x>EPA
United States      Industrial Environmental Research  EPA-600/7-78-164b
Environmental Protection  Laboratory         August 1978
Agency        Research Triangle Park NC 27711

Environmental
Assessment of
Coal- and Oil-firing
in a Controlled
Industrial Boiler;
Volume II.
Comparative
Assessment

Interagency
Energy/Environment
R&D Program Report

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                 RESEARCH  REPORTING SERIES

 Research reports of the Office of Research and Development, U.S. Environmental
 Protection Agency, have been grouped into nine series. These nine broad cate-
 gories were established to facilitate further development and application of en-
 vironmental technology. Elimination  of  traditional grouping was consciously
 planned to foster technology transfer and a maximum interface in related fields.
 The nine series are:

      1.   Environmental Health Effects Research
      2.   Environmental Protection Technology
      3.   Ecological Research
      4.   Environmental Monitoring
      5.   Socioeconomic  Environmental  Studies
      6.   Scientific and Technical Assessment Reports (STAR)
      7   Interagency Energy-Environment Research and Development
      8.  "Special" Reports
      9.  Miscellaneous Reports

This report has  been assigned to  the INTERAGENCY ENERGY-ENVIRONMENT
 RESEARCH AND DEVELOPMENT series. Reports in this series result from the
effort  funded under the 17-agency Federal Energy/Environment Research and
 Development Program. These studies relate to EPA's mission to protect the public
health and welfare from adverse effects of pollutants associated with energy sys-
tems.  The  goal of the Program is to assure the rapid development of domestic
energy supplies in an environmentally-compatible manner by providing the nec-
essary environmental data and control technology. Investigations include analy-
ses of the  transport of energy-related  pollutants and their health and ecological
effects; assessments of, and development of, control technologies for  energy
systems; and integrated assessments of a wide range of energy-related environ-
mental issues.
                           REVIEW NOTICE

 This report has been reviewed by the participating Federal Agencies, and approved
 for publication.  Approval does not signify that the contents necessarily reflect the
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This document is available to the public through the National Technical Informa-
tion Service, Springfield, Virginia 22161.

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                               DISCLAIMER

     This report has been reviewed by the Industrial  Environmental
Research Laboratory, U.  S.  Environmental  Protection Agency, and approved
for publication.  Approval  does not signify that the contents necessarily
reflect the views and policies  of the U.  S.  Environmental  Protection
Agency, nor does mention of trade names  or commercial  products constitute
endorsement or recommendation  for use.

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                                 ABSTRACT
     The report gives results of a comparative multimedia assessment of
coal versus oil firing in a controlled industrial  boiler.  Relative
environmental, energy, economic, and societal  impacts were identified.
Comprehensive sampling and analyses of gaseous, liquid, and solid emis-
sions from the boiler and its control  equipment were conducted to identify
criteria pollutants and other species.  Major  conclusions include:  (1)
While the quantity, of particulates from oil  firing is considerably  less
than from coal firing, the particles are generally smaller and more
difficult to remove, and the concentration of  particulates in  the treated
flue gas from oil  firing exceeded that from coal  firing.   (2)  NOX and CO
emissions during coal firing were about triple those during oil  firing.
(3) Sulfate emissions from the boiler during coal  firing  were  about
triple those during oil firing; however, at the outlet of the  control
equipment, sulfate concentrations were essentially identical.   (4)  Most
trace element emissions (except vanadium, cadmium, lead,  cobalt,  nickel,
and copper) were higher during coal firing.   (5)  Oil  firing produces
cadmium burdens in vegetation approaching levels  which are injurious to
cattle.  (6) The assessment generally supports the national  energy  plan
for increased use of coal  by projecting that the  environmental  insult from
controlled coal firing is not significantly different from that from oil
firing.
     This report was submitted in fulfillment  of  Contract Number  68-02-2613,
Task 8 by TRW Environmental  Engineering Division  under the sponsorship  of
the U.S. Environmental Protection Agency.  This report covers  a period  from
October 24, 1977 to May 5, 1978, and work was  completed as of  May 5, 1978.
                                   11

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                                CONTENTS


Abstract	    i1"1"

Abbreviations   	      v

Acknowledgments   	     vi


     1.    Introduction	    1-1

     2.    Summary and Conclusions	    2-1

     3.    Test Setting	    3-1

     4.    Comparative Assessment of Coal  and Oil Firing in an
          Industrial  Boiler 	    4-1

     5.    Comparative Environmental  Impact Assessment  	    5-1
                                  IV

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                            LIST OF ABBREVIATIONS





acm/min --  Actual Cubic Meters Per Minute



ACFM    —  Actual Cubic Feet  Per Minute



DSCM    --  Dry Standard Cubic Meters



ESCA    --  Electron Spectroscopy for  Chemical Analyses



FGD     --  Flue  Gas Desul furization



ICPOES  --  Inductively Coupled Plasma  Optical Emission  Spectroscopy



MATE    --  Minimum Acute  Toxicity Effluent



NAAQS   --  National Ambient Air Quality  Standards



NSPS    --  New Source Performance Standards



SSMS    --  Spark Source Mass  Spectrometry



TSP     --  Total  Suspended Particulate

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                          ACKNOWLEDGMENTS

     The cooperation of the Firestone Tire and Rubber Company and FMC
is gratefully acknowledged.  We are particularly indebted to Gary Wamsley
of Firestone and Carl  Legatski  of FMC, without whose cooperation this
assessment could not have been  completed.
                               VI

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                                  SECTION I
                                 INTRODUCTION
      A comparative multimedia assessment of coal  firing and oil  firing
 In an industrial boiler was conducted.  Extensive sampling and analysis
 of all major gaseous, liquid, and solid emissions and effluents  was done.
 The test boiler was a dual fuel  10 MW equivalent  unit that is  capable of
 burning both coal and oil.  During the tests  conducted for this  study the
 boiler burned either exclusively coal  or oil, although it can  burn  both
 fuels simultaneously if required.  The boiler is  equipped with a pilot
 double-alkali flue gas desulfurization (FGD)  unit designed to  treat
 approximately 30% of the total  flue gas, approximately 3 MW equivalent.
 During the tests, however, the  FGD was processing only about 11-14% (13%
 average) of the total when coal  was fired and 23-32% (25% average)  when
 oil  was burned.  This corresponds to approximately 1.3 MW and  2.5 MW,
 respectively.  Because the FGD was operating  at less than design capacity,
 there is some question about  the typical ness  of the  test results.   That
 is,  the pilot unit may have been performing better than  full size commercial
 versions will.
      The assessment consists  of  several  parts.  First,  comprehensive
 emissions  assessments of each fuel  were  conducted.   These assessments
 consist of detailed examinations  of gaseous,  liquid  and  solid  emissions
 and  effluents considering  both pre-  and  post-scrubber  emissions  for each
 fuel.   The emissions to  all  three media  were  determined for the
 case  where no FGD was present and for  the case where an  FGD  capable of
 scrubbing  100%  of the flue  gas was  present.   The  comprehensive emissions
 assessment also  consisted  of an  examination of the effects  and
 efficiencies  of  the scrubber for  both  fuels.
      These  comprehensive emissions assessments were  used  to  develop a
 comparative emissions  assessment.  This assessment examines  the  differences
 in the quantities  and  character of the emissions  resulting  from  the com-
 bustion of  each  fuel.  In this case  the primary emphasis  was on  the
 emissions and effluents resulting from the burning of each fuel where 100%
 scrubbing capacity  was available.  This part of the  project was  concerned
with determining the  emissions resulting from each fuel with emission
                                    1-1

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 controls in place.   Of special  concern was  the cross-media  impacts  of
 each fuel.
      On the basis of the  emissions assessments a comparative  environ-
 mental, societal and energy  impact assessment was developed.  The emphasis
 here was on the  relative  impacts of each fuel assuming full flue gas
 desulfurization.  The  uncertainties inherent in these types of  analyses
 dictated that the differences in, rather than the absolute  magnitude  of
 these  impacts, be considered.
     The report consists of three volumes.   Volume I is an Executive
Summary which summarizes the major results  and conclusions of the study.
This volume, Volume  II, presents the comparative assessments.   Included
are a description of the test setting,  the  comparative emissions assess-
ment, and the comparative  environmental  societal  and energy impact assessment
Volume III  contains  the comprehensive  assessments  and appendices and includes
detailed descriptions of the test site,  the test  protocol  and  a  detailed
presentation of data.
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                                SECTION 2

                         SUMMARY AND CONCLUSIONS

     A comparative assessment of coal  and oil  firing in a  controlled  indus-

trial boiler was conducted.  The comprehensive emissions assessments  for

each fuel  were used to develop a comparative emissions assessment.  On  the

basis of the emissions assessment a comparative environmental  assessment

was developed.

    The following is a list of the major conclusions resulting from the

comparative and environmental assessments;

COMPARATIVE EMISSIONS ASSESSMENT

     e  Uncontrolled emissions of criteria pollutants produced during coal
        firing correspond well with emission factors from  AP-42.   This
        observation does not generally hold true for oil-fired emissions.
        NOx emissions from oil firing were nearly 23% lower than  the  AP-42
        emission factor, although they appear  to be within the normal range
        for similar industrial units.   CO emissions from oil  firing were
        nearly 63% lower than the AP-42 emission factor.  Oil-fired SO- and
        total hydrocarbons correspond well with their respective  AP-42
        emission factors.  Particulate emissions from oil  firing, in  the
        absence of coal  ash contamination, are approximately twice  the  value
        tabulated in AP-42.

     e  NOx emissions increased with increasing load for both coal  and  oil
        firing, as expected.  Available data indicate that for boiler loadings
        between 90 and 100%, NCx emissions from coal firing are
        approximately three times greater than from oil firing.

     e  Observed reductions of NOx emissions for coal firing and  early  oil
        firing tests appear to be due, at least in part, to air leakage into
        the scrubber outlet sampling line.  Data from later oil firing  tests,
        not known to be subject to leakage problems, indicate that  NOx
        removal across the scrubber is on the  order of  ?.%.

     8  Uncontrolled CO emissions from coal firing were 15.9 ng/J (0.04 1b/
        MM Btu) while those from oil firing were 5.47 ng/J (0.01  1b/MM  Btu).
        This factor of three difference is at  variance with AP-42 data
        indicating that CO emissions from oil  firing are 23% lower  than those
        from coal  firing.  Apparent reductions in CO emissions across the
        scrubber are not considered significant due to air leakage  in the
        sampling train and the low sensitivity of analysis at the measured
        CO concentrations.

     e  Uncontrolled S02 emission rates during coal and oil firing were


                                   2-1

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   1112 ng/J (2.59 Ib/MM Btu) and 993 ng/J (2.31  1 b/MM Btu),  respectively.
   Removal data indicate an average scrubber removal  efficiency of 97%
   during both coal and oil firing.  Controlled  S02  emissions for  coal
   and oil firing were 36.3 ng/J (0.08 1b/MM Btu)  and 26.8  ng/J (0.06
   1b/MM Btu), respectively, which are lower than  either  existing  or
   proposed NSPS limitations.

i   Particulate loadings prior to scrubbing were  2951  ng/J (6.86 1 b/MM Btu)
   during coal  firing and 59.0 ng/J (0.14 1b/MM  Btu)  during oil firing,
   in the absence of coal ash contamination.  Scrubbing removed 99% of
   the coal-fired particulates and 75% of the oil-fired particulates.
  The lower removal  efficiency obtained during  oil  firing  is attributed
  to the increased fraction of particles smaller  than 3  ym;  at least
  21% of the uncontrolled oil-fired particulates  are less  than 3  ym
  while substantially less than 1% of uncontrolled  coal-fired particulates
  are under 3 ym in diameter.

  There appears  to be a net increase in emission  rates across the
  scrubber  for coal-fired particulates less than  3 ym in size. This
  net increase can be attributed to the poor removal efficiency of the
  scrubber  for fine particulates, and to the sodium  bisulfate (NaHS04)
  and calcium  sulfite hemihydrate (CaS03-l/2 H20)  particulates generated
  by the  scrubber.  Both NaHS04 and CaS03-l/2 HgO have been  identified
  at  the  scrubber  outlet but not at the inlet.  Although a very slight
  increase  in  oil-fired particulates in the 1-3 ym  range was observed,
  a net decrease  in  particulates less than 3 ym was  observed during  oil
  firing.   Based on  the results of coal  firing  tests, it appears  reason-
  able  that  scrubber generated particulates were  present in  the scrubber
  outlet  stream during oil  firing but that the  high  fine particulate
  loading associated with oil  firing masked detection of these materials.

