  X


units are expressed as incremental differences in emissions between the



current emission regulations (referenced to as baseline) and the promulgated



regulations.



     The impacts of the new source performance standards (NSPS) for



particulate matter and NO  emissions are stated as a range  of emission
                         J\


reductions.  This range stems from the different regulatory requirements ,



which can be assumed to apply to new units subject to these standards.  The



lower estimate of emission reductions is based on the incremental  change



between the baseline regulations (State implementation plans and Subpart D



new source performance standards) and the particulate matter and NO
                                                                   /\


emission limits in the promulgated standards.  The upper estimate is based



on the incremental change between the baseline regulations  and the



particulate matter and NO  standards combined with the recently proposed new
                         X


source performance standards for S02 (51 FR 22384), which would also apply



to this category of steam generating units.  The proposed SOp standards are



expected to increase the number of natural gas-fired steam  generating  units



subject to the standard from approximately 30 percent of the total number  of



steam generating units subject to the standards to approximately 55 percent.



Because natural gas combustion results in lower particulate matter and NO

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emissions than either coal  or oil  combustion,  increased particulate matter



and NO  emissions control result with S07 standards in place.
      A                                 C~


     Baseline emissions of particulate matter  from new industrial-



commercial-institutional  steam generating units are projected  to be



approximately 49,000 Mg (54,000 tons) per year in 1990. Under  the



promulgated standard, particulate matter emissions rates are projected to



decrease from those baseline levels by about 16,000 to 22,000  Mg (18,000 to



24,000 tons) per year.  Baseline emissions of  NO  from new industrial-
                                                A


commercial-institutional  steam generating units are projected  to be



approximately 77,000 Mg (85,000 tons) of NO  per year in 1990.  Under the
                                           A


promulgated standard, NO  emission rates are expected to decrease from those
                        A


baseline levels by about 21,000 to 24,000 Mg (23,000 to 26,000 tons) per



year.  These emission reductions represent about a 35 to 45 percent



reduction in the growth of particulate matter  emissions and about a 25 to 30



percent reduction in NO  emissions from new steam generating units subject
                       A


to the standards.



     The solid and liquid waste impacts associated with the promulgated



standards are minimal.  The NO  standards are  based on the use of combustion
                              A


modification techniques to control NO  emissions, and these techniques do
                                     /\


not result  in the production of either solid or liquid wastes.  Flyash



disposal levels associated with existing State regulations and Subpart D new



source performance standards are only incrementally increased as a result of



the particulate matter standards adopted today.  Further, the change in fuel



use patterns resulting from the particulate matter and NO  standards, or
                                                         X


from the combined particulate matter, NO  , and S09 standards, can actually
                                        X        c.

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reduce flyash levels.  Overall, the standards are projected to result in
solid waste impacts ranging from a net reduction of about 9,000 Mg/year
(10,000 tons/year) to a net increase of 13,000 Mg/year (14,000 tons/year).
The liquid waste impacts of the promulgated standards are minimal and are
primarily the result of the projected use of wet scrubbing systems for the
control of particulate matter emissions from wood-fired steam generating
units. Under these regulations, liquid waste production levels would
increase from baseline by approximately 19,000 m  (680,000 ft ), or
approximately 1.5 percent.
1.1.3  Energy and Economic Impacts of the Promulgated Action
     The energy impacts of the proposed regulations were presented in the
preamble to the proposed standards (49 FR 25102, June 19, 1984) and in
Chapter 10 of the BID.  Additional background on the energy impacts of the
promulgated standards can be found in the four documents on the
environmental impacts of the standards identified above.
     Steam generating units that are projected to be affected by the
standards are expected to demand approximately 525 million GJ (498 trillion
Btu) of fossil fuels in 1990.  It is projected that natural gas will provide
approximately 30 to 50 percent of the heat input to these steam generating
units, and that residual oil will provide most of the remaining steam
generating unit fuel.  Coal use is projected to be limited to large units
with relatively high annual capacity factors.
     The use of electrostatic precipitators (ESP's) and fabric filters to
comply with the particulate matter standards is expected to increase the
national electric energy requirements for new steam generating units by

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about 146 GWh/year in 1990.  This increased electrical  energy requirement



could be met by combusting an additional  524,000 GJ (497 billion Btu/year)



of fossil fuel in an electric utility steam generating  plant, or less-than a



1 percent increase in the overall annual  fuel consumption by new industrial-



commercial-institutional steam generating units.  The use of low excess air



(LEA) for NO  control will result in fuel savings which will partially
            X


offset this increased fuel use.



     The economic impacts of the proposed standards were presented in the



preamble to the proposed standard (49 FR 25102, June 19, 1984) and in



Chapter 9 of the BID. The economic impacts of the proposed standards, in



terms of increases in product prices or the availability of capital to the



firms purchasing steam generating units, are not expected to change



significantly from the impacts identified for the proposed standards.



Additional information on the economic impacts of the promulgated standards



can be found in the docket in the four documents  described above in the



section on environmental impacts.



     The projected capital and annual costs associated with the promulgated



standards vary depending on the regulatory requirements which are assumed to



apply to new steam generating units.  The addition of the proposed S02



standards to the promulgated particulate matter and NO  standards will
                                                      /\


result in a slight increase in the cost of NO  controls.  Since reductions
                                             X


in particulate matter emissions are achieved as an incidental effect of S02



control under the proposed S02 regulation, the total costs of that proposed



standard are attributable  to S02 control alone and are discussed in the



preamble to those proposed regulations (51 FR 22384).

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     The promulgated standards are projected to increase the capital costs



of new steam generating units by less than 1 percent over the baseline



capital costs.  Nationwide annual  costs for new industrial-commercialr



institutional steam generating units will  be approximately $36 million in



1990, or an increase of less than 1 percent over baseline annualized costs.



The national average cost effectiveness of the particulate matter standard



is projected to range from approximately $1,025 to $l,400/Mg ($930 to



$l,270/ton) of particulate matter removed.  The national average cost



effectiveness of the NO  standards is projected to range from $370 to
                       /\


$640/Mg ($340 to $580/ton) of NO  removed.
                                X


1.1.4  Other Considerations



     1.1.4.1  Irreversible and Irretrievable Commitment of Resources.  The



long-term gains and losses in environmental resources expected to result



from the proposed regulation are discussed in Chapter 7 of the BID.  These



gains and losses are not expected to change under the promulgated standards



Other than the fuels required for power generation and the materials



required for the construction of the control systems, there is no apparent



irreversible or irretrievable commitment of resources associated with this



regulation.



     1.1.4.2  Environmental and Energy Impacts of Delayed Standards.  The



environmental and energy impacts of delay in the promulgation of the



proposed standards are discussed in Chapter 7 of the BID.  The results of



delay in the standards are that new industrial-commercial-institutional



steam generating units would be built which may not meet the emission



limitations established by these standards.  This would delay the ambient

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air quality benefits, and other environmental  benefits associated with this



NSPS.  Further, potential improvements in energy efficiency resulting from



the adoption of LEA for NO  control  would also be postponed.
                          X


     1.1.4.3  Urban and Community Impacts.   Neither plant closures nor



impacts on small businesses are forecast.  No  significant adverse impacts on



urban areas or local communities are anticipated as the result of the



promulgation of these standards.

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                       2.0  SUMMARY OF PUBLIC COMMENTS








     A total  of 58 letters commenting on the proposed standards for control



of emissions  of participate matter and NO  from new industrial-commercial -

                                         x                         *


institutional steam generating units were received.  Comments were provided



by industry representatives, governmental entities, and environmental



groups.  These comments have been recorded and placed in the docket for this



rulemaking (Docket Number A-79-02, Category IV).  Table 2-1 presents a



listing of all persons submitting written comments, their affiliation  and  .



address, and  the recorded Docket Item Number assigned to each comment.



     Also, a  total of three letters were received commenting on the



correction to the proposed rule.  This correction proposed to revise the NO
                                                                           /\


emission limit for wood residue and natural gas-fired steam generating



units.  Table 2-2 presents a listing of all persons submitting written



comments, their affiliation and address, and the recorded Docket Item Number



assigned to each comment.



     The comments summarized in this chapter have been organized into the




following categories:



     2.1    Applicability of the Standard



     2.2    Selection/Performance of Demonstrated NO  Control Technology
                                                    /\


     2.3    Stringency of the Proposed NO  Emission Limits
                                         A


     2.4    Selection/Performance of Demonstrated Particulate Matter Control



            Technology



     2.5    Stringency of the Proposed Particulate Matter Emission Limits

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        TABLE 2-1.   LIST OF COMMENTERS ON THE PROPOSED STANDARDS FOR

            PARTICULATE MATTER AND NITROGEN OXIDES EMISSIONS FROM

         INDUSTRIAL-COMMERCIAL-INSTITUTIONAL STEAM GENERATING UNITS
Commenter

Jan B. Vlcek
James P. Rathvon
Sutherland, Asbill  & Brennan
1666 K Street, N.W.
Washington, D. C.  20006

C. H. Fancy, P.E.,  Deputy Chief
Bureau of Air Quality Management
State of Florida
Department of Environmental Regulation
Twin Towers Office Building.
2600 Blair Stone Road
Tallahassee, Florida  32301

James K. Hambright, Director
Bureau of Air Quality Control
Commonwealth of Pennsylvania
Department of Environmental Resources
P. 0. Box 2063
Harrisburg, Pennsylvania  17120

Kennard F. Kosky, P.E., Vice President
Environmental Science and Engineering, Inc.
P. 0. Box ESE
Gainesville, Florida  32602

Harold  E. Hodges, P.E.
Technical Secretary
Tennessee Air Pollution Control Board
Tennessee Department of Health and Environment
T.E.R.R.A. Building
150  Ninth Avenue, North
Nashville, Tennessee  37203

Bruce Blanchard, Director
Environmental Project Review
United  States Department of  the Interior
Office  of the Secretary
Washington, D.  C.  20240
 Docket
Reference

 IV-D-1
  D-2
  D-3
  D-4
  D-5
  D-6
                                       10

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                                                                  Docket
Commenter                                                        Reference

W. T. Danker, Manager                                              D-7
Environmental Programs
Chevron U.S.A., Inc.
P. 0. Box 7643
San Francisco, California  94120

Charles P. Blahous, J.D., Vice President                           D-8
Environmental Health and Safety
PPG Industries, Inc.
One PPG Place
Pittsburgh, Pennsylvania  15272

Walter Roy Quanstrom, General Manager                              D-9
Standard Oil Company (Indiana)
200 East Randolph Drive
Chicago, Illinois  60601

E. William Brownell                                                D-10
Hunton & Williams
P. 0. Box 9230
Washington, D.C.  20036

John L. Festa, Ph.D.                                               D-ll
Director, Chemical Control Programs
National Forest Products Association/
  American Paper Institute
1619 Massachusetts Avenue, N.W.
Washington, D.C.  20036

Harry H. Hovey, Jr., P.E., Director                                D-12
Division of Air
New York State Department
  of Environmental Conservation
50 Wolf Road
Albany, New York  12233

John E. Pinkerton                                                  D-13
Air Quality Program Manager
National Council of the Paper Industry
  for Air and Stream Improvement, Inc.
260 Madison Avenue
New York, New York  10016

James P. Rathvon                                                   D-14
Sutherland, Asbill & Brennan
1666 K Street, N.W.
Washington, D. C.  20006
                                      11

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                                                                  Pocket
Commenter                                                        Reference

Hugh B. Barton                                                     D-15
Regulatory Affairs Manager
Production Department
Exxon Company, U.S.A.
P. 0. Box 2180
Houston, Texas  77001

A. 6. Smith, Manager                                               D-16
Environmental Affairs
Shell Oil Company
One Shell Plaza
P. 0. Box 4320
Houston, Texas  77210

Fin Johnson, Chief                                                 D-17
Air Quality Section
North Carolina Department of Natural
  Resources & Community Development
P. 0. Box 27687
Raleigh, N. C.  27611

K. M. Karch, Manager                                               D-18
Regulatory and Environmental Affairs
Weyerhaeuser Company
Tacoma, Washington  98477

Charles 0. Velzy, P.E., President                                  D-19
Charles 0. Velzy Associates, Inc.
Consulting Engineers
355 Main Street
Armonk, N. Y.  10504

Dal ton Yancy                                                       D-20
Executive Vice President
Florida Sugar Cane League,  Inc.
P. 0. Box 1148
Clewiston, Florida  33440

James E. Walther                                                   D-21
Supervisor, Air and Noise Programs
Crown Zellerbach
Environmental Services
904 N.W. Drake St.
Camas, Washington  98607
                                      12

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                                                                  Docket
Commenter                                                        Reference

Daniel T. Skizim                                                   D-22
Manager of Contract Development
American Ref-Fuel
P. 0. Box 3151
Houston, Texas  77253

Peter W. McCallum                                                  D-23
Senior Corporate Environmental Specialist
Sohio-The Standard Oil Company
Midland Building
Cleveland, Ohio  44115

M. E. Miller, Jr., Manager                                         D-24
Environmental Engineering Unit
R. 0. Reynolds Tobacco Company
Winston Salem, N. C.  27102

Catherine A. Marshall                                              D-25
Vice President & Administrator,
  Technical Department
United States Brewers Association, Inc.
1750 K Street, N.W.
Washington, D. C.  20006

J. J. Moon, Manager                                                D-26
Environmental and Consumer Protection
Phillips Petroleum Company
7 D4 Phillips Building
Bartlesville, Oklahoma  74004

Donald A. Dowling                                                  D-27
Senior Vice President
Chief Operating Officer
Cogentrix of North Carolina,  Inc.
Two Parkway Plaza, Suite 290
Charlotte, N. C.  28210

W. C. Wolfe, Manager                                               D-28
Steam General Business Unit
Babcock & Wilcox
Industrial Power Generation Division
4282 Strausser Street, N.W.
P. 0. Box 2423
North Canton, Ohio  44720
                                      13

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                                                                  Docket
Commenter                                                        Reference

Mark D. Tucker                                                     D-29
Legal Department
The Dow Chemical Company
2030 Willard H. Dow Center
Midland, Michigan  48640

W. H. Axtman                                                       D-30
Executive Director
American Boiler Manufacturers Association
Suite 160
950 North Glebe Road
Arlington, Virginia  22203

William T. Burkhard, Supervisor                                    D-31
Regional Air Pollution Control Agency
451 W. Third Street
P. 0. Box 972
Dayton, Ohio  45422

J. D. Patterson, Manager                                           D-32
Environmental Affairs
Middle South Services, Inc.
Box 61000
New Orleans, Louisiana  70161

J. A. Barsin, Manager                                              D-33
Boiler Components & Equipment
Babcock & Wilcox
P. 0. Box 351
Barberton, Ohio  44203

U. V. Henderson, Associate Director                                D-34
Environmental Affairs
Research Environmental Safety Department
Texaco,  Inc.
P. 0.  Box 509
Beacon,  N. Y.   12508

F. William Brownell                                                D-35
J. D.  Fay
Hunton  & Williams
P. 0.  Box 12930
Washington,  D.  C.   20036
                                       14

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                                                                  Docket
Commenter                                                        Reference

Geraldine V. Cox, Ph.D.                                            D-36
Vice President, Technical Director
Chemical Manufacturers Association
2501 M Street, N.W.
Washington, D. C.  20037

Jan B. Vlcek                                                       D-37
James P. Rathvon
Sutherland, Asbill & Brennan
1666 K Street, N.W.
Suite 800
Washington, D. C.  20006

David G. Hawkins                                                   D-38
Natural Resources Defense Council, Inc.
1350 New York Avenue, N.W.
Suite 300
Washington, D. C.  20005

J. C. Edwards                                                      D-39
Clean Environment Program
Eastman Kodak Company - Chemicals Division
P. 0. Box 511
Kingsport, Tennessee  37862

John L. Festa, Ph.D.                                               D-40
Director, Chemical Control Program
National Forest Products Association/
  American Paper Institute
1619 Massachusetts Avenue, N.W.
Washington, D. C.  20036

Jan B. Vlcek                                                       D-41
James P. Rathvon
Sutherland, Asbill & Brennan
1666 K Street, N.W.
Suite 800
Washington, D. C.  20006

J. C. de Rugter, Senior Engineer, Power Group                      D-42
T. A. Kittmeman, Air Quality and Hazards
  Engineering Group
E.I. du Pont de Nemours & Company, Inc.
Engineering Department, Louviers Building
Wilmington, Delaware  19898
                                      15

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                                                                  Docket
Commenter                                                        Reference

Dr. William J. Vullo                                               D-43
Environmental Project Engineer
General Electric Company
Environmental Protection Operation
One River Road
Schenectady, New York  12345

Rae E. Cronmiller                                                  D-44
Environmental Counsel
National Rural Electric Cooperative Association
1800 Massachusetts Ave., N.W.
Washington, D. C.  20036

James D. Beatty                                                    D-45
The Procter & Gamble Company
P. 0. Box 599
Cincinnati, Ohio  45201

Jan W. Mares                                                       D-46
Assistant Secretary for Policy, Safety,
  and Environment
Department of Energy
Washington, D. C.  20585

Dr. John E. Pinkerton                                              D-47
Air Quality Program Manager
National Council of the Paper Industry
  for Air and Stream Improvement, Inc.
260 Madison Ave.
New York, New York  10016

S. J. Eaton                                                        D-48
Coen Company, Inc.
1510 Rollins Road
Burlingame, California  94010

Bruce P. Clinton                                                   D-49
Senior  Energy Technology Specialist
Hercules, Inc.
Hercules Plaza
Wilmington,  Delaware   19894
                                       16

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                                                                  Docket
Commenter                                                        Reference

Herbert Wortreich                                                  D-50
Assistant Director, Air and Noise Quality
State of New Jersey
Department of Environmental Protection
John Fitch Plaza CN 027
Trenton, New Jersey  08625

Bo 0. A. Oscarsson                                                 D-51
Technical Manager
Gotaverken Energy Systems
P. 0. Box 2147
Charlotte, N. C.  28211

Kathleen M. Bennett                                                D-52
Director of Regulatory Affairs
Champion International Corporation
One Champion Plaza
Stamford, Connecticut  06921

Eric J. Schmidt                                                    D-53
Senior Environmental Engineer
Georgia-Pacific Corporation
P. 0. Box 105605
Atlanta, Georgia  30348

L. K. Arehart                                                      D-54
Supervisor-Regulatory Analysis
Health and Environmental Affairs Department
Diamond Shamrock Corporation
717 North Harwood Street
Dallas, Texas  75201

H. E. Cameron                                                      D-55
Plant Environment
Environmental Activities Staff
General Motors Corporation
General Motors Technical Center
30400 Mount Road
Warren, Michigan  48090

H. B. Coffman, Manager                                             D-56
Environmental Services
Texas Utilities Generating Company
Skyway Tower
400 North Olive Street, L.B. 81
Dallas, Texas  75201
                                      17

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                                                                  Docket
Commenter                                                        Reference

Richard C. Wigger                                                  D-57
Vice President
Environmental and Safety Affairs
Champion International Corporation
One Champion Plaza
Stamford, Connecticut  06921

N. D. Fitzroy, Manager                                             D-58
Energy and Environment Programs
General Electric Company
Gas Turbine Technology Development
  & Planning Operation
One River Road
Schenectady, New York  12345

Terry McGuire, Chief                                               D-64
Technical Support Division
California Air Resources Board
1102 Q Street
P. 0. Box 2815
Sacramento, CA  95812

Maggie Dean, Director                                              D-65
Environmental Affairs
American Textile Manufacturers Institute, Inc.
1101 Connecticut Avenue, N.W.,
Suite 300
Washington, D.C.  20036

Larry F. Kertcher, Chief                                           D-70
Air Compliance Branch (5AC-26)
U.S. Environmental Protection Agency
Region V

Michael Baly, III                                                  D-76
Vice President, Government Relations
American Gas Association
1515 Wilson Boulevard
Arlington, VA  22209
                                      18

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          TABLE 2-2.   LIST OF COMMENTERS ON THE PROPOSED AMENDMENT
         OF THE NITROGEN OXIDES STANDARD FOR NATURAL GAS/WOOD-FIRED

                      SUBPART D STEAM GENERATING UNITS


                                                                  Docket
Commenter                                                        Reference

James D. Beatty                                                   IV-D-77
The Procter and Gamble Company
6110 Center Hill Road
Cincinnati, Ohio  45224

William B. Marx, President                                         D-78
Council of Industrial Boiler Owners
11222 Silverleaf Drive
Fairfax Station, Virginia  22039

John L. Festa, Ph.D.                                                D-79
Director, Chemical Control Program
National Forest Products Association/
  American Paper Institute
1619 Massachusetts Avenue, N.W.
Washington, D. C.  20036
                                      19

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     2.6    Costs/Cost Effectiveness of the Proposed Standards



     2.7    Monitoring, Recordkeeping, and Reporting Requirements



     2.8    Emission Credits for Cogeneration/Combined Cycle Systems .



     2.9    Energy, Environmental, and Economic Impacts  •



     2.10   Miscellaneous Comments



     2.11   NO  Emission Limits for Wood Residue and Natural Gas-Fired Units
              A


2.1  APPLICABILITY OF THE STANDARD



2.1.1  General



        1.  D-17



       Comment:     EPA is correct in exempting modified sources from the



                    NO  emission limits.
                      /\


        2.  D-38



       Comment:     EPA has no statutory authority to exempt modified steam



                    generating units from the NO  standards.  NO  control
                                                J\               /\


                    techniques can be retrofitted to steam generating units.



        3.  D-8, D-34, D-58



       Comment:     The proposed NO  emission limits would apply to gas
       ~"^^^                         A


                    turbine emissions when these turbines are employed in



                    cogeneration systems.