  Of  the 22 major  trace elements analyzed in the  flue gas  stream
  during coal  firing,  18 exceed their KATE values at the scrubber
  inlet and 4  at the scrubber outlet.  Similarly, for oil  firing,
  11  exceeded  their  MATE values at the scrubber inlet while  5  exceeded
  their MATE values  at the scrubber outlet.   Elements exceeding their
  MATE values  at the scrubber outlet and which are common  to  both
  fuels are arsenic,  chromium and nickel.   Additionally, iron  exceeded
  its MATE value at  the scrubber outlet  during coal  firing as  did
  cadmium and  vanadium during oil  firing.   The overall removal of
  trace elements across  the  scrubber is  99% for coal  firing  and 87%
  for oil firing.

  Polycyclic organic material  (POM)  was  not  found in  the scrubber
  inlet or outlet  at detection  limits  of 0.3  yg/rn^ for either coal or
 oil  firing.  MATE  values  for  most  POM's are greater than this detec-
  tion limit.  However,  since  the MATE values for at  least two POM
 compounds -  benzo(a)pyrene  and  dibenz(a,h)anthracene -  are less  than
 0.3 yg/n,3, additional  GC/MS analyses at higher sensitivity  would  be
 required to conclusively preclude  the  presence of all  POM's  at MATE
 levels.

 Beryllium emissions after scrubbing were less  than  or equal to its
 MATE value for coal and oil firing.  At the measured emission concen-
 trations  the National Standard for Hazardous Air Pollutants limitation

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   of 10 grams beryllium per day would only be exceeded by boilers of
   50 MW capacity for coal  firing and 100 MW capacity for oil  firing.

t  The combined waste water stream from the boiler operation may
   not pose an environmental hazard in terms of organic materials
   since the discharge concentrations of organics are well  below their
   MATE values for both coal and oil  firing.  The same conclusion may
   be drawn for inorganic compounds with the exception of cobalt, nickel,
   copper and cadmium for coal  firing, and nickel and copper for oil
   firing, since these metals may exceed their MATE values.

•  Organic emissions for coal and oil firing were very similar.   Total
   organic emissions were less than 9 ng/J (0.02 1b/MM Btu)  for  both
   tests, and these emissions appear  to be primarily C] to Cg  hydrocarbons
   and organics heavier then C-\§.  hhile uncontrolled emission rates  for
   both coal and oil firing are low,  emissions of these organics were
   further reduced by about 85% in the scrubber unit.

e  The organic compounds identified in the gas samples from  both coal
   and oil firing were generally not  representative of combustion-
   generated organic materials, but were compounds associated  with
   materials used in the sampling equipment and in various analytical
   procedures.  This again confirms the low level of organic emissions.

f  The relatively poor removal  efficiency (approximately 30% in  both
   oil and coal-fired tests) for $03  across the scrubber is  an indication
   that $03 is either present as very fine aerosols in the scrubber
   inlet, or is converted to very fine aerosols in the flue  gas  stream
   as it is rapidly cooled inside the scrubber-

o  The fraction of fuel sulfur converted to $03 during oil  firing was
   50 to 75% higher than during coal  firing.  In contrast, the fraction
   of fuel sulfur converted to sulfates during coal firing was twice
   that during oil firing.

o  Sulfates are more efficiently removed than S03 (60% removal for oil
   firing and 88% for coal  firing).  This indicated that S0^=  is probably
   associated with the larger particulates which are more efficiently
   removed than smaller particulates.  The higher sulfate removal from
   the coal flue gases is explained by the higher particulate  loading
   during coal firing.

•  Uncontrolled chloride and fluoride loadings were higher during coal
   firing (5 and 0.2 ng/J,  respectively) than during oil firing  (0.2  and
   0.02 ng/J, respectively).  This was attributed, in the case of
   chlorides, to a higher fuel  chlorine content for coal than  for oil.
   Chlorides were removed with better than 99% efficiency from coal flue
   gases and with about 51% efficiency from oil flue gases.   This
   difference was attributed to the higher particulate removal efficiency
   for coal particulates.  Fluorides  were removed with greater than 86%
   and about 87% efficiency for coal  and oil firing, respectively.
   Uncontrolled nitrate emissions were 0.08 ng/J during oil  firing, and
   nitrates were removed from oil flue gases with 57% efficiency.
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     o  The scrubber cake produced during coal  firing contained 29% coal
        fly ash; during oil firing it contained 1% oil fly ash.  The
        trace element concentrations in the coal-fired scrubber cake
        exceeded their health based MATE values, with the exception of
        boron.  In the oil-fired scrubber cake, all trace elements except
        antimony, boron, molybdenum and zinc exceeded their health based
        MATE values.  All ecology based MATE values were exceeded by
        trace element concentrations during both oil  and coal  firing.
        Because the trace elements may leach from  the disposed scrubber
        cake, these solid wastes must be disposed  of  in specially designed
        landfills,

COMPARATIVE ENVIRONMENTAL ASSESSMENT

     •   The difference in environmental  insult expected to result between
        coal  and oil  combustion emissions from a single controlled 10 MW
        industrial  boiler is insignificant.  This  is  because:  1) there
        are only slight differences in the emissions  levels of the pollu-
        tants, or 2)  the absolute impact of either fuel  use is insignifi-
        cant .

     •   The environmental impacts of emissions from a cluster of  controlled
        10 MW  industrial  boilers are potentially significant.  The impacts
        include health effects, material damages, and ecological  effects
        from  high levels of S02, NOx and suspended particulate matter; health
        effects and ecological  damage due to trace metal  accumulation  in
        soils  and plants; and aesthetic degradation from visibility  reduction
        and waste disposal sites.

     0   The risk of environmental damage from emissions  of controlled  in-
        dustrial boilers, whether oil  or coal-fired, is  considerably  less
        than  the risk posed by emissions from uncontrolled industrial
        boilers.  It  should be noted that this finding is  based on an  ex-
        ceptional  facility.  The reference facility is very well  run and
        maintained,  and emissions are low.

     •   The environmental acceptability  of a cluster of  controlled indus-
        trial  boiler  emissions  is more dependent on site  specific  factors
        (e.g.,  background pollution levels,  location and  number of other
        sources) than  type of fuel  utilized.   Careful  control  of  the site
        specific factors  can avert  potential  environmental  damages and
        generally compensate for any differential  effects  arising  between
        the use  of coal  or oil .

     •   With the possible exception  of ambient  levels  of NO, the risk of
        violating the  NAAQS  due  to  operation of clusters of controlled
        industrial boilers  is essentially the same  whether the fuel  combusted
        is  coal  or oil.   Based on tests of the reference 10 MW boiler  (which
       was not  controlled for NOx emissions), localized  NOx concentrations
       produced by coal  firing are estimated to be twice the level of  that
       resulting from oil firing, and greater than the levels  permitted  by
       the NAAQS for 24-hour and one year averaging periods.
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     9  Short term C3 hour and 24 hour averaging times) maximum ambient
        concentrations present the most significant air pollution problem
        resulting from operation of controlled industrial  boilers.  Restric-
        tions imposed by the NAAQS for short term ambient  levels would be
        most constraining to boiler operation in areas where air quality is
        already only marginally acceptable.  Expected long term concentra-
        tions arising from boiler emissions would not appear to pose a risk
        for violation of the NAAQS.

     0  Coal firing appears to produce a greater enrichment of trace elements
        in the flue gas desulfurization cake than oil firing produces.  How-
        ever, the scrubber cake resulting from either coal  or oil  firing
        contains sufficient amounts of heavy metals and toxic substances to
        pose difficult waste disposal  problems.

     The impact categories considered  include public  health,  ecology,

societal, economic, and energy.  The specific findings with respect to

the various impact categories are summarized briefly  below.
Health Effects--
        Based on the Lundy/Grahn Model  for health effects  associated with
        suspended sulfate levels, regional  emissions  levels  from  controlled
        oil or coal-fired industrial  boilers would not  be  expected  to cause
        a significant impact on regional  health.   Emissions  from  uncontrolled
        boilers would result in substantially greater levels  of regional sus-
        pended sulfate levels, and the  associated health effects  would  be  an
        order of magnitude greater.

        Emissions from clusters of controlled industrial boilers  are expected
        to cause significant adverse health effects in  a localized  area  near
        the plant cluster.  Oil firing  would be expected to  result  in local-
        ized health effects about one third less  severe than  those  resulting
        from coal firing.  The increase in mortality  attributable to either
        controlled coal  or oil firing is  appreciably  less  than that associ-
        ated with uncontrolled industrial  boilers emitting higher levels of
        particulates and SOx.

        The impact of solid waste generation on health  is  essentially the
        same for controlled coal  firing and oil  firing, provided  suitable
        land disposal  techniques  are employed to  assure minimal leaching
        rates and migration of trace elements to  groundwater  and  the ter-
        restrial  environment.

        Addition of cadmium to a  localized environment  in  the quantities
        produced by clusters of controlled industrial boilers may
        result in cadmium concentrations  in plants approaching levels in-
        jurious to man.   Because cigarettes contain significant cadmium
        levels, smokers  are more apt to achieve thresholds of observable
        symptoms for cadmium exposure when consuming  additional cadmium via
        the food chain.
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        The concentration  of metals  in  runoff waters due  to controlled  oil
        firing is  predicted  to  be  slightly  less  than that occurring  from
        controlled coal  firing;  in either case,  hazard  to human  health  by
        drinking water  is  remote.

        Trace element  emissions  from clusters of controlled  industrial
        boilers may significantly  increase  local  background  levels  in
        drinking water,  plant tissue,  soil, and  the atmosphere;  however,
        the expected increases  in  the levels of  such elements  are generally
        several orders  of  magnitude less  than allowable exposure levels.
        Oil  firing is  estimated  to cause  cadmium burdens in  plants  approach-
        ing levels injurious to  man, and  coal firing may produce plant
        concentrations  of  molybdenum which  are  injurious to  cattle.
Ecology--
     e  The potential for crop damage from either controlled coal  firing
        or oil  firing depends greatly on ambient levels of NOx,  S02,  or
        trace element soil concentrations.  If such levels are presently
        high, localized plant damage would be expected to occur  within a
        1  to 2  km range from a controlled boiler cluster.  Leaf  destruc-
        tion from S02 exposure would be expected to be slightly  more  severe
        in the  vicinity of a cluster of controlled boilers which are  coal-
        fired as opposed to oil-fired.  For boilers uncontrolled for  NOx
        emissions, plant damage would be expected to be significantly
        greater in the vicinity of the coal-fired cluster, owing to higher
        levels  of ambient NOx produced.  The likelihood of damage  occurring
        in plants due to emissions of trace elements from either controlled
        oil  or  coal  firing is remote, with the possible exception  of  injury
        due to  elevated levels of molybdenum and cadmium in plant  tissue
        resulting from coal firing and oil  firing, respectively.

     o  The effect of emissions from industrial  boilers on trace element
        burdens in plants is greater via soil  uptake than by foliar inter-
        ception.  This is because soil  concentrations  are the result  of
        accumulative long term exposure to boiler emissions whereas foliar
        exposure is  determined by the immediate  deposition rate  of emissions
        on the  plant surface and the lifetime  of the leaf.

     •   The  impact of fossil  fuel  combustion  in  controlled  oil or  coal-
        fired boilers on plant damage via  acid precipitation  would be
        insignificant.   The levels  of suspended  sulfate (the  origin
        of acid  rain) would be essentially the same  whether the controlled
        boilers  are  coal  or oil-fired.

    ft  Measurement  and  analyses of  leaching rates at experimental  waste
       disposal  sites  indicate  that  landfills of untreated flue  gas desul-
       furization system  scrubber cake can be constructed such that signi-
       ficant adverse  impacts will not occur.
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Societal--
     •  The Impact of boiler emissions on corrosion in the local  area near
        a cluster of controlled industrial boilers would be significant.
        The corrosion rate would be slightly greater when the boilers are
        coal-fired.  However, the extent of this overall  impact (oil  or coal)
        is minor compared to that which occurs when industrial  boilers are
        uncontrolled.

     •  The increase in annual TSP and soiling damages in the vicinity of a
        cluster of controlled industrial  boilers could result in  additional
        cleaning and maintenance costs about 10 to 15% greater  than that
        already experienced in a typical  urban area.  The cleaning costs
        may-be slightly greater when the boilers are coal-fired.