        4.  D-2, D-3



       Comment:     Steam generating units firing municipal solid waste



                    would be subject to both 40 CFR Part 60 Subpart Db and



                    40 CFR Part 60 Subpart E.



        5.  D-2



       Comment:     The applicability of the regulation to sewage sludge



                    incinerators which generate steam should be addressed.
                                      20

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 6.  D-2
Comment:
 7.  D-2
Comment:
             Sewage sludge incinerators  and incinerators  subject to
             40 CFR Part 60 Subpart E  should be excluded  from 40 CFR
             Part 60 Subpart Db.

             The emission limits  for solid waste-fired steam
             generating units should be  expressed in  a concentration
             format because it is difficult to accurately measure the
             heat input for these steam  generating units.
             NO  emission limits for combustion of municipal  solid
               A
 8.  D-19, D-22,  D-28,  D-30,  D-37
Comment:
             wastes should not be included in the  final  standard,  but
             treated on case-by-case basis by State and  local
             agencies.   The composition of municipal  solid waste
             varies too widely to set a specific  emission  limit.
 9.  D-8, D-36
Comment:      EPA  has not adequately studied the emission
             characteristics  of chemical  waste incinerators.   There
             is a wide  variety of industrial  incinerators  currently
             in use. The definition of incinerators  is  too broad  and
             is inconsistent  with prior definitions of steam
             generating units.
10.  D-2
Comment:
             The precise definition of a municipal  solid waste
             incinerator should be addressed in the regulation  for
                               21

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                    purposes of defining prevention of significant
                    deterioration (PSD)  applicability.
2.1.2  Process Units
        1.  D-7
       Comment:
        2.  D-9
       Comment:
        3.  D-9
       Comment:
The definition of steam generating unit should be
modified to exclude process heaters that produce steam
in waste heat economizers for energy conservation
purposes.  These sources should be covered in the NSPS
for fired heaters in the petroleum refining and
petrochemical industries.

Sources where low excess air (LEA) operation is not
appropriate should be exempted from the NO  emission
                                          /\
limits.  These would include certain process units such
as carbon monoxide (CO) steam generating units where
fossil fuels are fired as supplementary fuels.  Process
units are subject to variations in process conditions
and have several sources of heat input.  LEA operation
may not be applicable to these units.

Sulfur recovery unit feed gas would be included in the
definition of natural gas.  This would make Claus units
subject to the regulation.  LEA technology is not
applicable to Claus units because the amount of air used
for combustion is only one-third of the theoretical
requirement.

                  22

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 4.  D-19



Comment:
 5.  0-29



Comment:
 6.  D-34



Comment:
The proposed NSPS appears to unfairly penalize auxiliary



gas-fired units (energy recovery units) compared to



straight incineration and non-heat recovery units by



establishing stringent emission limits for auxiliary



gas-fired units and exempting non-heat recovery units.







EPA has not considered the operating parameters and



source characteristics of thermal heat recovery



oxidation (THROX) units.  THROX units destroy toxic and



non-toxic wastes, recover hydrochloric acid and sodium



bicarbonate solution, and generate heat for use in



process plants.  THROX units utilize technology which is



very different from conventional steam generating units



or incinerators.  Because these units both generate



steam and destroy "hard to destroy" wastes, they should



be treated as a distinct source category.  NO  emissions
                                             X


from THROX units are typically in the 25 to 50 ppm



range.  In meeting the proposed NO  emission limits, the
                                  s\


ability of THROX units to destroy wastes and recover



materials would be limited.







Do the proposed standards apply to fluid catalytic



cracking units?
                               23

-------
        7.  D-34



       Comment:      EPA's treatment of CO steam generating units  in



                    60.43b(a)  and (b)  is unclear.   The formulas provided do



                    not contain any terms for NO  emissions from  CO burning.
                                                X


                    Would CO steam generating units be required to meet the



                    proposed limit for natural gas firing?



2.1.3  Mixed Fuel-Fired Units



        1.  D-3



       Comment:      It is not  clear whether and how the emission  limits



                    identified as (6)  or (7) in the table of 60.43b(a)  would



                    apply to sources firing a mixture of fuels.



        2.  D-16, D-36, D-42



       Comment:      Firing of  solid industrial waste in combination with



                    fossil fuels should be exempted from the regulations or



                    covered under a separate category.



        3.  D-18, D-37, D-40,  D-47, D-49, D-53, D-57



       Comment:      The 5 percent annual fossil fuel capacity factor



                    criterion  suggested by EPA for exclusion from the NO
                                                                        /\


                    monitoring and emission standards is not realistic



                    because it does not account for the limitations on



                    system burndown ratios, or for the need to periodically



                    increase fossil fuel use to account for fluctuations in



                    load and fuel characteristics.  Steam generating unit



                    stability requires fossil fuel use of at least 10



                    percent.
                                      24

-------
        4.   D-57
       Comment:      Steam generating units  burning combinations of
                    gas/oil/coal  and wood should be exempt from the NOX
                    standards if  the annual  fossil fuel  capacity factor is
                    less than 25  percent.
2.1.4  Fuel  Definitions/Exclusions
        1.   D-30, D-37, D-42, D-45, D-49
       Comment:      Black liquor  recovery steam generating units, coal/water
                    slurries, coal/oil  slurries, and micronized coal  should
                    be explicitly exempted from the regulations.
        2.   D-9, D-30, D-36, D-37, D-42, D-45, D-49, D-54
       Comment:      The existing  definition of "natural  gas" is too broad,
                    and should be revised to exclude other gaseous
                    materials.
        3.  D-30
       Comment:
	      The definition of wood should be revised to include only
             natural wood products without additives, drying, sizing,
             and with a moisture content of between 40 and 50 percent
             and a nitrogen content of greater than 0.4 percent
             (dry).
 4.  D-15, D-34, D-36, D-37, D-38
Comment:     The definition of "other fuels" is too vague.  Emission
             limits for these fuels should be determined on a
             case-by-case basis.
                                      25

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 5.  D-20
Comment:

 6.  D-18,
Comment:
 7.  D-18
Comment:
 8.  D-27,
Comment:

 9.  D-29
Comment:
10.  D-29
Comment:

11.  D-32,
Comment:
  Units burning bagasse should be explicitly exempted from
  the regulations.
D-37
  The proposed standard appears to cover wood gasification
  and combustion of that gas, but no data are presented.
  Gaseous and liquid products from wood and other forms of
  biomass should be excluded from the standard until data
  become available.

  Firing of pulverized wood fines should be exempt from
  the regulations because no data are available on
  emissions from units firing this fuel.
D-29, D-37, D-45, D-54
  Combined cycle/cogeneration systems should be exempted
  from the proposed NO  emission limits.
                      X

  No definition is provided for incinerators.

  Thermal heat recovery oxidation (THROX) units should be
  exempted from the proposed standards.
D-35, D-56
  Auxiliary steam generating units at steam-electric
  plants should be exempted from the standards.  These
  steam generating units are infrequently operated and do
  not contribute significantly to emissions.
                               26

-------
12.  D-34
Comment:
13.  D-37
Comment:
14.  D-37
Comment:
15.  D-37
Comment:

16.  D-54
Comment:

17.  D-16,
Comment:
  Plant produced fuel  gas  can  contain  elevated nitrogen
  concentrations and a waiver  should be  granted by EPA for
  this  difference in NO emissions.
                       /\

  Steam generating units burning any type of agricultural
  wastes should be exempted from the proposed standard.
  No data are available to support standards, and
  emissions from burning these wastes  are minimal.

  The definition of coal  is too broad.  Data are
  unavailable to support standards for units burning
  coal-derived fuels.   The definition  of coal should be
  restricted to established coal forms and firing methods.

  Incinerators should be excluded from the proposed
  standards.

  Heat recovery steam generating units should be exempted
  from the proposed regulations.
D-30, D-34, D-36, D-37, D-39,  D-42, D-45, D-49
  Gaseous and liquid byproduct fuels should be deleted
  from the definitions of  natural gas  and residual oil.
  The emissions and combustion characteristics of these
  fuels are too variable  to justify their inclusion in the
  proposed standards for  fossil oil and gas.
                               27

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2.1.5  Size Cutoff
        1.  D-6, D-12, D-31
       Comment:      EPA is correct in establishing NSPS for steam generating
                    units in the 29 to 73 MW (100 to 250 million Btu/hour)
                    heat input capacity size range because the States have
                    been reluctant to set stringent emission limits for
                    these units in the absence of NSPS.
        2.  D-ll, D-18, D-40, D-42, D-47, D-57
       Comment:      The NSPS for steam generating units in the 29 to 73 MW
                    (100 to 250 million Btu/hour) heat input capacity size
                    range are not warranted given the relatively small
                    contribution to emissions from these sources.  State
                    regulations are sufficient to meet the regulatory needs
                    of these steam generating units.
        3.  D-ll, D-57
       Comment:      It would be "arbitrary and unlawful" for EPA to
                    promulgate NSPS for steam generating units in the 29 to
                    73 MW (100 to 250 million Btu/hour) heat input capacity
                    size range without first formally denying requests that
                    these size units be delisted.
        4.  D-38
       Comment:
It would be unlawful for EPA to regulate steam
generating units only down to 29 MW (100 million
Btu/hour) heat input capacity because EPA has previously
                                      28

-------
                    identified steam generating  units  as  small  as  2.9  MW (10



                    million  Btu/hour)  heat  input capacity to  be major



                    sources.



        5.   D-50



       Comment:      The lower limit on capacity  of affected steam  generating



                    units  is  too  high  and  should be set at 15 MW (50 million



                    Btu/hour) heat input capacity.  Steam generating units



                    in the 15 to  29 MW (50  to  100 million Btu/hour) heat



                    input  capacity range are  similar in design to  those in



                    the 29 to 73  MW (100 to 250  million Btu/hour)  heat input



                    capacity size range, make  up a similar fraction of the



                    total  steam generating  unit  population, and have similar



                    fuel  use patterns.



2.2  SELECTION/PERFORMANCE OF DEMONSTRATED  NO  CONTROL TECHNOLOGY
                                             /\


2.2.1  General



        1.   D-9, D-30, D-48



       Comment:      Low excess air (LEA) technology should form the



                    technological  basis of  the proposed standards  for  NO
                                                                        J\


                    rather than add-on control technology.   The LEA



                    technology results in  no  additional capital or operating



                    costs, saves  energy, does  not result  in increased



                    emissions of  other pollutants, and is effective at all



                    generating loads.



        2.   D-16, D-24, D-25, D-30, D-36,  D-37,  D-42,  D-43, D-46,  D-48, D-49



       Comment:      The EPA  has made broad  and sweeping conclusions as to



                    the performance of control technologies on the basis of





                                      29

-------
             limited test data.   Sufficient data have not been



             developed to support emission limits for all the fuels



             and fuel  combinations the proposal  intends to regulate.



 3.  D-29, D-30, D-36, D-37, D-42, D-48



Comment:     Staged combustion (SC) has not been adequately



             demonstrated in reducing NO  emissions from steam
                                        X


             generating units in the 29 to 73 MW (100 to 250 million



             Btu/hour) heat input capacity size range, and there are



             insufficient data to support emission standards based on



             SC controls.  Specifically, (1) SC technology has not



             been adequately demonstrated for high heat release



             package steam generating units burning residual oil with



             a nitrogen content of 0.2 to 0.4 weight percent, (2) SC



             has not been adequately demonstrated on



             spreader-stokers, (3) SC has been shown to be



             ineffective in reducing NO  emissions under reduced load
                                       A


             operation for all steam generating unit/fuel



             arrangements.



 4.  D-30, D-37, D-48



Comment:     The correlations established for predicting the



             emission reductions achievable by SC are in error



             because (1) data from all different types of steam



             generating units were grouped together, (2) the majority



             of data are for small package units or large field



             erected units, (3) a number of data points were obtained



             from units operating with high excess air and the method





                               30

-------
             used to normalize emission data to a baseline oxygen



             level  is subject to error, and (4) virtually all  of the



             data for SC operation were obtained from furnaces-with



             long residence times and low heat release rates,  and



             these data cannot be generalized to high heat release



             package steam generating units.



 5.  D-30



Comment:     The EPA is incorrect in stating that flue gas



             recirculation (FGR) achieves little reduction in  NO
                                                                A


             beyond that achievable with LEA.  FGR is most effective



             in suppressing thermal NO  formation from combustion of
                                      /\


             gas and distillate oil and can achieve a reduction in



             NO  emissions of more than 30 percent.  Drawing
               A


             conclusions from tests on two small FGR-equipped  units



             [less than 15 MW (50 million Btu/hour) heat input



             capacity] is difficult, and demonstrates the need for a



             larger data base in determining demonstrated technology.



 6.  D-25, D-29, D-30, D-33, D-36, D-37, D-42, D-48



Comment:     The EPA has given inadequate consideration to variations



             in steam generating unit design and the effect of these



             design variations on NO  emissions, particularly  those
                                    A


             relating to firebox design, heat release rate, and other



             factors relating to steam generating unit size.



 7.  D-9, D-37



Comment:     The EPA was correct in mathematically correlating NO
                                                                 A


             emission reductions with steam generating unit operating
                               31

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 8.  D-9
Comment:
             variables.   However,  EPA should demonstrate that these
             correlations are representative of the actual  population
             of steam generating units that EPA intends to  regulate.
             Case-by-case determinations should be allowed  for steam
             generating  units which are not representative.
Performance of NO  controls may decline with increasing
                 A
             equipment age.   The EPA tests were probably conducted on
             relatively new equipment and the emission limits may not
             account for declining performance due to age.
 9.  D-25, D-37
Comment:     Large package steam generating units may have  to be
             derated by up to 30 percent to meet the proposed
             standard because of limitations on firebox size.  The
             Agency derating estimate of 7 percent is an
             underestimate.
10.  D-25, D-26, D-36, D-37
Comment:     The "vendor guarantees" cited by EPA can not be used as
             a basis for determining best demonstrated technology
             because these do not represent actual contracts between
             buyers and sellers, and many of these guarantees apply
             only to the extreme lower size of the steam generating
             units to be regulated.
11.  D-32
Comment:
Only one of five vendors would guarantee a NO  emission
                                             /\
limit of 43 ng/J (0.1 ID/million Btu) heat input for a
                               32

-------
             distillate oil-fired unit.   This is insufficient for
             determining best demonstrated technology and has
             potential  antitrust ramifications.
12.  D-15, D-25
Comment:     Vendors of steam generating units and burner equipment
             are unable to guarantee an  emission limit of 43 ng/J
             (0.1 Ib/million Btu) heat input will  be achieved when
             firing natural  gas or distillate oil.
13.  D-38
Comment:     The EPA has ignored the fact that various types of flue
             gas treatment technologies  have been  demonstrated in
             controlling NO  emissions from oil- and coal-fired steam
                           X
             generating units.  These systems should be used as the
             basis for setting the standards.
14.  D-38
Comment:     The proposed standards do not reflect the level of
             control achievable by low excess air/staged combustion/
             staged combustion burner (LEA/SC/SCB) technologies
             (lower emission limits are  justified).
15.  D-37, D-49
Comment:     Background data obtained over a 30-day test period
             should not be relied upon as representative of long-term
             operating conditions.  NO  emissions  can fluctuate due
             to process load swings, changes in  fuel characteristics,
             automatic control deviations, and time.
                               33

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2.2.2  Coal-Fired Steam Generating  Units



        1.   D-16, D-25, D-30,  D-36, D-37,  D-42,  D-49



       Comment:      Insufficient emission  test data are  available  to  support



                    the proposed NO  emission  limit of 301  ng/J  (0.7
                                   A


                    Ib/million Btu) heat  input for pulverized  coal-fired



                    steam generating units.   No  test  data were provided for



                    pulverized coal-fired  steam  generating  units of  less



                    than 88 MW (300 million  Btu/hour)  heat  input capacity.



                    Pulverized coal-fired  steam  generating  units of  less



                    than 73 MW (250 million  Btu/hour)  heat  input capacity



                    are designed substantially differently  (i.e.,



                    wall-fired) than larger  pulverized coal-fired  steam



                    generating units (i.e.,  tangentially-fired).
        2.  D-33



       Comment:
        3.  D-31



       Comment:
The proposed standards have not considered fluidized bed



combustion (FBC) as a demonstrated control technology.



Based on 2-year operating data with atmospheric



fluidized bed combustion (AFBC) units, NO  emissions of
                                         A


172 ng/J (0.4 Ib/million Btu) heat input are achievable



when burning eastern bituminous coal.








Pulverized coal-fired steam generating units can reduce



emissions of NO  to below the proposed limit of 301 ng/J
               A


(0.7 Ib/million Btu) heat input.  One unit was tested



and found to emit 84 ng/J (0.195 Ib NO /million Btu)
                                      /\


heat input.
                                      34

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 4.  D-25, D-33, D-37, D-43



Comment:     The NO  emission limit for coal firing should allow for
      ~"             /\


             differences between firing bituminous and subbituminous



             coal.  Such allowances are provided in the NSPS for



             steam-electric plants.



 5.  D-30, D-46



Comment:     The EPA does not have sufficient data to substantiate



             the long-term variation in NO  emissions from spreader
                                          /\


             stokers of 7 percent when using a 30-day rolling



             average.  Only two units were equipped with continuous



             monitors and both of these were operated at light loads



             and high excess air.
 6.  D-30



Comment:
             The EPA is incorrect in concluding that fuel  nitrogen




             content had no measurable effect on NO  emissions from
                                                   /\
             spreader stoker steam generating units.   The test



             procedures were inadequate to correlate  the fuel  burned



             at a given moment to NO  emissions.
                                    J\


 7.  D-25, D-30, D-33, D-36, D-37, 0-39, D-42



Comment:      The EPA is in error in concluding that combustion air



             preheat has no effect on NO  emissions from spreader
                                        /\


             stoker steam generating units.   The  test data were



             incorrectly interpreted.
                               35

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2.2.3  Gas-/0i1-Fired Steam Generating Units



        1.   D-30



       Comment:      The relationships between fuel  nitrogen content and NO
            "                                                         *     A


                    emissions is not well  established for residual oils,



                    especially the difference between burning residual  oil



                    in package steam generating units versus field erected



                    steam generating units.



        2.   D-7



       Comment:      Two new (1976) gas-fired steam generating units without



                    combustion air preheat and using LEA at the El Segundo



                    refinery have NO  emissions of 116 ng/J (0.27 Ib/million
                                    A


                    Btu) heat input.  To achieve the proposed emission



                    limit, emissions would have to be reduced by about 63



                    percent.  This exceeds the emission reduction capability



                    of SC/SCB technology,  which is normally recognized to be



                    30 to 45 percent.



        3.   D-25, D-36, D-37, D-48



       Comment:      The regression formula relating NO  emissions to design
         *~™^^^^^                                        A


                    variables for residual oil firing does not properly



                    address the thermal or the fuel NO  component.  The
                                                      A


                    thermal NO  component should vary according to heat
                              A


                    release to absorbing area and increase with increasing



                    capacity.  The values used in the equation for



                    conversion of fuel nitrogen to NO  are too low.
                                                     A
                                      36

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 4.  D-25, D-29, D-33, D-36, D-37
Comment:     Performance data for two natural  gas-fired units
             equipped with LEA air and overfire air capability-are
             not representative because the units had large  heat
             input capacities [166 and 234 MW (567 and 800 million
             Btu/hour)].
 5.  D-25, D-37, D-48
Comment:     Performance data for three natural gas-fired units
             equipped with LEA and SCB are not representative because
             they had been slightly derated.
 6.  D-26, D-29, D-32, D-36, D-37
Comment:     The data supporting the NO  emission limit for  steam
             generating units firing gas and distillate oil  are not
             representative because only one long-term test  was
             available and this was on a very small unit [1.5 MW (5
             million Btu/hour)] heat input capacity.
 7.  D-26
Comment:
The data supporting the NO  emission limit for steam
                          /\
             generating units firing gas and distillate oil  are not
             representative because the steam generating units with
             air preheat had relatively low air preheat temperatures.
 8.  D-26, D-32
Comment:
             generating units firing gas and distillate oil  are not
             representative because of the wide scatter seen among
The data supporting the NO  emission limit for steam
                          X
                               37

-------
                    the  individual  data  points.   Given  this  variability,  EPA



                    should  not  have relied  on  average values.



        9.   D-29,  D-30,  D-33, D-36, D-37, D-42,  D-49



       Comment:      The  EPA did not adequately assess the  effect  of



                    combustion  air  preheat  on  NO  emissions  from  gas-  and
                                                A


                    distillate  oil-fired steam generating  units.



       10.   D-29,  D-36,  D-37



       Comment:      The  EPA did not consider the effect of the nitrogen



                    content of  distillate oil  on NO  emissions from
                                                  J\


                    distillate  oil-fired steam generating  units.



       11.   D-32,  D-33,  D-36, D-37, D-42



       Comment:      Low  excess  air/staged combustion burner  technology has



                    not  been demonstrated to reduce emissions  from



                    distillate  oil-fired steam generating  units to 43  ng/J



                    (0.1 Ib/million Btu) heat  input.
       12.   D-55



       Comment:
The NO  standards for gas- and oil-fired steam

      A
                    generating units are based on a minimal  amount of test



                    data and appear impossible to meet on a  continuous



                    basis.