     •  Emissions of particulate matter from controlled industrial  boilers
        may result in visibi-lity reduction.  This aesthetic degradation
        would occur in a localized area near the boiler cluster,  and  would
        occur to essentially the same extent whether the  boilers  are  oil
        or coal fired.

     e  Total  land disposal requirements for scrubber cake waste  generated
        by controlled coal firing are three times greater than  those  for
        controlled oil firing.  Waste disposal  of the scrubber  wastes may
        result in significant depreciation of property value and  aesthetic
        degredation in the area of the disposal  site.  These impacts  would
        5e more severe if boilers use coal rather than oil.
 Economic--
     o  The differential direct economic impact between emissions from
        coal  firing and oil firing is generally insignificant with the
        possible exception of some differences occurring in a limited
        localized area near clusters of boilers.  The extent of the
        incremental direct economic impacts is proportional to the
        extent of the incremental environmental damages.

     o  Differential second order economic impacts, such as changes in
        hospital employment, alteration of taxes, or changes in income,
        are expected to be insignificant between emissions from con-
        trolled oil and coal-fired industrial  boilers
Energy--
        At the present time, the comparative assessment of the effects of
        emissions from controlled oil  and coal-fired industrial  boilers
        tends to support the national  energy plan for intensified utilization
        of coal.  The fuel  choice of oil  or coal  is a relatively minor issue
        concerning the environmental acceptability of controlled industrial
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 boilers;  other  site specific and plant design factors exert a great-
 er  effect on  environmental damages.  While it was shown that fuel
 choice  caused significant differences in impacts to occur when the
 boiler  is uncontrolled for NOx emissions, these differences may be
 mitigated by  the addition of NOx control technologies with minimal
 overall cost  impact.

 As concern for  environmental protection increases, the issue may
 not be  whether  coal or oil use is more environmentally acceptable,
 but whether the increasing use of fossil fuels can be continued at
 the present levels of control technology without potential long-
 term damages.   If it is found that long-term effects of pollution
 (e.g.,  trace metals accumulation, lake acidity from acid rains)
 from fossil  fuel combustion and other sources are environmentally
 unacceptable, it is clear that energy use may be affected.  Energy
cost will  increase with increasing control  requirements, possibly
to the level  where other cleaner forms of energy become more
competitive.

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                                 SECTION 3
                               TEST SETTING

     The host for this assessment was the Pottstown, Pennsylvania plant of
the Firestone Tire and Rubber Company.  Boiler No. 4, one of four used to
supply process steam to the plant, was tested.  The boiler burns either coal
or oil and has a pilot FMC double alkali flue gas desulfurization system
designed to treat approximately one-third of the boiler's flue gas.
     The excellent cooperation and assistance from the Firestone Tire and
Rubber Company and FMC was invaluable in performing this assessment.
     The test boiler (No. 4) is one of four comprising a steam plant  which
supplies process steam and heating steam for the facility.  The boiler is
one of three which operates at a fairly constant rate of 45,400 kg/hr
(100,000 Ib/hr) of steam.  Process steam demand is relatively steady, since
the plant operates 24 hours per day, seven days per week.  Fluctuations in
heating load are satisfied by either boosting steam generation rates  on
these boilers or by operating the fourth boiler (No. 1).  The steam gener-
ation rate of Boiler No. 1 varies from zero to approximately 22,700 kg/hr
(50,000 Ib/hr) of steam.  A schematic of the steam plant is shown in
Fi gure 3-1 .
     Boiler No. 4 is a once-through Babcock and Wilcox Type P-22 EL,  inte-
gral furnace.  Installed in 1958 and originally designed as a coal-fired
unit, it was converted to fire either coal  or fuel oil in 1967.  The  change-
over from one fuel to the other can be accomplished in less than thirty
minutes.  (See Section 3, Volume III of this report for additional  detail.)
     The two fuels are usually not burned simultaneously except when  con-
verting from oil  to coal  firing.  The coal  is ignited by continuing oil
firing until  a stable coal  flame is obtained.  Oil and coal can be  fired
simulataneously to maintain acceptable steam generation rates if coal with
a  low heat content is burned.
     The boiler uses either Number 6 fuel  oil or Eastern bituminous coal.
Currently there are no fuel oil  specifications.  Therefore, sulfur and heat
content of the oil vary with supplier.  The coal is required to meet  CLASS
II, Group 2 of ASTM D388.  Normally the coal used is mined in Pennsylvania.

                                    3-1

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                              MANUFACTURING
                              AND WAREHOUSE
Figure  3-1.   Industrial  site plant  layout.
                             3-2

-------
However, coal was purchased from a mine in Kentucky during the 1978 coal
strike.
     An air preheater is located in the flue gas plenum directly downstream
of the boiler..  This gas-to-gas heat exchange recovers approximately 4.2
gigajoules/hr (4 million BTU/hr) when the boiler is operating at full  load.
EXHAUST GAS  CLEANING
     The flue gases are treated by an air pollution control  system.  The
air pollution control equipment consists of multiclone units and a pilot
FGD unit.  All of the flue gas passes through the multiclones.  The stream
then is split and two-thirds of the flue gas ducted to the stack.   The
other one-third is ducted to the pilot FGD system.  The boiler has no  NO
                                                                       X
controls.
     The characteristics and volume of fly-ash collected by the multiclone
unit vary significantly depending upon the type and composition of the fuel.
During oil firing, very little fly-ash leaves the boiler.   During  coal
firing, a large amount reaches the multiclones.
                  \
     The collection efficiency of the multiclone varies as a function  of
the particle  size distribution and grain loading.  Typically, multiclones
remove 90% of those particles with diameters 10y and greater, and  50%  to
80% of those  particles with diameters 3y and greater.  The collection  effi-
ciency of multiclones drops off rapidly for particles less than 3y diameter.
     Fly-ash  is periodically removed and transported to an on-site landfill
for final disposal.
FLUE GAS DESULFURIZATION SYSTEM
     The flue gas desulfurization (FGD) system was designed and manufactured
by FMC Corporation.  The FGD system is a pilot unit designed to handle 280
acm/min (10,000 ACFM) of flue gas, which is approximately one-third of
the volume of the flue gas produced by the boiler.
     Figure 3-2 is the basic flow diagram of the FMC FGD system as it  is
applied at this site.
     The flue gas (Stream 1) is withdrawn downstream of the boiler on  the
exit side of the multiclone dust collectors.  During oil  firing the partic-
ulate loading to the scrubber is low.   During coal  firing  the multiclones

                                    3-3

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                                                     MESH MIST EL
oo
I
                                                                                                     SLURRY
                                                                                                    THICKENER
       LEGEND:
          BOILER  FLUE GAS TO SCRUBBER
          SCRUBBER  OUTLET TO ATMOSPHERE
          SOLID WASTE TO LANDFILL
          ABSORBENT  SOLUTION TO SCRUBBER
          ABSORBENT  SOLUTION TO REGENERATION
          SODIUM  CARBONATE MAKEUP
          REGENERATION SOLUTION
          REGENERATED SCRUBBER SOLUTION
          CONCENTRATED SLURRY
          RETURNED  SCRUBBER SOLUTION
                      Figure  3-2.   Flow diagram  of the FMC  flue gas  desulfurization unit.

-------
do not achieve complete fly-ash removal.  Therefore, the fly-ash loading
in the gas stream inlet to the scrubber is substantially higher than
during oil-firing.  The FGD system was designed to operate with or without
fly-ash, and can be operated without any mechanical  changes on either fuel.
     Upon entering the FGD unit the flue gases are contacted with a slightly
acidic scrubbing solution (stream 4) and the sulfur dioxide is absorbed.
The process utilizes a sodium sulfite-sodium bisulfite solution as the
absorbent.  The particulate matter and sulfur dioxide are removed at the
scrubber  throat and carried away in the scrubbing solution.
     A bleed stream (stream 5) of the scrubbing solution is removed from
the system at a rate which will keep the pH of the solution in an acceptable
range.  The bleed stream is reacted with calcium hydroxide in a short reten-
tion time, agitated vessel to regenerate the sodium sulfite.
     The  slurry of precipitated sulfur compounds (stream 8) is concentrated
and then  pumped to a rotary drum filter where the essentially clear liquid
and solid waste products are separated.  The clear liquid (stream 10) is
returned  to the system for further utilization.  The solid wastes, in the
form of filter cake containing 40% (by weight) water (stream 3). are
removed from the rotary drum filter and conveyed to a storage bin to await
transportation to the dump site.  Because of the heavy particulate loading,
more filter cake is produced during coal firing than during oil firing.
     The  on-site landfill, which is the final disposal  facility for all  of
the solid waste generated at the facility, has several  test wells from which
samples are collected every three months and sent to an independent labora-
tory for  analysis.  In addition, monthly tests are conducted by plant per-
sonnel to monitor sodium and specific conductivity.  With permission of the
Pennsylvania Department of Environmental Resources, this site is being used
as an experimental disposal  area for the filter cake from the FMC unit.
BOILER SLOWDOWN
     There are two blowdown sources in the boiler system: the steam drum
and the mud drum.  There is a continuous blowdown from the steam drum
which keeps the level  of suspended solids in the boiler feedwater within an
                                    3-5

-------
 acceptable range.  Tests of the steam drum  blowdown  effluent  are  made  every
 four hours and adjustments to blowdown rate  are  made accordingly.   The mud
 drum is blown once per shift.
      The effluent from both blowdowns is  sent  to the same  pit that  collects
 effluent from the water pretreatment unit.
 TEST DESCRIPTION
      Multi-media emission tests were conducted on Boiler No.  4 of the  Fire-
 stone Plant from 27 September through 8 October  1977.   Solid, liquid and
 gaseous emission streams were sampled during coal  firing and  during oil
 firing  to  obtain data  for the assessments.   Flue gas sampling was
 conducted  before and after the pilot flue gas  desulfurization
 unit to establish which pollutants  are removed,  modified,  or  produced
 by the  control  device.
      Emissions  were characterized  using EPA's  phased approach to  sampling
 and analysis.   This approach  utilizes two separate levels  of  sampling  and
 analytical  effort (Level  1  and Level  2).  Level  1  is a  sampling and analysis
 procedure  accurate within a  factor  of about  3.   This level  provides pre-
 liminary assessment data and identified problem  areas and  information  gaps
 which are  then  used to  form the Level  2 sampling and analysis effort.
 Level 2  provides  more  accurate detailed information  that confirms and
 expands  the information gathered in Level 1.   The methods  and procedures
 used for Level  1  sampling and analysis are  documented in the  manual, "Com-
 bustion  Source  Assessment Methods and Procedures Manual for Sampling and
 Analysis", September 1977.  The Level  2 methods  and  procedures  included
 "state-of-the-art"  techniques as adapted to  the  needs of this  site.
 They are delineated in  Volume III Appendices B and C.
     Normally all  Level  1  samples are  analyzed and evaluated  before moving
 to  Level 2.  Because of program time-constraints,  the Level 1   and Level 2
 samples  were obtained during  the same  test period.   However,  analysis of
 the samples did proceed  in a  phased manner except where sample degradation
was of concern.    In those cases, Level  2 analyses were performed on
the samples prior to completion of Level 1  analyses.
     The industrial boiler assessment  tests  were  conducted  during  both  coal
and oil  firing.    Figure 3-3,  the system schematic for Boiler No. 4,  includes

                                    3-6

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                                                   EXHAUST
                                                   GAS TO STACK
                 EXHAUST GAS
                 TO STACK
  FEEDWATER
    FROM
PRETREATMENT
    UNIT —
                               TO MUNICIPAL
                               SEWAGE
                               TREATMENT
LEGEND

1 - FUEL
2 - SLOWDOWN
3- FLYASI
4 - EXHAUST GAS
  FGD INLET
5 - EXHAUST GAS
  FGD OUTLET
6 - SCRUBBER CAKE
7 - MAKE UPWATER
8 - SCRUBBER FEED SOI IDS
      Figure 3-3.   Boiler system schematic  and  sampling
                       locations.
                                     3-7

-------
 the pilot  flue  gas  desulfurization unit and shows all  sample  locations.
 Parameters sampled  during coal and oil firing at each  location  are  summarized
 in Table 3-1.   The  table also identifies the sampling  and analysis  method
 used to characterize  each parameter.  Volume III contains a more  complete
 description of  the  sampling and analysis activities.
      The boiler exhaust  gas was sampled at the inlet and outlet of  the
 desulfurization unit.  Integrated bag samples were taken at both  points  in
 each test.
      Continuous monitors for CO, N0/N0x, S02, and total hydrocarbons  (as
 CH4) were  installed in the system as shown in Figure 3-4 and  operated during
 all tests.  A Thermal Electron Corporation (TECO) gas  conditioner was used
 to remove  condensate  and particulate from the flue gas prior  to entering
 the CO, NOX, and  S02  analyzers.  Model numbers for all analyzers are  shown
 in Table 3-1 .
      The Source Assessment Sampling System (SASS) was  used to collect both
 gaseous and particulate emission samples at the inlet  and outlet for  Level 1
 organic and inorganic analysis.  The train was run for 6 to 8 hours until a
 minimum of 30 cubic meters of gas had been collected.
      Previous sampling and analysis efforts had indicated possible  inter-
 ference of SASS train materials on certain organic and inorganic analysis
 when at the lower detection limits of Level 2 methods.  To avoid this possi-
 bility,  all glass sampling trains were used to collect Level  2 samples.
 Two Method  5 sampling trains were modified for Level  2 organic and  inor-
 ganic sample acquisition.  Both trains sample approximately 10 cubic meters
 of  flue  gas during a 6-  to 8-hour run time.  The Level 2 trains were  run
 at  the  inlet and outlet of the FGD unit for both coal  and oil  firing.
     A  controlled condensate train (Goksoyr-Ross) was  used at each  location
 during  coal and  oil  firing to  obtain samples  for S02,  S03 (as  H2S04), par-
 ticulate sulfate, HC1  and HF .
     During Level  2  test  runs,  Anderson Cascade impactors were used to
obtain particulate samples  by  particle size fraction.
                                   3-8