2.2.4  Other Steam Generating Units



        1.  D-16, D-30, D-37, D-39



       Comment:     Insufficient data are available to determine best



                    demonstrated technology for units firing combinations of



                    fossil  and nonfossil fuels.
                                      38

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 2.  D-22, D-28
Comment:     State requirements for minimum temperatures and
             residence times for destruction of organics in
             incinerators burning municipal solid waste would prevent
             these units from achieving the proposed limits on NO
                                                                 A
             emissions.
 3.  D-28
Comment:     Municipal solid waste incinerators would have to install
             scrubbers in order to reduce NO  emissions to 129 ng/J
                                            A
             (0.3 Ib/million Btu) heat input.  The costs of these
             systems have not been addressed.
 4.  D-34
Comment:
NO  control technologies for steam generating units may
  /\
             not be effective for turbines, particularly those firing
             distillate oil.
 5.  D-8, D-30, D-54
Comment:     The EPA has insufficient background information on which
             to establish NSPS for combined cycle systems.  No
             parametric data on effects of excess air, overfire air,
             system design or duct-firing have been obtained.
             Combined cycle systems should be evaluated as a separate
             source category.
                               39

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2.3  STRINGENCY OF THE N0v  EMISSION  LIMITS
                         A


        1.   D-23,  D-42, D-57



       Comment:     There is  no compelling  reason  to  establish  NSPS  for NO
       -•-~ f                                                                X


                    emissions from small  steam generating  units.   Only  one



                    area in the U.S.  is  not in attainment  with  the National



                    Ambient Air Quality  Standards  (NAAQS)  for NO  .
                                                               A


2.3.1  Gas-/Disti11ate Oil-Fired Steam Generating  Units



        1.   D-29,  D-30, D-37, D-48



       Comment:     The proposed emission limits are  unrealistic  and should



                    be raised to 86  ng/J (0.2 ID/million Btu) heat input for



                    distillate fuel  oil  (less than 0.05  percent nitrogen)



                    and for gas burning  with ambient  combustion air.



                    Gas-fired units  with preheated combustion air should be



                    limited to 108 ng/J  (0.25 Ib/million Btu) heat input.
        2.  D-7



       Comment:
        3.  D-9



       Comment:
The proposed emission limit is too stringent and should



be raised to between 65 and 86 ng/J (0.15 and 0.20



Ib/million Btu) heat input.  The proposed emission limit



exceeds the emission reduction capacity of LEA/SC/SCB



control technology.







The emission limits should be set at 86 ng/J (0.2



Ib/million Btu) heat input for natural gas-fired units



and 129 ng/J (0.3 Ib/million Btu) heat input for



distillate oil-fired units.  These levels can be met by



using LEA alone.





                  40

-------
        4.   D-15,  D-26
       Comment:      The proposed gas/distillate oil  emission limit is too
                    stringent and should be raised to 86 ng/J (0.2
                    ID/million Btu)  heat input.
        5.   D-33
       Comment:
        6.   D-33
       Comment:
A NOY standard of 86 ng/J (0.2 Ib/million Btu) heat
    /\
input for non-preheat gas/distillate oil firing would be
supported by commercial guarantees.
A NOY standard of 108 ng/J (0.25 Ib/million Btu) heat
    A
                    input for greater than 93°C (200°F)  preheat
                    gas/distillate oil  firing would be supported by
                    commercial  guarantees.
2.3.2  Residual  Oil-Fired Steam Generating Units
        1.   D-29,  D-30,  D-37, D-48
       Comment:      The  proposed NO  emission limits for residual  oil  firing
                                   /\
                    should be raised to 172 ng/J (0.4 Ib/million Btu)  heat
                    input for low nitrogen oils and to 215  ng/J (0.5
                    Ib/million  Btu) heat input for oil  with a high nitrogen
                    content.   The proposed limits  would prematurely force
                    most residual oil-fired units  to implement SC, which  has
                    not  been  properly developed for large package  units.
        2.   D-33
       Comment:
A NOV emission limit of 215 ng/J (0.5 Ib/million Btu)
    J\
heat input for high nitrogen (greater than 0.35 percent)
                                      41

-------
 3.   D-33
Comment:
             residual  oil  firing would be supported by commercial
             guarantees.
                    A NO   emission  limit  of 172  ng/J  (0.4 Ib/million Btu)
                       /\
             heat input for low nitrogen (less than 0.35 percent)
             residual  oil  firing would be supported by commercial
             guarantees.
 4.  D-38
Comment:     The data show that even high nitrogen residual oil-fired
             steam generating units could achieve a 30-day average
             emission rate of 129 ng/J (0.3 Ib/million Btu) heat
             input.
 5.  D-54
Comment:
                    The emission limits for residual  oil  firing should not
                    vary with the fuel  nitrogen content.   Fuel  nitrogen
                    varies widely on the basis of crude oil  supplies and is
                    expensive to monitor.
2.3.3  Mass Feed Coal-Fired Steam Generating Units
        1.  D-33
       Comment:     The proposed emission limit would be supported by
                    commercial guarantees.
2.  D-37
Comment:
                    The NO  emission limit for mass feed coal-fired steam
                          A
                    generating units should be 215 ng/J (0.5 Ib/million Btu)
                    heat input.
                               42

-------
2.3.4  Spreader Stoker Coal-Fired Steam Generating  Units



        1.   D-27, D-29, D-30,  D-37,  D-39



       Comment:     Spreader stoker  steam generating  units  operating  with



                    preheated  combustion air cannot achieve a  NO   emission
                                                               /\


                    limit of 258 ng/J  (0.6 lb/million Btu)  heat input.   The



                    emission limit should be raised to 301  ng/J (0.7



                    lb/million Btu)  heat input.   It was noted  that the



                    proposed limit would force spreader stokers with



                    preheated  combustion air to  be  designed for very  low



                    heat release rates, which would raise costs and thus



                    encourage  pulverized coal (PC)  firing.   The proposed



                    emission limit for PC firing is 301 ng/J (0.7  ID/million



                    Btu) heat  input.
        2.  D-33



       Comment:
        3.  D-33



       Comment:
        4.  D-38



       Comment:
A NO  emission limit of 301 ng/J (0.7 lb/million Btu)
    A


heat input for air preheat spreader stoker coal firing



would be supported by commercial guarantees.







A NO  emission limit of 258 ng/J (0.6 Ib/million Btu)
    /\


heat input for non-air preheat [less than 93°C (200°F)]



spreader stoker coal firing would be supported by



commercial guarantees.







The 11 percent upward adjustment of the long-term test



data is not representative of the other units tested and
                                      43

-------
             The NO  emission limit for pulverized coal-fired steam
                   /\
                    the emission level  should be lowered to between 172 and
                    215 ng/J (0.4 and 0.5 Ib/million Btu)  heat input.
2.3.5  Pulverized Coal-Fired Steam Generating Units
        1.  D-29, D-30, D-37, D-48
       Comment:
                    generating units should be raised to 344 ng/J (0.8
                    Ib/million Btu) heat input.   Although  LEA/SC can reduce
                    emissions from units smaller than 73 MW (250 million
                    Btu/hour) heat input capacity, a reduction to 301  ng/J
                    (0.7 Ib/million Btu) heat input cannot be achieved.  In
                    small  units, higher flame temperatures must be
                    maintained to achieve complete combustion because  of
                    smaller volume-to-surface area ratios.  These conditions
 2.  D-33
Comment:
             result in higher NO  emissions.
                                /\
                    A NOV emission limit of 344 ng/J (0.8 Ib/million Btu)
                        A
                    heat input for pulverized coal  firing would be supported
                    by commercial  guarantees.

                    Data collected by EPA/IERL show an emission rate of 172
                    ng/J (0.4 Ib/million Btu) heat input can be achieved
                    using low NO  burners.
                                /\
2.3.6  Multiple Fuel Units
        1.  D-30
       Comment:     More leeway must be provided in determining NO  emission
                                                                  A
                    limits for units burning multiple fossil fuels.
 3.  D-38
Comment:
                               44

-------
             Multiple fuel  steam generating units  are designed



             according to the most difficult fuel  to be burned.



             Because of this, NO  emission control  techniques are
                                A


             compromised in a multiple fuel-firing situation.  It is



             unreasonable to expect optimum NO  control when both
                                              A


             clean and dirty fuels are fired in a  unit designed



             primarily in accordance with the requirements for



             burning the more difficult to burn (dirty) fuels.



             Therefore, the limits should not be based on the lowest



             achievable NO  emissions for individual fuels in a
                          A


             multiple fuel  unit.



 2.  D-29, D-30, D-36, D-39, D-42, D-54



Comment:     Insufficient data are available to regulate emissions



             from units burning a combination of fossil fuels and



             chemical byproduct gaseous and liquid wastes,



             particularly waste fuels such as hydrogen gas, ammonia



             bearing gas, liquids with high nitrogen content, and



             high heat content fuels (greater than 1,500 Btu/ft).  In



             many instances, the applicable fossil  fuel-based NO
                                                                A


             limit could not be met.



 3.  D-16, D-30, D-36, D-37, D-39



Comment:     Insufficient data are available to justify NO  emission
                                                          /\


             limits for units firing nonfossil fuels and mixtures of



             nonfossil and fossil fuels.
                               45

-------
        4.   D-57
       Comment:      A  nonfossil  fuel  steam generating  unit  designed  to  burn
                    gas  and residual  oil  would be  designed  to  fire either
                    fuel  at the  same  rate.   Thus,  if the  weighted average
                    were applied,  the applicable emission limit would be  86
                    ng/J (0.2 Ib/million  Btu)  heat input.  A  steam
                    generating unit burning gas or residual oil  in
                    combination  with  wood or solid waste  should not  be
                    restricted to  86  ng/J (0.2 ID/million Btu)  heat  input
                    when a combination with distillate oil  would be  allowed
                    to emit 129  ng/J  (0.3 Ib/million Btu) heat input.   A
                    nonfossil steam generating unit burning gas and  residual
                    oil  in combination should be allowed  a  NO   limit
                                                             /\
                    equivalent to  that for residual oil-fired  steam
                    generating units.
2.3.7  Combined Cycle  Systems
        1.   D-30, D-48
       Comment:     The emission limit for combined cycle units should  be
                    raised to 86 ng/J (0.2 Ib/million Btu)  heat input  for
                    units burning  gas and distillate oil  and  should  be
                    deferred for units firing residual oil.
2.4  SELECTION/PERFORMANCE OF DEMONSTRATED PARTICULATE MATTER CONTROL
     TECHNOLOGY
        1.   D-4
       Comment:     A specific collection area (SCA) of greater than 250
                      2
                    ft /I,000 acfm will not assure that the proposed

                                      46

-------
 2.  D-13
Comment:
 3.  D-4
Comment:
 4.  D-4
Comment:
standard will be met.  Data from one plant indicated
that a particulate matter emission level of-65 ng/J
(0.15 Ib/million Btu) heat input is achievable on.a
continuous basis with existing technology.  The standard
must account for soot blowing.

Electrostatic precipitators are capable of reducing
particulate matter emissions from combination
coal-/wood-fired steam generating units to 86 ng/J (0.02
Ib/million Btu) heat input.

Insufficient data are available to set NSPS for
particulate matter emissions from municipal solid
waste/refuse derived fuel-fired steam generating units
(MSW/RDF).  The EPA did not test enough facilities to
account for typical emissions variability, or test any
facilities burning up to 50 percent MSW.

Variability in fuel characteristics (moisture, ash, heat
content) which is 2 to 3 times higher for MSW/RDF than
for other fuels causes corresponding variabilities in
emissions and control device performance.  Particulate
matter emissions ranged from 22 to 56 ng/J (0.05 to 0.13
Ib/million Btu) heat input and averaged 39 ng/J (0.09
Ib/million Btu) heat input (standard deviation = 0.03).
Periodic (greater than 6 min/hour) soot blowing is also

                  47

-------
 5.  D-31
Comment:
             required which increases particulate matter emissions by
             about 80 percent.

	      Two MSW incinerators equipped with ESP's (300 ft2/l,000
             cfm) achieved emission rates of 13 and 17 ng/J (0.03 and
             0.04 Ib/million Btu) heat input.  State of the art
             control technologies can reduce emissions from MSW
             incinerators to less than 43 ng/J (0.1 ID/million Btu)
             heat input.
 6.  D-31, D-38
Comment:     The "relaxed" emission levels allowed for units
             operating at capacity factors of less than 30 percent do
             not represent application of best demonstrated
             technology.
 7.  D-31, D-38
Comment:     Based on EPA's own admission, ESP's are capable of
             reducing emissions from units firing mixed fuels to  less
             than 43 ng/J  (0.1 Ib/million Btu) heat  input.
 8.  D-38
Comment:
             The  EPA's conclusion that fabric filters and ESP's
             cannot achieve better than 22 ng/J  (0.05 Ib/million Btu)
             heat input on coal-fired steam generating units  is
             arbitrary, capricious,  and is not supported by the data
             available to EPA.  The  EPA has previously determined,
             and  defended in  court,  that  emissions  of 13 ng/J  (0.03
             Ib/million Btu)  heat input are achievable based  on data

                               48

-------
                    from both utility and  industrial  steam generating units.
                    The few test data showing  emissions  higher than  13 ng/J
                    (0.03 Ib/million Btu)  heat input  were from ESP's  having
                    SCA's less than that considered to  represent best
                    demonstrated technology (650 ft /I,000 acfm).  All  of
                    the data on the fabric filter systems support an
                    emission limit of 13 ng/J  (0.03 Ib/million Btu)  heat
                    input.   The Unit C system  was not a  well  designed and
                    operated system and test data on  this system included
                    soot blowing cycles.
        9.   D-50
       Comment:      Particulate matter emissions from wood-fired steam
                    generating units can be controlled  to less than  43 ng/J
                    (0.1 Ib/million Btu) heat  input.
2.5  STRINGENCY  OF THE PARTICULATE MATTER  EMISSION LIMITS
        1.   D-24,  D-57
       Comment:      The emission limits for particulate  matter are too
                    stringent.
        2.   D-31
       Comment:      The emission limit for coal-fired steam generating units
                    of 22 ng/J (0.05 ID/million Btu)  heat input is
                    appropriate.
        3.   D-31,  D-38
       Comment:      The proposed emission  limit for municipal  waste
                    incinerators is too lenient and does not reflect  best
                    demonstrated technology.

                                      49

-------
 4.  D-31, D-38
Comment:     The proposed emission limits for units operating at less
             than 30 percent capacity factors are far too lenient.   A
             capacity factor of 30 percent does not reflect a
             "standby" or sparingly used unit.
 5.  D-31
Comment:
 6.  D-38
Comment:
 7.  D-38
Comment:
 8.  D-38
Comment:
The proposed emission limits for mixed fuel firing as
specified in 60.42b(c) are too lenient and should be
lowered to 30 ng/J (0.07 Ib/million Btu) heat input.

The proposed emission limit of 22 ng/J (0.05 Ib/million
Btu) heat input for coal-fired steam generating units is
too lenient, and should be lowered to 13 ng/J (0.03
Ib/million Btu) heat input.

Wood-fired steam generating units equipped with
electrostatic granular filters (EGF) can achieve
emissions of 9 to 17 ng/J (0.02 to 0.04 Ib/million Btu)
heat input.  The EPA has not justified setting a higher
standard.

In the absence of any theoretical or empirical data to
show that mixed solid fuel steam generating units cannot
achieve the same emission levels as coal-fired steam
generating units, EPA should not propose separate
emission limits for these sources.  The 5 percent mixed

                  50

-------
 9.  D-50
Comment:
10.  D-55
Comment:
11.  D-37
Comment:
fuel criterion will  encourage owners and operators to
burn these fuels in  order to be subject to a less
stringent emission limit.

The proposed emission limit of 43 ng/J (0.1 Ib/million
Btu) heat input for  wood-fired steam generating units is
too lenient.  Although wood is not widely burned, the
proposed emission limit fails to consider the emission
impact of the proposed standard in the areas near wood
burning sources.

The particulate matter emission limit of 22 ng/J (0.05
Ib/million Btu) heat input for coal-fired steam
generating units prohibits the use of wet scrubbers
which may be required for standards covering emissions
of sulfur dioxide.

The following particulate matter emission limits are
recommended for steam generating units in the 29 to 73
MW (100 to 250 million Btu/hour) heat input capacity
size range:
                       Mass feed spreader stoker, 108 ng/J
                       (0.25 Ib/million Btu) heat input;
                       Pulverized coal, 43 ng/J (0.1 Ib/million
                       Btu) heat input.

                               51

-------
                    For steam generating units above 73 MW (250 million



                    Btu/hour) heat input capacity,  a particulate matter



                    emission limit of 43 ng/J  (0.1  Ib/million Btu)  heat



                    input should be set for coal  and residual oil  firing.



       12.   D-12



       Comment:      The proposed particulate matter emission levels are



                    appropriate.



2.6  COSTS/COST EFFECTIVENESS OF THE PROPOSED  STANDARDS



        1.   D-7, D-25, D-30, D-36, D-37, D-39



       Comment:      The EPA has used steam generating units without low



                    excess air (LEA) controls  as  the basis for calculating



                    the cost effectiveness of  NO   controls.  Fuel  savings
                                                A


                    from LEA operation were credited to the costs of NO
                                                                       /\


                    controls.  This is inappropriate because new units will



                    be operated under LEA conditions even in the absence of



                    an NSPS.  The EPA's approach  understates the real cost



                    effectiveness of the proposed regulation.



        2.   D-15, D-36



       Comment:     The costs of meeting the proposed NO  emission limits
       " ™"                                               /\


                    are largely undefined because manufacturers do not



                    presently offer steam generating units guaranteed to



                    meet a 43 ng/J  (0.1 Ib/million Btu) heat input emission



                    limit.



        3.  D-18, D-24, D-26, D-27, D-29, D-40, D-45, D-46,  D-49, D-53



       Comment:     The costs of NO  continuous emission monitoring systems
       ^^^^™"--- •"                         /\


                    (CEMS) are  excessive for steam generating  units in the






                                       52

-------
             29 to 73 MW (100 to 250 million Btu/hour) heat input



             capacity size range.




 4.  D-18, D-53



Comment:      Steam generating units using between 5 and 30 percent of



             fossil  fuel input without a permanent NO  monitor will
                                                     A


             be required to perform an expensive 30-day NO
                                                          A


             compliance test.  The costs of this test will not be



             commensurate with the air quality benefits obtained.




 5.  D-18, D-24



Comment:      The cost effectiveness of controls for small steam



             generating units is 20 to 40 times higher than that for



             utility steam generating units, and represents a poor



             use of limited capital for environmental protection.




 6.  D-23



Comment:      The EPA estimates show that the cost of implementing the



             standard may be as high as $2,000/Mg ($l,800/ton) of NO
                                                                    A


             removed, but EPA has also estimated the benefits of NO
                                                                   A


             control are only $150/Mg ($135/ton).



 7.  D-25, D-37, D-43



Comment:      EPA has grossly underestimated the capital and operating



             costs of CEMS equipment.  Capital costs are about



             $125,000 and annual costs are about $100,000.



 8.  D-25, D-37



Comment:      The cost effectiveness of the proposed NO  standard for
 '"'                                                     A


             a gas-fired 44 MW (150 million Btu/hour) heat input



             capacity unit would be $3,000/Mg ($2,700/ton) removed,
                               53

-------
10.  D-27



Comment:
11.  D-31


Comment:
             The cost effectiveness  of the proposed NO  standard for
                                                      X
             assuming the use of a low NO  burner,  baseline LEA
                                         A


             operation,  a 7 percent derating,  and revised monitoring



             costs.   The costs are unreasonable.



 9.  D-25, D-37



Comment:



             a residual  oil-fired 44 MW (150 million Btu/hour)  heat



             input capacity unit would be $2,800/Mg ($2,500/ton)  for



             0.3 percent fuel nitrogen, and $4,400/Mg ($4,000/ton)



             for 0.4 percent fuel nitrogen, assuming the use of



             overfire air ports, baseline LEA operation, a 7 percent



             derating, and revised monitoring costs.  These costs are



             unreasonable.
             The costs for NO  CEMS are $110,000 in capital  costs and
                             A


             $50,000 in annual operating costs.   In addition, a



             microprocessor would be required to calculate 30-day



             rolling averages at a cost of $80,000.






             The EPA has placed too much reliance on cost and



             economic factors in establishing the proposed emission



             1imits.



12.  D-32, D-35



Comment:     It is not cost effective to require low excess



             air/staged combustion burner (LEA/SCB) controls on steam



             generating units with capacity factors of less than 30



             percent.
                               54

-------
13.  D-36,
Comment:
14.  D-36,
Comment:
15.  D-36,
Comment:
16.  D-38
Comment:
17.  D-38
Comment:
D-39, D-46
  The EPA has not presented cost effectiveness numbers in
  Tables 9 to 14 of the proposal in a manner which is
  meaningful for comparing alternative control levels.
  The incremental cost effectiveness between alternative
  control levels should be shown.
D-39
  The cost effectiveness numbers of pulverized coal firing
  in Table 9 are misleading because EPA has used the costs
  of a low efficiency ESP instead of the costs for a
  sidestream separator or a double mechanical collector.
D-37, D-45
  The cost effectiveness of particulate matter control for
  coal-fired steam generating units'are out of proportion
  to the cost effectiveness for utility size units.  The
  EPA should justify why a cutoff in cost effectiveness of
  $110/Mg ($100/ton) should not be established.

  Cost effectiveness calculations should be based on the
  actual expected performance of the best demonstrated
  systems in reducing emissions rather than on the
  emission limits themselves.

  EPA has not established that operating a CEMS for NO
                                                      /\
  emissions would be unreasonably costly for units
                               55

-------
             operating at an annual  capacity factor of less than 30



             percent.



18.  D-37, D-45



Comment:     The NO  emission limits should be revised to be of



             comparable cost effectiveness as those for utility size



             steam generating units.



19.  D-30, D-46, D-55, D-57



Comment:     The cost effectiveness of the proposed standards for



             particulate matter (coal/wood) are underestimated



             because the baseline emissions levels used by EPA [258



             ng/J (0.6 1 fa/million Btu) heat input] are higher than



             the actual emission levels generally allowed from these



             sources by State regulations.