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          TABLE 3-1.  PARAMETERS SAMPLED FOR COAL AND OIL FIRING
Location    Parameter
                        Sampling Method
                         Analysis
  4 & 5
FUEL (coal  & oil)
  C, H, N,  S, ash,
  moisture, heating
  value
  inorganics

COMBINED SLOWDOWN
  alkalinity/acidity
  PH
  conducti vi ty
  hardness
  TSS
  nitrate
  sulfate
  sulfite
  phosphate
  ammonia
  nitrogen
  organics

FLYASH
  i norganics
  organics

FLUE GAS (inlet & out!
  CO
              C02
              NO/N02/NOX
              N2,02

              S02
              S02/S03
              H2S04 HCI  HF
              participate  sulfate
              total  hydrocarbons
              (as CH4)
              C]  -  CG  Organics

              particulate  and
               vapor
              particulate  sizing
                                    Grab
                                    Composite dipper
                                    Composite grab
                        Continuous,  Beckman
                        Model  400
                        Grab  (bag)
                        SASS

                        Method 5
                        Anderson impactor
                        SASS
                         Ultimate (lab)


                         Level II (lab)

                         On-site HACH kit
                                                           Level  1  &  2  (lab)
                                                           Level  1
                                                           Level  1
                                   2 (lab)
                                   2 (lab)
et)
  Continuous, Beckman    Direct reading
  Model  865
  Grab (bag)
  Grab (bag)
  Continuous, TECO
  Model  10A
  Grab (bag)
  Continuous, TECO
  Model  41
  Goksoyr-Ross
                                               GC  (TCD)  on  site
                                               GC  (TCD)  on  site
                                               Direct  reading
                                               GC  (TCD)  on  site
Direct reading

Level  2 (lab)

Direct reading
                         GC  (FID)  on  site
                         Level  1  (lab)

                         Level  2  (lab)
                         Level  2
                         Level  1
                               (continued]


                                   3-9

-------
                          TABLE 3-1.  (Continued)
 -ocatlon     Parameter	Sampling Method	Analysis	

      6       SCRUBBER CAKE           Composite grab
               inorganics                                   Level 1  & 2  lab)
               organics                                     Level 1  & 2 (lab)

      7       BOILER AND SCRUBBER     Top grab
             MAKEUP WATER
               organics                                     Level 1  (lab)
               inorganics                                   Not required

     8       SCRUBBER MAKEUP         Grab                   Not required
               SOLIDS
     The combined boiler blowdown was sampled using the composite dipper
 method.  Boiler  and  scrubber  makeup  water  were  sampled  by  the  top grab

method.  Samples from each location  received  the analyses  shown  in
Table 3-1 for combined blowdown.  In addition, samples from each location
were extracted with methylene chloride and returned to the lab for further
analysis.

     Composite samples of the fly-ash and scrubber filter cake were collected
per Level 1  procedures and returned  to the lab for analysis.  Grab samples
of the scrubber feed solids were also obtained.
                                   3-10

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EXHAUST
GAS INLET
 FGD UNIT

                   HEAT TRACED SAMPLE LINES,
           CO
       ANALYZER
 NO/NOX
ANALYZER
        EXHAUST
        GAS OUTLET
                                                THC
                                             ANALYZER
                                          GAS CONDITIONER
   S02
ANALYZER
       Figure  3-4,  Flue gas continuous monitor setup.
                            3-11

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                                 SECTION 4

COMPARATIVE ASSESSMENT OF COAL AND OIL FIRING CASES FOR AN INDUSTRIAL BOILER

     This section provides a comprehensive multimedia assessment and
comparison of emissions/effluents associated with coal  and oil  firing in
an industrial boiler equipped with an FGD system.  Data from Level  I/
Level 2 sampling and analyses were utilized to quantitatively determine
and compare emissions in gas, solid and liquid waste streams generated dur-
ing coal and oil firing.  The performance of pollution  control  equipment
during coal and oil firing was evaluated.  Waste stream pollutant concen-
trations during coal and oil firing are compared.with Minimum Acute
Toxicity Effluent (MATE) values, when appropriate, to provide an indication
of risk to public health and ecology.  Simplified air quality models were
used to determine the relative ground level air quality resulting from
uncontrolled and controlled emissions from both fuels.

TEST CONDITIONS
     Five tests were performed on the industrial  boiler at Firestone for
each of two fuels, a high volatile bituminous coal  and  a Number 6 fuel  oil.
Unit loading ranged from 31,800 to 45,400 kg steam per  hour (70,000 to
100,000 pounds per hour) which corresponds to between 70 and 100% of full
load operation for this boiler.  Specific test conditions for both  fuels
are summarized in Table 4-1.  Tabulated fuel  feed rates are nominal,
although their accuracies have been estimated from fuel analyses and steam
production data under the assumption of 90% thermal efficiency.   Nominal
coal feed rates appear to be accurate to within 13%, while oil  feed rates
are accurate to approximately 3%.  Oxygen concentrations presented  in
Table 4-1 were measured in flue gas samples drawn from  the inlet of the
system's wet scrubber unit.  Due to air leakage into upstream ducting
operating at sub-atmospheric pressure and  possibly air leakage into the flue
gas bag sampling system, tabulated oxygen concentrations are not necessar-
ily representative of concentrations at the furnace outlet.  Oxygen con-
centrations of 3 to 4% in the furnace after combustion  are typical  for this
unit during normal  operation; this concentration  range  corresponds  to an
excess air input of approximately 16 to 25%.  Excess air estimates presented

                                   4-1

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                      TABLE  4-1 .   SUMMARY OF TEST CONDITIONS
Test
No.

200
201-1
201-2
201-3
201-4

202-1
202-2
202-3
202-4
203
Steam Production Rate
kg
steam/hr

39,700
44,200
43,100
34,000
40,800

45,400
45,400
44,200
42,200
31,800
Ibs.
steam/hr

87,500
97,500
95,000
75,000
90,000

100,000
100,000
97,500
93,000
70,000
% of Nominal Fuel
Maximum Feed Rate,
Load kg/hr gal/hr
COAL FIRING
87.5 3629
97.5 3629
95.0 3629
75.0 3175
90.0 3629
OIL FIRING
100 900
100 900
97.5 880
93.0 805
70.0 600
% 02 at
Scrubber
Inlet*

7.8
8.2 ,
8.4
8.3
6.7

5.8
6.3
6.1
4.0
Not
Measured
Estimated %
Excess Air,
to Furnace

20
20
20
20
20

21
21
21
21
21
Due to air leaks in ducting upstream of the scrubber inlet, tabulated  02  values  are  not
representative of combustion zone 02 concentrations.  Combustion  zone  02  concentrations
normally range from 3 to 4% for this unit.
                                            02 - CO/2
                                      0.264 N2 - (02 - CO/2)' where °2 was assumed to be
excess air is estimated to be 100 x
3.5% and other species concentrations were computed from fuel  analyses.

-------
in the table were computed assuming an average oxygen concentration of 3.5%
in the furnace after combustion and utilizing ultimate analysis of the
respective fuels.
     Test data relating to flue gas flow rates and scrubber loading are
summarized in Table 4-2.  Flue gas flow rates measured at the scrubber
inlet (expressed as dry standard cubic meters per minute, or dscm/min)  are
presented in the first column.  For discussion in this report,  standard
temperature and pressure are defined as 20°C and one atmosphere,  respec-
tively.   Typical inlet and outlet gas temperatures for the scrubber unit
were 300°F and 125°F, respectively.  Measured flow rates correspond to the
scrubber loading listed in the second column of the table.  An  average
scrubber loading of 96 dscm/min or 54% of design load was maintained during
coal firing while a load of 180 dscm/min or 102% of design load was main-
tained during oil firing.  Differences in scrubber loading for  the two
fuels are due to multiclone malfunction during the test period  which
resulted in an unusually high particulate loading at the scrubber inlet
during coal firing.  This high particulate loading increased the  scrubber
cake production rate per unit volume of flue gas processed and, owing to
fixed capacity scrubber cake disposal facilities, necessitated  a  reduction
in scrubber loading during coal firing.
     Total flue gas flow rates presented in Table 4-2 were computed from
fuel analyses, fuel feed rate data and flue gas oxygen analyses utilizing
the following expression:
              nFG
4.762 (nc + ns)  + .9405  nR  -  3.762  n
          1  - 4.762 (02/100)
where:
     nrr = gm moles of dry effluent/gm of fuel.
      r b

     n.  = gm moles of element j in fuel per gm of fuel.
      J
     0~  - volumetric $2 concentration in percent.
                                   4-3

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                TABLE 4-2.  FRACTION OF FLUE GAS PROCESSED BY
                           THE SCRUBBER DURING EACH TEST
Test No.

200
201-1
201-2
201-3
201-4
Average

202-1
202-2
202-3
202-4
203
Average
Flow Rate
at Scrubber
Inlet,
dscm/min*

99
91
89
98
102
96

193
192
189
155
171
180
% of Design
Load
COAL FIRING
56
51
50
55
58
54
OIL FIRING
109
109
108
88
97
102
Total
Flue Gas
Flow Rate,
dscm/min*

754
761
798
684
706
741

824
850
818
657
537
737
Fraction of
Total Flue Gas
Processed by
the Scrubber

0.13
0.12
0.11
0.14
0.14
0.13

0.24
0.23
0.23
0.24
0.32
0.25















-------
     The scrubber is a pilot unit and, as such, was not sized to process
the entire flue gas output of the furnace.  As indicated in Table 4-2, the
slipstream drawn for scrubber processing represented from 11  to 32% of the
total flue gas generated.
     Ultimate analyses of the feed coal and oil, averaged over the five
tests run with each fuel, are presented in Table 4-3, along with standard
deviations associated with averaging.  The fuel compositions  were essential-
ly constant during the testing.   The oil heat content is about 40% higher
for oil  than for coal, 40,741 vs 29,485 kJ/kg.  To compare ash, sulfur, and
nitrogen concentrations for the two fuels, these values are normalized to a
weight per heat content basis, yielding 3360 ng ash/J for coal  vs 4.9 ng
ash/J for oil, 556 ng S/J for coal vs 481 ng S/J for oil, and 312 ng N/J
for coal vs 88 ng N/J for oil.  Laboratory tests have shown that 30 to 60%
of the fuel nitrogen may be expected to be emitted as NO , as is d'iscussed
                                                        X
later (Reference 1).
     Additional analyses were performed on fuel samples from tests 201-1
(coal) and 202-4 (oil) to determine concentrations of 20 trace  elements
(Ca, Mg, Sb, As, B, Cd, Cr, Co, Cu, Pb, Mn, Mo, Ni, V, Zn, Se,  Sr, Zr, Be,
and Hg) and two minor elements (Fe and Al).  These data are presented in
Table 4-4.  The method employed for analysis of most of these elements was
inductively coupled plasma optical emission spectroscopy (ICPOES) which
is generally considered to be more accurate than spark source mass spec-
trometry (SSMS).  However, a feed coal sample from test 200 was analyzed
for the trace elements boron and beryllium by SSMS.  Oil beryllium was also
analyzed by SSMS on a sample from test 203.  Mercury was analyzed using
cold vapor analysis on samples from tests 200 (coal) and 203 (oil).  Several
of the oil trace elements were below the ICPOES detection limit.  Approxi-
mate values were calculated for these elements by using the concentrations
found at the scrubber inlet, assuming that essentially all of the oil
trace elements reach the scrubber.  As no bottom ash was generated during
oil firing, this assumption should be valid.  The value for oil arsenic
presented in the table, 2 ppm, was also calculated because the value
obtained from ICPOES analysis, 45 ppm, appeared to be unreasonable compared
to both  the SSMS value (0.1  ppm)  and the typical ranges found in the
1iterature.
                                    4-5