20.  D-37



Comment:     The EPA has grossly underestimated the costs of control



             of NO  .  A steam generating unit derating of 30 percent
                  A


             will be required in many cases.  The monitoring



             requirements were underestimated by one-half.  There



             will be no fuel savings with  low NO  burners.  The
                                                /\


             actual cost effectiveness of  the standard for a 44 MW



             (150 million Btu/hour) heat  input capacity  natural



             gas-fired  steam generating unit  is over  $8,300/Mg



             ($7,500/ton).  The actual cost effectiveness  of



             controlling a  residual oil-fired steam generating  unit



             (0.4 percent nitrogen) is $5,500/Mg  ($5,000/ton).  The



             actual cost effectiveness of controlling a  residual
                                56

-------
21.  D-37



Comment:







22.  D-37



Comment:
                    oil-fired steam generating unit (0.3 percent nitrogen)



                    is $8,800/Mg ($8,000/ton).








                    The EPA must quantify the benefits of any proposed



                    standards.








                    Cost effectiveness data for residual oil-fired units are



                    presented for oils with 0.47 and 0.6 percent nitrogen.



                    Because the standard distinguishes residual oil with



                    less than 0.35 percent nitrogen, cost effectiveness data



                    for this oil should be provided.








                    Capital costs, including installation, for a



                    transmissometer for continuous opacity monitoring are



                    approximately $40,000.  These costs are unreasonable.



2.7  MONITORING, RECORDKEEPING AND REPORTING REQUIREMENTS



2.7.1  Continuous NO.. Emission Monitoring Systems
        i    ..,.,.,,.-.._.   j^                   •*  *•



        1.  D-5, D-39, D-40, D-47, D-54



       Comment:     Steam generating units having an annual capacity factor



                    greater than 30 percent should not be required to



                    install and operate a NO  CEMS if, during a 30-day
                                            /\


                    performance test, NO  emission levels of 30 percent (or
                                        J\


                    10 percent, D-47) or more below the applicable limit are



                    demonstrated.  This would be consistent with 40 CFR Part



                    60 Subpart D requirements.
23.  D-27



Comment:
                               57

-------
 2.  D-7, D-27, D-43, D-47, D-49



Comment:      Monitoring of operating conditions should be allowed for



             all units regardless of capacity factor.   NO  emissions
                                                         ^\


             can be reliably predicted for LEA, SC, and SCB controls



             once excess oxygen, optimum staging ratios, and load



             response curves are established.  These parameters can



             be established during the 30-day performance test and be



             subject to approval by the Administrator.  This approach



             would avoid the financial, maintenance, and operating



             problems associated with installing a NO  monitor on top
                                                     J\


             of the Op/CO monitors used in LEA systems.



 3.  D-8, D-21



Comment:      NO  monitors installed on combined cycle units will
   ^^~^^^^~        /\


             measure emissions from both the steam generating unit



             and the turbine unless two monitors are installed (inlet



             and outlet of steam generating unit) to determine



             incremental NO  formed in the steam generating unit.
                           A


             The EPA has not investigated costs or accuracy of twin



             monitoring systems.



 4.  D-18, D-24, D-47, D-49, D-53, D-55



Comment:      Most smaller manufacturing facilities which would be



             subject to the NSPS do not have personnel capable of



             operating, calibrating, and maintaining NO  CEMS.
                                                       /\


 5.  D-23, D-33, D-49, D-54



Comment:      Continuous NO  monitors are unreliable.
 ~                         A
                               58

-------
 6.  D-23, D-24, D-29, D-37, D-40,  D-43, D-49,  D-53,  D-55
Comment:
 7.  D-24,
Comment:

 8.  D-24,
Comment:
 9.  D-26
Comment:
10.  D-50
Comment:
11.  D-53
Comment:
  The continuous monitoring requirements for NO  emissions
                                               A
  are unnecessary and excessive.
D-26, D-27, D-33, D-37, D-55
  EPA Reference Method 7 is sufficient for determining
  compliance with the NO  emission limits.
                        /\
D-39
  The proposed requirement that malfunctioning CEMS
  equipment must be repaired within 15 days is unrealistic
  because of the sophisticated nature of this equipment,
  and the possible need to return the device to the
  manufacturer.


  If CEMS are required, provisions should be made to allow
  owners/operators to remove CEMS if after a sufficient
  period (2 years) emissions have not exceeded the limits.
  The proposed NO  monitoring requirements should be
                 A
  retained in the promulgated standards because major
  increases in NO  emissions in the future will create the
                 X
  need for better information on NO  control.
  The language currently in 40 CFR 60.45(b)(3) and (4)
  would provide adequate assurance that a new source was
  designed, manufactured, installed, and operated in a
  manner to achieve the proposed NO  emission limits.
                                   /\
                               59

-------
       12.   D-54



       Comment:
       13.   D-9



       Comment:
       14.   D-21



       Comment:
2.7.2  Opacity



        1.   D-3



       Comment:
It is not clear why EPA chose to adopt the 30-day



rolling average for NO  compliance.  The data seem to
                      /\


support a figure more than 8 percent above the 43 ng/J



(0.1 Ib/million Btu) heat input emission limit.  If this



is true, EPA should set the limit at 52 ng/J (0.12



Ib/million Btu) heat input or greater and retain the



existing compliance methods.







A NO  CEMS should not be required for gas and/or
    A


oil-fired steam generating units with less than 73 MW



(250 million Btu/hour) heat input capacity.  Stack



testing at suitable intervals should be an alternative



to installation of continuous NO  monitors.
                                X






An exemption from the NO  CEMS requirement is
                        X


recommended for combined cycle supplementary-fired gas



turbine systems with less than 30 percent total heat



input from low NO  duct burners.
                 X
The opacity span values of 60 to 80 percent would not



allow a determination of the severity of exceedances



above the span value.  A span value of 100 percent is



recommended.
                                      60

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 2.  D-4
Comment:
 3.  D-5
Comment:
 4.  D-5
Comment:
The opacity limit of 20 percent cannot be achieved
continuously for units firing municipal solid waste and
refuse derived fuel.  Company test data show 6-minute
opacity readings from 0 to 60 percent.  At average
particulate matter emissions of 327 ng/J (0.76
Ib/million Btu) heat input, opacity averaged 42 percent
for one test run.  The EPA data also show greater than
20 percent opacity with particulate matter emissions of.
43 ng/J (0.1 1 fa/mill ion Btu) heat input.  Soot blowing
increases opacity by 154 percent over non-soot blowing
periods.

Opacity values from in-stack monitoring devices should
be used for purposes of determining compliance instead
of Reference Method 9.  Use of transmissometers would be
contingent on proper installation and operation of the
device.  They would not be applicable for situations
where exhaust gases contain condensed water vapor, or
where a reaction or condensation plume is noted above
the stack.

When proper reading techniques are utilized, visible
emissions evaluations may be obtained from steam
generating units equipped with wet scrubbing devices.
                               61

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 5.  D-13,
Comment:

 6.  D-18
Comment:
 7.  D-18,
Comment:
 8.  D-27
Comment:
 9.  D-31
Comment:
10.  D-31
Comment:
D-18, D-47
  An opacity limit of 20 percent cannot be achieved
  continuously by units burning coal/wood mixtures. -

  The 6-minute average opacity limits would not be
  consistent with the limits on particulate matter
  emissions expressed as a 3-hour average.
D-30, D-37
  Site-specific opacity limits should be established.

  Visual determination of opacity using Reference Method 9
  is an adequate indicator that a particulate matter
  control device is being properly operated and
  maintained.

  The proposed opacity limit of 20 percent is too lenient
  for coal-fired units.  Properly operating control
  devices should result in visible emissions of no more
  than 5 to 10 percent opacity.

  The proposed opacity limits are assumed to apply to all
  phases of equipment operation:  startup, shutdown,  soot
  blowing, ash removal.
                               62

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       12.   D-38
       Comment:
11.  D-31
Comment:     Control devices operating at elevated temperatures to
             avoid dew point related problems will have difficu-lty in
             meeting the proposed opacity limits during startup and
             shutdown.

             Fabric filters and ESP's which are well operated and
             maintained can achieve an opacity limit of 1 percent.
             Accordingly, EPA should adopt an opacity limit of
             1 percent.
13.  D-37, D-57
Comment:     There is no justification of establishing a "not to be
             exceeded" limitation of opacity of 20 percent.  Opacity
             cannot be correlated to mass emission rates.  Opacity
             limits should only be used as an indicator of possible
             exceedance for reporting purposes.
       14.   D-54
       Comment:
             Facilities burning gas and oil should be exempt from the
             continuous opacity monitoring requirement.
2.7.3  Data Collection
                    The NO  averages  based on 720 hours  of operation would
                          /\
 1.  D-3, D-23
Comment:
             not be consistent with data collected for calendar time
             periods, and will be administratively burdensome.  The
             30-day averages should be calculated on rolling calendar
             time periods.

                               63

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        2.   D-3
       Comment:     The data availability requirement in  60.45b(f)  is  too
                    lenient because it  allows  a  source to be  in  compliance
                    while collecting less than 0.3  percent valid data
                    (1  hour valid  data  for every 16 days).  A required
                    percent (75  percent is recommended) valid data  should  be
                    specified for  each  30-day  period.
        3.   D-5,  D-53
       Comment:     To  be consistent with 40 CFR Part 60  Subpart D,  the
                    proposed minimum sampling  time  (for particulate  matter
                    emissions)  of  120 minutes, and  the minimum sampled
                    volume of 120  dscf, should be lowered to  60  minutes and
                    60  dscf, respectively.
2.7.4  Reporting  Requirements
        1.   D-3,  D-31,  D-38
       Comment:     Submittal of reports on a  semiannual  basis is too
                    infrequent for tracking CEMS operation, maintenance, and
                    quality assurance data.  Reports should be submitted
                    quarterly and  include emissions, data validation,  and
                    calibration information.
        2.  D-31
       Comment:
Affected facilities located in States to which EPA has
delegated enforcement authority should not be required
to submit reports to EPA.  In these cases, the reporting
requirements would be duplicative and should be waived.
                                      64

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 4.  D-38
Comment:
        3.   D-31
       Comment:      It is unclear in 60.46b(h).what specific items  should be
                    reported on excessive opacity in order to fulfill.the
                    reporting requirement.

                    Reports should be required,  regardless of whether an
                    excess emission has occurred, in order to ensure that
                    some sources do not neglect  to file  a  report.
2.7.5  Exemptions
        1.   D-3
       Comment:      The exemptions allowed  in 60.44b(a)  would not encourage
                    efforts to minimize emissions during startup, shutdown,
                    and malfunction.  Rather than granting a blanket
                    exemption, EPA should specify a percentage of each
                    reporting period when exceedances during startup,
                    shutdown, and malfunction would be allowed.
        2.   D-5, D-24, D-25, D-36, D-37, D-40, D-47, D-49
       Comment:      One 6-minute per hour exemption should be allowed for
                    opacity.  The 27 percent opacity allowance under 40 CFR
                    Part 60 Subpart D should be  extended to the  smaller
                    units covered in the proposed regulations.
        3.   D-13, D-39, D-47, D-57
       Comment:      The EPA should revise the proposed standard  to  allow  for
                    a number of 6-minute average opacity readings of above
                    20 percent to account for rapidly changing fuel  feed
                    rates or fuel  quality.

                                      65

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        4.   D-29
       Comment:      The  existing  pro-visions  for  petitioning  the
                    Administrator for  an exemption  from  the  proposed  -
                    standards  are inadequate.  Meeting the NO  emission
                                                            X
                    limits  for some  type of  units  (e.g.,  THROX) may not
                    result  in  non-compliance with  other  Federal,  State or
                    local regulations,  although  it  would  still result  in
                    diminished destruction efficiencies  and  interference
                    with process  operation.  The petitioning procedures
                    would cause substantial  delay,  expense,  and uncertainty.
        5.   D-36,  D-43
       Comment:      An  allowance  for soot blowing  in  residual oil- and solid
                    fuel-fired units should  be  included.
        6.   D-39
       Comment:      The  provisions for petitioning  the Administrator  for
                    units burning hazardous  wastes  should be expanded  to
                    allow these units  to  "maintain  the appropriate
                    destruction efficiency."
        7.   D-37,  D-45,  D-49,  D-53
       Comment:      Sources equipped with wet  scrubbers  for  particulate
                    matter  control should be exempted from the opacity
                    monitoring requirements.
2.7.6  Enforcement/Permitting
        1.   D-17
       Comment:      If EPA  delegates to a State the authority  to  enforce  the
                    proposed regulations, would a  permit which  limits  the

                                      66

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                    capacity factor have to be adopted as  part of the State
                    implementation plan (SIP)?
        2.   D-54
       Comment:      The rationale for the "capacity factor basis" appears
                    designed to accommodate those who permit multiple and/or
                    standby fuels.  The problem with the Agency's approach
                    is that, while a facility may be permitted to burn
                    residual oil  25 percent of the time, the facility
                    actually burns 100 percent oil during  those 90 days  per
                    year.   This proposal would leave such  an operation with
                    permit limits that could be met only by burning 25
                    percent oil all year long.  Thus, this approach does not
                    appear to be appropriate for use with  the EPA's proposed
                    30-day rolling average limits.
2.8  EMISSION CREDITS FOR  COMBINED CYCLE SYSTEMS
        1.   D-16,  D-29, D-34, D-36, D-39, D-40, D-44, D-54
       Comment:      Emission credits should be provided for combined cycle
                    and other cogeneration systems.
        2.   D-16,  D-29, D-40, D-44
       Comment:      The EPA should defer to State and local  agencies in
                    determining on a case-by-case basis specific emission
                    limits to ensure that emission credits do in fact lead
                    to net reductions in emissions.
        3.   D-34,  D-36
       Comment:      Emission reduction credits are often the difference
                    between making or breaking a cogeneration project.

                                      67

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        4.   D-36,  D-39
       Comment:      Site-specific factors  should not prevent EPA from
                    allowing emission credits  for cogeneration systems..   A
                    credit equivalent to about 50 percent of the credit  that
                    would be given on a one-to-one basis should be allowed.
        5.   D-36,  D-39,  D-46
       Comment:      The  EPA's decision not to  provide emission credits for
                    cogeneration systems is contrary to Congressional intent
                    in passing PURPA and other energy/environmental
                    legislation.
        6.   D-44
       Comment:      Emission credits could be  granted on a system-wide basis
                    for an electric utility based on system-wide reductions
                    in emissions achieved by avoidance of new conventional
                    technologies or replacement of older sources.
        7.   D-39,  D-44,, D-54
       Comment:      The EPA has exaggerated the potential for cogeneration
                    systems to displace cleaner sources of energy such as
                    hydroelectric or nuclear facilities.
2.9  ENERGY, ENVIRONMENTAL, AND ECONOMIC IMPACTS
2.9.1  Energy Impacts
        1.   D-25,  D-30,  D-48, D-49
       Comment:      The proposed NO  standards will not promote energy
       __^«^_«^H__                     ^
                    efficiency.  The use of staged combustion (SC) will
                    result in operation of units at unnecessarily high
                    excess air rates.
                                      68

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        2.   D-29



     • Comment:      The proposed NO  standards may limit the use of hydrogen
       ™™^~«—                         J\


                    and other wastes as fuel  and lead to increased usage of



                    natural  gas.



        3.   D-30,  D-36



       Comment:      The proposed NO  standards will  decrease energy
          1 •-—                       X


                    efficiency by limiting the use of combustion air



                    preheat.



2.9.2  Environmental Impacts



        1.   D-25,  D-30, D-37, D-47, D-48, D-55, 0-57



       Comment:      The EPA has overestimated the environmental  benefits



                    associated with this NSPS.  The number of new steam



                    generating units projected is too high and the



                    "baseline" emission levels used by EPA in calculating



                    national impacts are too high.



        2.   D-30,  D-48



       Comment:      The use of SC will result in many units being out of



                    compliance with State regulations for particulate



                    matter.



        3.   D-16,  D-25, D-29, D-30, D-36, D-37, D-43, D-48, D-49, D-54



       Comment:      The EPA has not investigated the impacts of higher



                    carbon monoxide, particulate, and hydrogen emissions



                    resulting from use of SC.
                                      69

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 4.  D-18, D-57
Comment:     The EPA estimates of the total  emission reductions which
             would be achieved under the proposed NSPS are only a few
             tenths of a percent of total  national  emissions.   The
             EPA has greatly overstated the  benefits of the proposed
             NSPS by not distinguishing steam generating units larger
             than 73 MW (250 million Btu/hour) heat input capacity
             from those in the 29 to 73 MW (100 to  250 million
             Btu/hour) heat input capacity size range.
 5.  D-18, D-37, D-57
Comment:     The EPA should perform a more thorough examination of
             the impacts of the proposed NSPS versus the benefits
             achieved under State regulations in order to determine
             whether the proposed standard will result in a
             significant improvement in air  quality.
 6.  D-18, D-37, D-55
Comment:     The proposed standards may result in delays in
             replacement of existing steam generating units,
             resulting in higher emissions.   Most new steam
             generating units are likely to  be replacements for older
             units.
 7.  D-57
Comment:
The tightening of the existing particulate matter
emission limit for coal-fired steam generating units
would provide no discernible environmental benefit in
maintaining the NAAQS.

                  70

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2.9.3  Economic Impacts
        1.  D-30, D-48
       Comment:     By forcing the premature use of SC, the financially
                    depressed steam generating unit/burner market will  be
                    subjected to "excessive risk."  The steam generating
                    unit/burner market is in no position to shoulder this
                    risk because of recent declines in the market.
        2.  D-23, D-33
       Comment:     The proposed regulations for particulate matter
                    emissions could raise the cost of a coal-fired steam
                    generating unit by as much as 10 percent, which would
                    discourage the transition from oil or gas to coal.   They
                    may encourage more industries to locate overseas.
        3.  D-36
       Comment:
                    The 15 percent steam generating unit derating required
                    for package residual oil-fired steam generating units to
                    meet the NO  emission limits would increase the cost of
                               /\
                    these steam generating units by 10 percent.
        4.  D-57
       Comment:
                    The proposed emission limits for particulate matter
                    would increase capital  costs and result in reduced
                    operating flexibility and increased downtime.
2.10  MISCELLANEOUS COMMENTS
        1.  D-17
       Comment:      The wording in 60.42b(c)  is cumbersome and unclear.
                                      71

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 2.  D-26
Comment:
 3.  D-38
Comment:
 4.  D-38
Comment:
 5.  D-47
Comment:
The phrase "after initial startup" should be deleted
from 60.44b(e)(2) in order to eliminate possible •
confusion with the requirements set forth in 60.8(a).

In calculating the achievable emission levels for
various technologies, EPA appears to have relied on
statistical techniques that specify an emission level
that will be exceeded only once every 10 years.  This
implies that enforcement action will result for one
exceedance in a 10-year period.  The EPA should
calculate the achievable emission levels based on one  .
assumed exceedance every year, every 2 years, and every
5 years.

The EPA has ignored the potentially important emission
reductions of both particulate matter and NO  that could
                                            /\
be achieved by the selective use of natural gas and
distillate oil.  The EPA should examine the emissions,
costs, and energy implications of standards for coal-
and residual oil-fired steam generating units that
assume the proportional use of these cleaner fuels at
several alternative levels of use.

Section 60.43b needs to be clarified.  Paragraph (a)
entry  (6) in the table indicates that mixtures of gas  or

                  72

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             oil  with wood or solid waste have  an  emission  limit of



             129  ng/J (0.3 Ib/million  Btu)  heat input.   Entry (7)



             conflicts with this limit.   The  reference  to entry (5)



             apparently should be to entry  (6). Otherwise,  the



             formula in paragraph (b)  would have to  be  used  to



             calculate the NO  emission  limit for  gas/oil/wood
                             /\


             combinations, and this would be  incorrect.  Also,  there



             is a problem with the formula  in paragraph  (b)  as  it



             applies to mixtures of wood/coal/gas/oil.   A 29 MW (100



             million Btu/hour) heat input capacity steam generating



             unit with a heat input of 5.9  MW (20  million Btu/hour)



             from wood, 2.9 MW (10 million  Btu/hour)  from gas,  and



             21 MW (70 million Btu/hour)  from coal would have an



             emission limit of 275 ng/J  (0.64 Ib/million Btu) heat



             input.   This problem could  be  corrected by  changing the



             definition of Ht to include  heat input  from wood when



             wood is burned with gas and  coal or with oil and coal.



             The  definition of Hu should  be modified to  include



             mixtures of distillate oil  and wood.



 6.  D-50



Comment:      The  equation used for the NO  limit for mixed  fossil/
                                         A


             nonfossil fuel burning needs to  include a  term  for the



             heat input from nonfossil fuels  in the  denominator.
                               73

-------
          7.   D-57



         Comment:      The EPA should not propose any new rules governing



                      particulate matter emissions while revisions to the



                      NAAQS for participates are still being considered.



          8.   D-30



         Comment:      60.43b(d) refers to modification of a facility as



                      defined in §60.15.  However, §60.15 covers



                      reconstruction, and §60.14 covers modification.  Which



                      is correct?
          9.  D-30



         Comment:
In 60.44b(a), the reference should be 60.43b, not



60.42b.
  2.11  NO  EMISSION LIMITS FOR WOOD RESIDUE AND NATURAL GAS-FIRED UNITS
          J\


          1.  D-77, D-78, D-79



         Comment:     The proposed rule that corrects the NSPS for units



                      firing mixtures of wood residue and natural gas to



                      129 ng/J (0.30 Ib/million Btu) heat input is strongly



                      endorsed.



          2.  D-77, D-78, D-79



         Comment:     The correction to the proposed rule should be adopted as



                      soon as possible (before May 31, 1986, D-77).
U.S. Environmental Protection Agency

Region V, Library                  *

230 South Dearborn Street

Chicago,  Illinois  60604
                                        74

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