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     TABLE 4-3.   SUMMARY OF ULTIMATE FUEL  ANALYSES  (5  TEST  AVERAGES)
Component
Moisture
Carbon
Hydrogen
Nitrogen
Chlorine
Sulfur
Ash
Oxygen
kJ/kg
Coal
Weight %
7.15
72.10
4.28
0.92
0.12
1.64
9.90
3.89
29,485

a
0.86
1.07
0.06
0.07
0.02
0.23
0.85
0.23
459
Oil
Weight %
~o
86.28
10.92
0.36
N.A.X
1.96
0.02
0.46
40, 741 f

at
-
0.39
0.03
0.06
-
0.08
0.004
0.40
-
ta  =  one standard deviation.
 M
   n   -  not analyzed.
*The heat content of the oil burned is nearly constant at this value;
 individual values were not available.
                                  4-6

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  TABLE 4-4.  CONCENTRATION OF MAJOR TRACE  ELEMENTS IN OIL AND  COAL
Element
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Be
Hg
ppm in
Fuel Oil*
5.50
<0.04
0.03**
2.0AA
<0.15
<3.5
2.2
<1 .25
1.40
12.3
2.6**
0.4**
2.9**
16.0
36.5
3.0
**
0.7
0.23
3.5
<0.05
<0.05>;
0.09*X
Typical
RangeA
No data
No data
0.002-0.8
0.0006-1.1
No data
No data
0.002-0.02
No data
No data
0.003-14
No data
0.001-6
<0.1-1 .5
14-68
15-590
No data
0.03-1
No data
No data
No data
No data
0.02-30
Reference


2
2


2


2,6

2
2
7
7
2




2
ppm in
Coalt
770
350
85
137
2.4f
3.5
48
127
72
12,250
85
12
293
37
47
56
73
68
14,000
270
2.3 f
0.1 4Y
Typical
Range'1"''
0-1600
0-959
0.2-8.9
0.5-93
4-115
• 0.1-65
4-144
0.5-43
3-61
0.3-40,000
4-218
6-181
0.4-30
2-80
2-147
6-5,350
0.4-74
No data
0.4-40,700
8-133
0.6-4.1
0.07-0.49
Reference
3,5
3,5
3
2,3
2,4
3
2,4
2,3
2,3
3,5
2,3
3
2,3
2,3
2,3,4
3
3,4

3,5
3
2
2
*  Test 202-4 .
A  Except for V and Ni,  these ranges  are  for U.S. and foreign crude oils.
   Ranges of V and Ni  concentrations  are  for fuel oils.
t  Average of two feed  coal  samples from  test 201-1 .
tt Typical range for Appalachian  and  Eastern Interior Basin coals.
** Values were calculated from concentrations at the scrubber inlet when
   ICPOES analysis provided  upper limit data only.
AA Arsenic concentration calculated from  concentration at the scrubber
   inlet (see text).
x  Performed by SSMS on  a feed oil sample from test 203.
f  Performed by SSMS on  a feed coal sample  from test 200.
xx Performed by cold vapor analysis on a  feed oil sample from test 203.
Y  Performed by cold vapor analysis on a  fuel coal sample from test 200.

                                  4-7

-------
      Considering the uniformity of fuel  ultimate  analyses  obtained during
 the test periods, it appears reasonable  to  assume that tabulated trace and
 minor element analyses are typical  of the  fuels  fired during  the five day
 test period.  Although analyses of other coal  samples from the  same source
 (mine or cleaning plant)  are not available  for direct comparison, analyses
 of most trace and minor elements presented  in  Table  4-4 appear  to be con-
 sistent with concentration limits typifying Appalachian and Eastern Interior
 Basin coals.  No coal  strontium analyses were  found  for comparison.  Trace
 elements present in  somewhat higher concentrations than are indicated to  be
 typical  by the limited published data are  antimony,  arsenic,  cobalt,  copper,
 molybdenum,  and zirconium.   Typical  ranges  of  some trace and  minor elements
 in U.S.  and  foreign  crude  oils  and for nickel  and vanadium in fuel  oils are
 also  presented in Table 4-4 for comparison.  Analyses of most trace and
 minor elements for which  typical  oil  values are  available  appear to be con-
 sistent  with the literature values.   Arsenic and  molybdenum values  are on
 the high side,  and chromium is  quite  a bit  higher than the typical  crude  oil
 values.   However,  the  significance  of these higher concentrations is  not
 apparent due to  the  limited quantity  of  published data and the  complete
 absence  of source  specific  data.

 STACK  EMISSIONS
     As  discussed  previously, the wet scrubber unit  processed a  slipstream
 of the total  flue  gas  generated, by  the furnace.   Analyses  of  the  slipstream
 have been used to  estimate  total  boiler  emissions on  the basis  of 100% of
 the flue  gas  being processed by the scrubber.  That  is,  it was  assumed that
 additional scrubber modules  could be  added  to  the system such that  the total
 flue gas  output would  be processed with  a mean scrubber efficiency  identical
 to that obtained  using  the  pilot  scrubber.    All emissions  data  presented in
 the following sections  are  based  on this assumption.

 Criteria  Pollutants
     Federal  New Source Performance Standards  (NSPS)  currently in effect
 define allowable emission rates of NOX (as  N02J,  S0£  and total particulates
 from fossil  fuel fired  utility boilers having 25 MW output or greater.
More stringent limitations have been proposed by EPA  for NOX and total
particulate emissions and additional  limitations  on S02 emissions are being

                                   4-8

-------
considered for proposal.  Federal NSPS do not currently address either CO
or total hydrocarbon emissions.  Existing NSPS and corresponding proposed
or potential emission standards for coal  and oil-fired utility boilers are
summarized in Table 4-5.
     Similar standards relating to industrial units have not been promul-
gated to date.  Therefore, criteria pollutant emission data presented in
this section will be discussed in the context of existing and proposed
Federal NSPS for utility boilers.
     As mentioned previously, 5 tests were performed on the Firestone
industrial boiler for each fuel.  Criteria pollutant concentrations were
generally measured at frequent intervals during each test and averaged to
obtain  the mean concentrations for each test.  The 5-test averages of
criteria pollutant emissions data are presented in Table 4-6.  Average
emissions data from the individual tests are presented in Tables 4-7 and
4-8 for coal and oil, respectively.  Additionally, the 5-test averages
of scrubber inlet data are presented in Table 4-9 for comparison with the
EPA AP-42 (Reference  8)  emission factors for uncontrolled sources.  Tabu-
lated AP-42 emission factors are for 10 MW industrial boilers firing the
appropriate fuel   Factors for coal-fired boilers are specific to dry
bottom  units.  The data are discussed by specific compound in the ensuing
sub-sections.

Nitrogen Oxide
     Mean NO  emission factors prior to FGD  processing were 421 ng/J
(0.98 Ib/MM Btu) and 168 ng/J (0.39 Ib/MM Btu) for coal and oil, respec-
tively.  The full load NO  emission factors  prior to FGD processing were
491 ng/J (1.14 Ib/MM Btu) for coal firing and 175 ng/J (0.41 Ib/MM Btu)
for oil firing.  The full load emission factor for coal firing is nearly
43% higher than the average emission factor  of 343 ng/J (0.80 Ib/MM Btu)
tabulated in AP-42.   On the other hand, the  emission factor for oil firing
is 19%  lower than the tabulated AP-42 emission factor of 217 ng/J
(0.51  Ib/MM Btu).  However, examination of published data from industrial
boilers indicates that each emission factor  is well within the range typical
for the respective fuel  (Reference 9).  Average measured NO  emission factors
                                                           A
                                    4-9

-------
                         TABLE  4-5.   EXISTING AND  PROPOSED FEDERAL EMISSION STANDARDS
       Compound
           Coal-Fired Utilities
                         NSPS
                    Proposed or Potential
                          Standard
                                        Oil-Fired  Utilities
                                  NSPS
                    Proposed or Potential
                          Standard
I
o
     N0x  (as
          sc
         Total
      Participates
   300 ng/J
(0.7 Ib/MM Btu)

   520 ng/J
(1.2 Ib/MM Btu)
    43 ng/J
(0.10 Ib/MM Btu)
220 ng/J (0.50 Ib/MM Btu)
max. with 65% reduction.

520 ng/J (1.2 Ib/MM Btu)
max. with 90%* reduction
to 85 ng/J (0.20 lb/
MM Btu)

13 ng/J (0.03 Ib/MM Btu)
max. with 99% reduction
    129  ng/J
(0.30 Ib/MM Btu)

    344  ng/J
(0.80 Ib/MM Btu)
     43 ng/J
(0.10 Ib/MM Btu)
129 ng/J (0.30 Ib/MM Btu)
max. with 65% reduction

344 ng/J (0.80 Ib/MM Btu)
max. with 90%* reduction
to 85 ng/J (0.20 lb/
MM Btu)

13 ng/J  (0.03 Ib/MM Btu)
      *The  90%  reduction  is a potential standard.

-------
                           TABLE 4-6.   CRITERIA POLLUTANT EMISSIONS  FOR  AN

                                       INDUSTRIAL BOILER  IN  THERMAL  UNITS
            Pollutant
                                                               ng/J  (Ib/MM  Btu)
           Coal  Firing
                                  Oil  Firing
                                 Before Scrubber
                    After Scrubber
                      Before  Scrubber
                   After Scrubber
       N0y (as  NOJ
.p,        X       c


i      co



       S00
       Organics (as CH.)



       Total  Particulates
 421     (0.98)



  15.9  (0.04)



1112     (2.59)



   5.79 (0.01)



2951     (6.86)
372    (0.87)



 14.3  (0.03)



 36.3  (0.08)



  6.29 (0.01)



 18.6  (0.04)
168    (0.39)



  5.47 (0.01)



993    (2.31)



  2.49 (0.01)



113    (0.26)
161     (0.37)



  5.31  (0.01)



 26.8  (0.06)



  2.74  (0.01)



 17.6  (0.04)

-------
TABLE 4-7.   SUMMARY OF CRITERIA POLLUTANT EMISSIONS - COAL FIRING
Test No.




200 Inlet

200 Outlet

201-1 Inlet

201-1 Outlet

201-2 Inlet

201-2 Outlet

201-3 Inlet

201-3 Outlet

201-4 Inlet

201-4 Outlet

Average Inlet

Average Outlet


NOY
A
(as NOJ
C
417
(0.97)
367
(0.85)
491
(1.14)
457
(1.06)
455
(1.06)
358
(8.33)
330
(0.77)
258
(0.60)
409
(0.95)
420
(0.98)
421
(0.98)
372
(0.87)

CO



20.7
(0.05)
18.5
(0.04)
16.5
(0.04)
15.7
(0.04)
17.7
(0.04)
15.9
(0.04)
16.2
(0.04)
12.7
(0.03)
8.56
(0.02)
8.95
(0.02)
15.9
(0.04)
14.3
(0.03)

so2



1009
(2.35)
25.4
(0.06)
1284
(2.99)
39.0
(0.09)
1295
(3.01)
35.5
(0.08)
1028
(2.39)
31.8
(0.07)
942
(2.19)
49.7
(0.12)
1112
(2.59)
36.3
(0.08)
ng/J
HC
(as ClU
*T

3.79
(0.01)
4.22
(0.01)
4.35
(0.01)
5.22
(0.01)
0.88
(0.00)
1.33
(0.00)
10.9
(0.03)
10.9
(0.03)
8.95
(0.02)
9.73
(0.02)
5.79
(0.01)
6.29
(0.01)
(Ib/MM Btu
Cl - C6

Organics

<5.49
(<0.01 )
<5.49
(<0.01)
<5.65
(<0.01 )
<5.65
(<0.01)
<5.75
(<0.01)
<5.75
(<0.01)
<5.69
(<0.01 )
<5.69
(<0.01)
<5.06
(<0.01 )
<5.06
(<0.01)
<5.53
(<0.01)
<5.53
(<0.01)

C7 - C16
/ i \j
Organics

0.34
{0.00)
0.27
(0.00)
--

--

--

--

__

--

--

--

0.34
(0.00)
0.27
(0.00)

Organics
Higher
Than
C16
2.28
(0.01)
0,33
(0.00)
--

--

--

--

--

--

--

--

2.28
(0.01)
0.33
(0.00)

Total
Participates


2361
(5.49)
14.3
(0.03)
3122
(7.26)
20.9
(0.05)
--

—

--

--

3370
(7.84)
20.6
(0.05)
2951
(6.86)
18.6
(0.04)

-------
                             TABLE 4-8.  SUMMARY OF  CRITERIA  POLLUTANT  EMISSIONS  -  OIL FIRING
 I



CO
Test No.
202-1 Inlet
202-1 Outlet
202-2 Inlet
202-2 Outlet
202-3 Inlet
202-3 Outlet
202-4 Inlet
202-4 Outlet
203 Inlet*
203 Outlet*
Average
Inlet
Average
Outlet

N0y
/\
175
(0.41)
166
(0.39)
175
(0.41)
165
(0.38)
181
(0.42)
177
(0.41)
141
(0.33)
138
(0.32)
--
--
168
(0.39)
161
(0.37)

CO
5.08
(0.01)
4.70
(0.01)
5.30
(0.01)
5.03
(0.01)
6.22
(0.01)
5.92
(0.01)
5.30
(0.01)
5.60
(0.01)
--
--
5.47
(0.01)
5.31
(0.01)

so2
938
(2.18)
32.1
(0.07)
1075
(2.50)
29.2
(0.07)
1085
(2.52)
26.7
(0.06)
874
(2.03)
19.2
(0.04)
--
--
993
(2.31)
26.8
(0.06)
ng/J
HCf
(as CH4)
2.84
(0.01)
3.20
(0.01)
4.61
(0.01)
5.01
(0.01)
1.71
(0.00)
1 .98
(0.01)
0.82
(0.00)
0.76
(0.00)
--
--
2.49
(0.01)
2.74
(0.01)
(Ib/MM Btu)
C - C
Ll L6
Organics
<4.63
(< 0.01)
<4.63
(< 0.01)
<4.79
(< 0.01)
<4.79
(< 0.01)
<4.73
(< 0.01)
<4.73
(< 0.01)
<4.14
(< 0.01)
<4.14
(< 0.01)
--
--
<4.57
(< 0.01)
<4.57
(< 0.01)

C7 " C16
Organics
--
--
—
--
--
--
--
--
0.17
(0.00)
0.02
(0.00)
0.17
(0.00)
0.02
(0.00)

Organics
Higher
Than C-]5
--
—
—
--
—
—
—
--
2.61
(0.01)
0.43
(0.00)
2.61
(0.01)
0.43
(0.00)

Total
Particulates
166
(0.39)
- 20.2
(0.05)
—
—
--
--
59.0
(0.14)
15.0
(0.03)
--
--
113
(0.26)
17.6
(0.04)
             Emission factors were computed assuming an 0-, concentration of 5.5%, the average concentration for  test 202.
             Total hydrocarbons as determined  by  FIP.

-------
                 TABLE 4-9.   COMPARISON  OF CRITERIA  POLLUTANT EMISSIONS WITH
                             EMISSION FACTORS  FOR  UNCONTROLLED BOILERS
Dr\ 1 1 i if" a n t"




NO (as N00 at full
x 2
CO
so2
Organics (as CH^)
Total Participates

Coal
Test Data
Before
Scrubber
load) 491 (1.14)
15.9 (0.04)
1112 (2.59)
5,79 (0.01)
2951 (6.86)
ng/J (1
Fi ring
AP-42
Emission
Factor*
343 (0.80)
19 (0.04)
1189 (2.77)
5.72 (0.01)
3212 (7.47)
b/MM Btu)
Oil
Test Data
Before
Scrubber
175 (0.41)
5.47 (0.01)
993 (2.31)
2.49 (0.01)
113 (0.26)

Firing
AP-42
Emission
Factor*
217 (0.51)
14.7 (0.03)
904 (2.10)
2.94 (0.01)
29.4 (0.07)
Factors are computed from AP-42 values for uncontrolled sources using the national  average
heating values of 11,263 Btu/lb for bituminous coal  and 146,285 Btu/gal  for fuel  oil,[10].

-------
after FGD were 372 ng/J (0.87 Ib/MM Btu) for coal firing and 161 ng/J (0.37
Ib/MM Btu) for oil firing.  As such, controlled NOX emission rates exceed
NSPS limitations by 23 to 25% (NSPS for N0v is 300 ng/J for coal and 129
                                          A
ng/J for oil).  Data presented in Tables 4-1, 4-7 and 4-8 indicate that
NO  emission varied with boiler load for both fuels, as expected.  NO
              .                                                       ^
emission factors measured at the scrubber inlet are presented in Figure 4-1
as a function of boiler loading for both fuels.  The straight line plots
presented in the figure were determined by linear regression analyses of
the data.  It is interesting to note that these lines have very similar
slopes, 6.72 ng/j.% loading for coal firing and 4.79 ng/j-% loading for oil
firing.  These data indicate that for boiler loadings between 90 and 100%,
NO  emission factors from coal firing are approximately three times greater
  X
than from oil firing.   While this factor of three compares favorably with
the ratio of fuel nitrogen contents (312 ng N/J in coal and 88.4 ng N/J  in
oil leads to a fuel nitrogen ratio of 3.5), total NO  emissions are com-
                                                    X
posed of both thermal  and fuel NO  components.  Laboratory data indicate
                                 X
that for these fuel nitrogen concentrations, 30 to 60% of the fuel  nitrogen
might be expected to form NO  , [1].  Therefore, fuel nitrogen content may be
                            A
a principal factor in the difference between NO  emissions from coal and
                                               X
oil-fired units.
     NO  data generally indicate a reduction of NO  emissions across the
       X                                 "         A
scrubber for both fuels; the magnitude of this apparent reduction ranges
from approximately zero to 24% for coal firing and from 2 to 6% for oil
firing.  However, NO  reductions measured during coal firing could not be
                    X
correlated to variables monitored during testing (NO  concentration,
                                                    X
flue gas temperature,  flow rates).  Further, NO  reduction trends paral-
                                               X
leled trends in CO reduction which suggested a sampling phenomenon rather
than chemical removal.   Subsequent examination of the sampling train dur-
ing oil firing tests revealed a small  air leak in the sampling line to the
scrubber outlet.  This  problem, associated with a faulty coupling, was
rectified prior to tests 202-3 and 202-4.   Data from these latter tests
indicate NO  removals  of approximately 2% across the scrubber.  Higher
           A
removals obtained earlier during the test period are considered to be
reflective, at least in part, of air leak problems and must be held sus-
pect.   NO  removal in  both wet and dry FGD systems has been reported in  the
         X
                                    4-15

-------
    40C
 °>  300


of

o
h-
u
z
o

oo
oo

2
o
   200
   100
                                         COAL FIRING
                                                       OIL FIRING
                                   90


                               BOILER LOADING, %
100
     Figure 4-1.   The Effect  of Boiler  Loading on  MO   Emission  Factors
                                                       A



                                      4-16

-------
literature, although no information is available regarding the chemistry of
such occurences,  [11],  [12].   It  is feasible that some degree of NOV removal
                                                                   A
may be effected by dissolution of NCL in the slightly acidic scrubber
solution.

Carbon Monoxide
     Emission rates of  CO prior to FGD were 15.9 ng/J (0.04 Ib/MM Btu)  and
5.47 ng/J  (0.01 Ib/MM Btu) for coal and oil firing, respectively.  Average
measured CO emissions for coal firing compare well with the AP-42 emission
factor of  19 ng/J (0.04 Ib/MM Btu).  However, CO emissions for oil  firing
are 63%  lower than the  respective AP-42 value of 14.7 ng/J (0.03 Ib/MM  Btu).
Thus, while AP-42 data  indicate oil firing CO emission factors to be 23%
lower than those  for coal firing, measured data for coal and oil firing
differ by  a factor of three.  A slight reduction of CO emissions across
the scrubber was  observed during most tests.  Average CO reductions for
coal and oil firing were 10 and 3% respectively.  As discussed previously,
CO reduction trends during coal firing and early oil firing tests are
reflective, to some extent, of air leaks in the flue gas sampling train.
Further, at these low CO concentrations, analytical sensitivity is  in the
range of 7-15% of the measured value.  Therefore, the slight reductions
are considered to be of little significance.

Sulfur Dioxide
     Average S0?  emission rates prior to scrubbing were 1112 ng/J (2.59
Ib/MM Btu) and 993 ng/J (2.31 Ib/MM Btu) for coal and oil firing, respec-
tively.  These uncontrolled emission factors correspond well  with the
respective AP-42  values of 1189 ng/J (2.77 Ib/MM Btu) for coal firing and
904 ng/J (2.10 Ib/MM Btu) for oil  firing.   Average S02 emission rates after
scrubbing were 36.3 ng/J (0.08 Ib/MM Btu)  for coal firing and 26.8  ng/J
(0.06 Ib/MM Btu)  for oil firing.  A mean scrubber efficiency of 97% is
indicated for both fuels by these data.  Measured SO,-, emission rates after
scrubbing are lower than either existing or potential NSPS limitations.

Hydrocarbons
     Total  organic emissions, expressed as methane, were analyzed with  a
Flame lonization Detector (FID) during coal and oil firing tests.  Average
                                    4-17

-------
 hydrocarbon emissions prior to scrubbing were 5.79 ng/J (0.01 Ib/MM Btu)
 for coal firing and 2.49 ng/J (0.01 Ib/MM Btu) for oil firing.  Measured
 emissions rates correspond well  with the AP-42 values of 5.72 ng/J
 (0.01 Ib/MM Btu) for coal firing and 2.94 ng/J (0.01  Ib/MM Btu) for oil
 firing.  It should be noted that, during these tests, the analyzed flue
 gas slipstream was processed through a gas conditioner situated ahead of
 the FID in the analytical train.  Therefore, higher molecular weight
 organics may have been condensed or scrubbed from the flue gas prior to
 analysis.
     Hydrocarbon emissions measured by FID appeared,  on the average, to
 increase across the scrubber by  approximately 10% for both fuels.  These
 data were evaluated in terms of  real time scrubber inlet and outlet data
 pairs obtained not more than 30  minutes apart.  The average increase in
 hydrocarbons across the scrubber is not statistically significant for coal
 firing data due to concentration fluctuations during  testing.  However,
 real time data pairs measured during coal firing do show a statistically
 significant difference with scrubber outlet samples being biased high
 relative to inlet samples.   The  magnitude of this bias is approximately
 5 ppm (1.5 ng/J at the excess oxygen levels measured).  The cause of the
observed bias is not known at the present time although the possibility
of moisture interference, improper FID calibration or variable sample gas
flow rate has been evaluated and subsequently discarded.  Real time data
 pairs measured during oil firing indicate that hydrocarbon emissions at
 the scrubber inlet and outlet are not statistically different.  Whether
 the absence of significant bias  for oil firing results from the lower
 emission factor associated with  oil firing.or reflects differences in
 combustion products from the two fuels cannot be determined from available
 data.
     In addition to FID analyses of total hydrocarbons, gas chromatograph
 analyses were performed on limited bag' samples of flue gas and catches
 from the Level 1 sampling (SASS  train).  Additionally, gravimetric analyses
 were performed on Level  1 samples to quantify high molecular weight
 organics.  Each bag sample was collected over an interval  of 30 to 45 min-
 utes, with a single sample being collected per test.   These samples were
                                    4-18

-------
utilized to measure GI to Cg hydrocarbons.  The SASS train collects approx-
imately 30 cubic meters of flue gas which are drawn isokinetically during
the test.  Samples from the SASS train were analyzed to determine organics
higher than Cg.  The C-, to C,g fraction was determined by gas chromatograph
while organics higher than C^, were determined gravimetrically.
     Analytical results for scrubber outlet SASS train XAD-2 resin samples
were not available due to sample handling problems.  However, data from
coal- and oil-fired utility boilers were utilized to obtain an average
ratio of resin-absorbed organics to all other organics collected by the
SASS train for each fuel.  These ratios were used in conjunction with data
from the scrubber outlet probe rinse, resin module rinse, particulate
organics and other organic catches from the SASS train to estimate the
resin catch.  Calculated outlet organic data from the C-, to C,, and higher
than C,g organic fractions are considered to be accurate to within a factor
of three to four.
     Emissions of hydrocarbons higher than C,g and scrubber removal effi-
ciencies for this fraction appear to be similar for coal and oil firing
tests.  As indicated in Tables 4-7 and 4-8, emission factors for organics
higher than C,fi for coal and oil firing differ by less than 15% with
2.28 ng/J (0.01 Ib/MM Btu) for coal firing and 2.61 ng/J (0.01 Ib/MM Btu)
for oil firing prior to scrubbing.  Organics higher than C-,,. comprise
28 to 60% of the scrubber inlet hydrocarbons during coal firing and 35 to
94% during oil firing.  Emissions of organics higher than C,fi were reduced
to 0.33 ng/J (85% removal) and 0.43 ng/J (83% removal) for coal and oil
firing, respectively.
     Emissions of C7 to C,fi fractions prior to scrubbing were 0.34 ng/J
for coal firing and 0.17 ng/J for oil firing.  These emission rates indi-
cate that the C-, to C,r fraction represents less than 9% of the total
               /     I b
organic emissions prior to scrubbing during coal firing and less than 6%
during oil  firing.  Emissions of the C-, to C,, fraction after scrubbing
were 0.27 ng/J and 0.02 ng/J for coal and oil firing, respectively.  These
data appear to indicate that removal of the C-, to C,g fraction by scrubbing
was 20% for coal firing and 88% for oil firing.  However, noting the uncer-
tainty in outlet organic levels described previously, the 20% removal
                                    4-19

-------
observed for coal firing may actually be as high as 97% while the
removal for oil firing may be as low as 53%.  Hence, while it appears
that some removal of C7 to C,c fraction was achieved for both fuels, defi-
nite conclusions regarding the relative removals for each fuel cannot be
drawn.
     Chromatographic analyses performed on the C^  to Cg hydrocarbon frac-
tions did not indicate the presence of these organics at the detection
limits indicated in Tables 4-7 and 4-8, namely 5.53 ng/J for coal and
4.57 ng/J for oil.   However, note that the emissions of C-, and higher
organics prior to scrubbing are essentially the same for coal and oil
firing and that removal  of these organics  by scrubbing is between 2.02 ng/J
and 2.33 ng/J.   Further, FID data do not show a decrease in organics across
the scrubber.   These observations appear to indicate that the flue gas
slipstream analyzed by FID contained light hydrocarbon fractions but did
not include higher  molecular weight organics.   This may be attributed to
processing the  flue gas  through a gas conditioner  prior to FID analysis.
As such, FID data may be reflective of C-,  to Cfi hydrocarbon emissions and
indicate that the coal  firing produces more C,  to  Cfi hydrocarbons than does
oil firing.

Total  Particulates
     Average emission rates of total particulates  prior to scrubbing were
2951  ng/J (6.86 Ib/MM Btu) for coal  firing and 113 ng/J (0.26 Ib/MM Btu)
for oil  firing.   A  mass  balance of the coal ash indicates that approxi-
mately 75% of the total  ash was processed  by the scrubber and that multi-
clones located upstream of the scrubber removed little or no particulate.
This observation was verified by site operators who noted that the multi-
clone unit was subject to mechanical failure during both coal and oil
firing.   Hence, particulate loadings measured at the scrubber inlet appear
to be representative of uncontrolled emissions.  Mean particulate loadings
at the scrubber inlet during coal firing are approximately 8% lower than
the value of 3212 ng/J  (7.47 Ib/MM Btu) presented  in AP-42, which repre-
sents rather good agreement.  On the other hand, the average particulate
emission factor for oil  firing is nearly a factor  of four greater than the
                                    4-20

-------
tabulated AP-42 value of 29.4 ng/J (0.07 Ib/MM Btu).  However, data pre-
sented in Table 4-8 show that the oil firing particulate loading prior to
scrubbing was substantially larger during test 202-1 than during test 202-4,
indicating that coal ash from previous testing may have been emitted during
early oil firing tests.  If particulate data from test 202-4 are assumed
to be representative of oil firing emissions, the particulate emission rate
of 59 ng/J (0.14 Ib/MM Btu) measured at the scrubber inlet exceeds the AP-42
value by a factor of two.  This assumption appears to be valid since data
from Polarized Light Microscopy analyses (PLM) indicate that particulates
from test 202-4 are composed primarily of oil soot and sulfate compounds
(refer to the Inorganic subsection for analysis).
     Total particulate emissions after scrubbing were 18.6 ng/J (0.04 Ib/MM
Btu) for coal firing and 17.6 ng/J (0.04 Ib/MM Btu) for oil firing.  These
controlled particulate emission rates correspond to 99% and 84% removal
efficiencies for coal and oil firing, respectively.  However, based on the
oil firing particulate catch known to be free of coal ash contamination, the
scrubber efficiency appears to be 75%.  Controlled particulate emissions for
both coal and oil firing are well below the NSPS limitation of 43 ng/J
(0.10 Ib/MM Btu) although they are slightly higher than the proposed limi-
tation of 13 ng/J (0.03 Ib/MM Btu).

Particulate Size Distribution
     Size distributions of particulates at the scrubber inlet and outlet
were determined by two methods.  Due to the high particulate loading at the
scrubber inlet during coal firing, PLM analyses were utilized to obtain a
size distribution in terms of optical diameter and number of particles per
size range.  All other particulate size distribution determinations involved
streams with substantially lower solids loadings and, therefore, an Anderson
cascade impactor was used.  The cascade impactor data differs from PLM
analyses in that size distributions are determined in terms of aerodynamic
diameter and weight percent in each size range.  Thus, data from the two
methods cannot be directly compared.   For this reason, the PLM data have been
converted to the same basis as the impactor data by assuming that particulate
density is independent of particle diameter.  This is a reasonable assumption
                                    4-21

-------
because the major components of the particulates generated from coal com-
bustion, the aluminosilicates and iron oxides, are known to partition equally
among small and large particulates.  With the constant density assumption,
the weight distribution in each size range would be proportional  to the
product of the number distribution and the particulate volume representing
the size range.  The particulate volume was calculated based on the geometric
mean diameter for the size range.
     Particulate size distribution data from coal  and oil  firing  tests are
summarized in Table 4-10.   These data show a significant change in parti-
culate size distribution before and after scrubbing for both fuels.  The
increase in the fraction of finer particulates across the scrubber indi-
cates that coarse particulates were removed more efficiently than fine par-
ticulates for both coal and oil  firing tests.   This is further indicated by
emission rate data presented in Table 4-11 which shows that particulates
larger than 3ym were removed with efficiencies of at least 97% while par-
ticulates smaller than 3ym showed little or no removal.
     As discussed previously, particulates from early oil  firing  tests
collected prior to scrubbing appear to contain residual  particulate from
coal fired tests.   Since coal particulate is generally coarser than oil
particulate, contaminated  oil particulate would appear to be somewhat coarser
than pure oil particulate.  Thus, while data in Table 4-10 show that oil
particulate is substantially finer than coal particulate, the difference in
size distributions is probably not as great as would have been found if a
pure oil particulate sample had been sized.
     It is also interesting to note that for coal-fired particulates less
than 3 ym in size, there is a net increase in emission rates across the
scrubber (Table 4-11).  This net increase indicates that the venturi scrubber
is probably not effective in removing the fine particulates present in the
flue gas, and that fine particulates may be generated within the  scrubber.
Based on the analysis of S03 and S04= emission data, it has been  estimated
that up to 40% of the fine particulate emissions at the scrubber  outlet
could be contributed by scrubber generated NaHS04.  The remaining portion of
the net increase in fine particulates across the scrubber can probably be
attributed to the uncertainties associated with the assumptions used in
                                    4-22

-------
TABLE 4-10.  SCRUBBER INLET AND OUTLET
             PARTICULATE SIZE DISTRIBUTION
Aerodynamic
Diameter Size
Range, Microns
< 1
1 - 3
3 - 10
> 10

Coal Firing
Scrubber
Inlet
0.0017
0.041
2.24
97.7
Weight %
(Test 201-1) Oil Firing (Test 202-1)
Scrubber Scrubber Scrubber
Outlet Inlet Outlet
62 20 83
30 1 12
7 74 5
1 5 0
TABLE 4-11. EMISSION RATES OF PARTICULATES
Aerodynamic
Diameter
Size Range,
Microns
< 1
1 - 3
3 - 10
> 10
Total
Coal Firing (Test
ks/hr
Scrubber Scrubber
Inlet Outlet
0.0055 1.30
0.13 0.63
7.3 0.15
316.5 0.021
324.0 2.10
201-1) Oil Firing (Test 202-1J
Removal kg/hr Removal
Efficiency Scrubber Scrubber Efficiency
Inlet Outlet
<0 4.48 2.27 49.2
<0 0.22 0.33 <0
97.9 16.6 0.14 97.4
>99.9 1.12 0.00 100
99.3 22.4 2.74 87.8
                  4-23

-------
converting PLM number size distribution data to weight size distribution,
and to calcium sulfite hemihydrate (CaS03«l/2 H20)  particulates generated
by the scrubber.
     Although a very slight increase in l-3ym oil-fired particulates was
observed, a net decrease in particulates less than  3ym was observed for oil
fired testing.  Also, compounds associated with scrubber solution were not
conclusively identified in the oil-fired particulates at the scrubber out-
let.  However, based on the results of coal-fired testing, it appears
reasonable that scrubber generated particulates were present in the scrub-
ber outlet stream during oil  firing but that the high fine particulate
loading associated with oil firing masked detection of these materials.

Sulfur Compounds:  SO,,, SO,,  and SO.
     A pulsed fluorescent analyzer was used to continuously monitor SCL
emissions for the coal  and oil  tests.   SCL was determined as FUSO, using
the Goksoyr-Ross  controlled condensation system, and SO,  was determined
by anion analysis of the particulate extracts from  the Method 5 sampling
train.  A summary of these analytical  results is presented in Table 4-12.
As can be seen from the sulfur balance, 90 to 94% of the input sulfur is
emitted as S02 when emissions are uncontrolled.  The removal efficiency
for S02 is high:   95 to 97% for coal firing and 97  to 98% for oil firing.
About 30% of the SO., was also removed by the scrubber.  The relatively poor
removal efficiency for S03 is an indication that SO, is either present as
very fine aerosols in the scrubber inlet, or is converted to very fine
aerosols as the flue gas stream is rapidly cooled inside the scrubber.  The
higher S04~ removal efficiency indicates that S04"  is probably associated
with larger particulates, which are efficiently scrubbed.

     A comparison of the sulfur oxide emissions is  best made by comparing
emission rates which are normalized to the amount of fuel sulfur available.
These are listed in the column "% of fuel sulfur found in flue gas at
inlet" in Table 4-12.  For S02> these values are almost the same for coal
and oil.  For S03, the values for oil  were 50 to 75% higher than for coal.
This result is generally attributed to the fact that vanadium and nickel,
which catalyze the oxidation of S02 to S03, are usually present in higher
concentrations in oil than in coal.  For sulfates,  the normalized emission
                                    4-24

-------
                           TABLE 4-12.  S02, S03, and S04  EMISSIONS FROM COAL AND OIL FIRING
ro
en

Pnl 1 ut=mt
r u i i tj uu 1 1 u
Test



S02 201-1
201-4
S03 201-1
201-4
S04= 201-1
Total 201-1


Scrubber
Inlet
ng/J

1280
937
7.2
4.9
66.3

Oi
U 1
Scrubber
Outlet
ng/J

37.8
47.8
4.9
3.3
8.0

'

% of Fuel
Sulfur Found
in Flue Gas
at Inlet
92
94
0.4
0.4
3
95


Removal
Effi-
ciency
%
97
95
33
32
88



Test



202-1
202-4
202-1
202-4
202-4
202-4


Scrubber
Inlet
ng/J

940
874
7.5
8.4
22.9

Hi
U J
Scrubber
Outlet
ng/J

32.2
19.2
5.3
6.0
9.1

i
i
% of Fuel
Sulfur Found
in Flue Gas
at Inlet
92
90
0.6
0.7
1.6
92


Removal
Effi-
ciency
%
97
98
29
28
60


-------
 rate  for coal  is twice that for oil.  Because the S03 concentration  levels
 are lower than the S04= levels, this cannot be satisfactorily explained by
 simply assuming a higher rate of reaction of gaseous S03 with ash particu-
 lates to form metallic sulfates.  A possible mechanism of metallic sulfate
 production is as follows:  the metal oxides in the ash may serve as  cata-
 lysts for the reaction of SCL to S03-  The S03, which is adsorbed on the
 ash surface, may then react with the surface to form a metallic sulfate,
 or may desorb and then collide with ash particulates and form the sulfate.
 It is thus proposed that in the coal-fired case the reaction is catalyzed
 by metallic ash constituents, and SO- is formed as an adsorbed intermediate,
 which then usually reacts with the ash on which it is adsorbed.  In  the
 oil-fired case, mainly gaseous SO- is formed, the reaction being catalyzed
 by Ni and V.
     A comparison  of scrubber efficiencies shows  that for the gaseous
 sulfur oxides,  the removal  efficiency does not depend upon the fuel  used.
 However,  sulfates  are not removed with equal  efficiency from flue gases
 from coal  and oil  firing.   The higher sulfate removal  from the coal  flue
 gases  is  explained by the fact that the particulates from coal  firing are
 larger than  those  from oil,  and the scrubber removes larger particulates
more efficiently  than smaller particulates.
     Table 4-13 shows the breakdown of the sulfate emissions into the
 water and acid  soluble fractions before and after the scrubber.  While both
 types of sulfates  were removed by the scrubber, the fraction of water solu-
 ble sulfates increased from 56 to 88% during oil  firing and from 24  to 97%
 during coal  firing.   One explanation is that the  acid soluble fraction is
 more efficiently removed than the water soluble fraction.  This cannot
 be checked by comparing the removal efficiencies  of the major element
 cations (Tables 4-16 and 4-17) as a function of the solubility of their
 sulfates because the types of sulfates present are not known.  A second
 explanation may be that the water and acid soluble fractions are removed
 with  comparable efficiency, and that the scrubber contributes shall   quan-
 tities of water soluble sulfate to the gas stream passing through.    Because
 of this possibility, an analysis effort utilizing Fourier Transform  Infrared
                                    4-26

-------
                TABLE 4-13,   SUMMARY OF SULFATE EMISSIONS
                             DURING COAL AND OIL FIRING
Emission Rate, nq/J
Coal - Test
Scrubber
Inlet
Water Soluble 16.0 (24%)
Acid Soluble 51.2 (76%)
Total 67.2
201-1
Scrubber
Outlet
8.1 (97%)
0.2 ( 3%)
8.3
Oil - Test
Scrubber
Inlet
12.9 (56%)
10.0 (44%)
22.9
202-4
Scrubber
Outlet
8.0 (88%)
3.5 (12%)
9.1
Analysis (FTIR) and X-Ray Diffraction (XRD) analysis was initiated to deter-
mine the nature of SQ~ emissions.  For the dual  alkali  system,  possible
sulfate species would be CaSO. and Ca(HSO.)2 from the scrubber regeneration
step, NaHSO. and Na^SO, from oxidation of NaHS03 and Na2S03-   Calcium sul-
fate and bisulfate are ruled out because of the low calcium concentration
at the outlet  (see Tables 4-14 and 4-15).  In the coal test,  FTIR and XRD
confirmed the  presence of sodium bisulfate at the scrubber outlet, but not
at the scrubber inlet.  This is positive proof that sulfates  are generated
within the scrubber and emitted in the scrubber effluent gas  in the coal-
fired test.  Based on these findings, it is believed that NaHS04 emissions
from the scrubber are on the order of 1 ng/J (the difference  between total
sulfate and H?S04 emissions determined as S03).  Furthermore, if one
assumes that only a small fraction of the H2S04 was collected on the filter
because of the high filter temperature, then the measured sulfate emissions
could be almost totally metallic sulfates, indicating that the scrubber
contribution could be as high as 8 ng/J.  This amount of scrubber generated
NaHSO, could account for 40% of the fine particulate  (<3 urn)  emissions at
the scrubber outlet.
     In the oil-fired test, FTIR confirmed the presence of NaHS04 at both
the inlet and  outlet of the scrubber, but XRD results indicated that
NaHSO, made up less than 1% of the particulate matter in the gas stream
                                    4-27

-------
        TABLE  4-14.  EMISSION CONCENTRATIONS  OF TRACE ELEMENTS
                     DURING COAL  FIRING - TEST  201-1

Trace
Element
•__ —— — — — — — —
*
Be
Hg1"
Ca
Mg
Sb
As
*
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total

Scrubber
Inlet
mg/m
0.1
0.011
74
19
3.7
7.8
0.2
0.47
2.6
3.6
9.6
450
8.5
0.78
10
1.4
3.1
2.3
3.2
11
480
1.6
1100

Scrubber
Outlet
mg/m
0.002
0.005
0.036
0.011
0.025
0.22
0.03
0.0010
0.13
0.012
0.020
2.4
0.021
0.015
0.027
0.063
0.058
0.048
0.099
0.058
2.6
0.018
6.2

MATE
Value
, 3
mg/m
0.002
0.05
16
6.0
0.050
0.002
3.1
0.010
0.001
0.050
0.20
1.0
0.15
5.0
5.0
0.015
0.50
4.0
0.200
3.1
5.2
5.0

—
Degree
Scrubber
Inlet
1 -
50
0.22
4.6
3.2
74
3900
0.07
47
2600
72
48
450
57
0.16
2.0
93
6.2
0.58
16
3.5
92
0.32


of Hazard
Scrubber
Outlet
1.0
0.10
0.002
0.002
0.5
no
0.01
0.1
130
0.24
0.10
2.4
0.14
0.003
0.005
4.2
0.12
0.012
0.50
0.019
0.5
0.004

 Approximate  values  as  determined by Spark Source Mass Spectrometry  (SSMS)
 The other values  presented are determined by Inductively Coupled Plasma
 Optical  Emission  Spectroscopy  (ICPOES) analysis.

 Mercury  was  determined by cold vapor analysis of SASS train.

*Degree of hazard  is defined  as the ratio of the discharge concentration
 to the MATE  value.

                                    4-28

-------
         TABLE  4-15.
EMISSION CONCENTRATIONS OF TRACE ELEMENTS
DURING OIL FIRING - TEST 202-4
Element
*
Be
Hgf
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Scrubber
Inlet
mg/m
<0.001
0.0016
0.41
0.31
0.062
0.15
0.53
0.28
0.17
0.10
0.54
4.8
0.20
0.03
0.22
1.1
2.7
0.61
0.050
0.043
5.7
0.015
18
Scrubber
Outlet
mg/m
0.001
0.0002
0.070
0.030
0.006
0.030
0.039
0.066
0.018
0,012
0.007
0.28
0.013
0.004
0.025
0.20
0.82
0.065
0.006
0.001
0.48
0.001
2.5
MATE
Value
mg/m
0.002
0.05
16
6.0
0.050
0.002
3.1
0.010
0.001
0.050
0.20
1.0
0.15
5.0
5.0
0.015
0.50
4.0
0.200
3.1
5.2
5.0

Degree
Scrubber
Inlet
<0.50
0.032
0.026
0.052
1.24
75.0
0.171
28.0
170
2.0
2.70
4.8
1.333
0.006
0.044
73.3
5.40
0.153
0.25
0.014
1.096
0.003

of Hazard
Scrubber
Outlet
0.50
0.004
0.004
0.005
0.120
15.0
0.013
6.60
18.0
0.24
0.035
0.28
0.087
0.001
0.005
13.33
1.640
0.016
0.03
0.0003
0.092
0.0002

Beryllium was determined by Spark Source Mass Spectrometry (SSMS).   The
other values, with the exception of mercury,  are determined  by  Inductively
Coupled Plasma Optical Emission Spectroscopy  (ICPOES)  analysis.

Mercury was determined by cold vapor analysis of SASS  train  samples  taken
during test 203.
                                    4-29

-------
whereas sulfates accounted for 40% of the participate matter at the
inlet and 60% at the outlet.  It is possible that scrubber generated
Na?SO. was added to the scrubber effluent gas, but this has not been
confirmed.  It would be expected that generation of sulfates by the
scrubber would be independent of the type of fuel, other operating
conditions being the same.  It is not presently known why these results
differed in the coal- and oil-fired tests.

Inorganics
     Concentrations of 22 major trace elements present in the flue gas
during coal and oil firing are presented in Tables 4-14 and 4-15.  To
assess the hazard potential  of these emissions, the emission concentrations
are compared with the Minimum Acute Toxicity Effluent (MATE) values.  The
MATE values are emission level goals developed under direction of EPA, and
can be considered as concentrations of pollutants in undiluted emission
streams that will not adversely affect those persons or ecological systems
exposed for short periods of time, [13].  Tabulated MATE values
represent air concentrations which were derived from human health consider-
ations.  Analysis of the flue gas generated during coal firing indicates
that 18 elements exceeded their respective MATE values at the scrubber inlet
and 4 exceeded their MATE values at the scrubber outlet.   These four elements
which pose a potential  hazard are arsenic, chromium, iron and nickel.
During oil  firing,  11  elements exceeded their respective  MATE values at the
scrubber inlet and  5 exceeded their MATE values at the scrubber outlet.
The 5 elements exceeding their MATE values at the scrubber outlet are
arsenic, cadmium, chromium,  nickel and vanadium.  Elements exceeding their
MATE values at the scrubber outlet and which are common to both coal and
oil firing are arsenic, chromium and nickel.
     The MATE value for arsenic is extremely low because arsenic  is a
cumulative poison producing chronic effects in humans.  MATE values for
nickel and chromium are extremely low due to considerations for potential
human carcinogenic!ty.   Similarly, the low MATE value for cadmium results
from considerations of potential carcinogenic, oncogenic and teratogenic
effects upon humans.  The MATE value for vanadium is comparatively higher
                                    4-30

-------
since vanadium has been associated with eye and bronchial irritation with-
out indication of chronic effects.  Emissions of arsenic and chromium after
scrubbing are below their TLV's which are each 0.5 mg/m3.  And, for coal
firing, emissions of nickel after scrubbing are below the TLV value of
        3
0.1 mg/m .  Hence, if TLV's were used as the basis for comparison, emis-
sions of arsenic, chromium and nickel would be considered less hazardous.
For oil firing, emissions of cadmium, nickel and vanadium after scrubbing
exceed their TLV values of 0.05, 0.1 and 0.5 mg/m3, respectively, in addi-
tion to exceeding their respective MATE values.
                                                        •D
     Beryllium emissions after scrubbing were 0.002 mg/m  for coal firing
and 0.001 mg/m  for oil firing.  These concentrations may be compared to
the beryllium MATE value of 0.002 mg/m .  At these emission concentrations,
the National Standard for Hazardous Air Pollutants limitation of 10 grams
beryllium per day would only be exceeded by boilers of 50 MW capacity or
greater for coal firing and 100 MW capacity or greater for oil firing.
     Emission factors and mass emission rates for the 22 trace elements
analyzed are presented in Tables 4-16 and 4-17.  Also presented in these
tables are scrubber removal efficiencies for each element.  An overall
removal efficiency of 99% was obtained for coal firing and 87% was obtained
for oil firing.  However, some elements were removed with less than the
average removal efficiency for their respective fuel.  It is interesting
to note that, with the exception of iron, all elements which exceeded their
MATE values at the scrubber outlet during coal firing were removed with
lower than average efficiency.  With the exception of chromium, the same
observation may be made regarding oil-fired data.
     Enrichment factors across the scrubber have been computed for each
element and are presented in the last columns of Tables 4-16 and 4-17.
The enrichment factor is defined as the ratio of the concentrations of
trace elements to aluminum at the scrubber outlet divided by the corres-
ponding ratio at the scrubber inlet.  Aluminum is selected as a reference
material because it is known to partition equally among particulates of
                                    4-31

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     TABLE  4-16.  EMISSION FACTORS AND MASS  EMISSION  RATES  OF

                  TRACE ELEMENTS DURING COAL  FIRING -  TEST  201-1
Trace
Element
*
Be
Hgf
Ca
Mg
Sb
As
*
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Emission Factor, ng/J
Scrubber
Inlet

0.04
0.08
32
8.2
1.6
3.4

0.1
0.20
1.1
1.6
4.1
190
3.7
0.34
4.3
0.60
1.3
0.99
1.4
4.7
210
0.69
470
Scrubber
Outlet

0.001
0.037
0.015
0.0046
0.010
0.092

0.01
0.00042
0.054
0.0050
0.0084
1.0
0.0088
0.0063
0.026
0.026
0.024
0.020
0.041
0.024
1.1
0.0075
2.6
Emission Rate, g/hr
Scrubber
Inlet

5
0.50
3300
860
170
350

10
21
120
160
430
20,000
380
35
450
61
140
100
140
500
22,000
72
50,000
Scrubber
Outlet

0.09
0.23
1.6
0.48
1.1
9.7

1.2
0.044
5.7
0.53
0.88
no
0.92
0.68
1.2
2.8
2.5
2.1
4.3
2.5
no
0.79
270
Removal
Efficiency

98
55
99
99
99
97

88
99
95
99
99
99
99
98
99
95
98
98
97
99
99
99
99
Enrich-
ment
Factor

3.7
84
0.09
0.11
1.2
5.3

2.1
0.4
9.5
0.6
0.4
0.99
0.5
3.4
0.5
8.6
3.6
3.9
5.8
0.9
1.0
2.1

Appropriate values as determined by SSMS.   The  other values,  with  the

exception of mercury, were determined by ICPOES analysis.


Mercury was determined  by  cold  vapor  analysis of SASS train samnlP*
taken during test 200.                                train samples
                                 4-32

-------
         TABLE 4-17.  EMISSION FACTORS AND MASS EMISSION RATES OF
                      TRACE ELEMENTS DURING OIL FIRING - TEST 202-4
Element
*
Be
Hgf
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Emission Factor,
ng/J
Scrubber
Inlet
<0.0003
0.0006
0.13
0.10
0.02
0.049
0.17
0.091
0.055
0.033
0.18
1.6
0.065
0.010
0.072
0.36
0.88
0.20
0.016
0.014
1.9
0.0049
6.0
Scrubber
Outlet
0.0003
0.0001
0.022
0.0094
0.0019
0.0094
0.012
0.021
0.0057
0.0038
0.002
0.088
0.0041
0.0013
0.0079
0.063
0.26
0.02
0.002
0.0003
0.15
0.0003
0.78
Emission
cmi/h»
Scrubber
Inlet
<0.04
0.05
16
12
2.5
5.9
21
11
6.7
3.9
21
190
7.9
1.2
8.7
43
110
24
2.0
1.7
220
0.59
710
Rate,
Scrubber
Outlet
0.04
0.006
2.7
1.1
0.23
1.1
1.5
2.5
0.69
0.46
0.27
11
0.50
0.15
0.95
7.7
31
2.5
0.23
0.038
18
0.038
96
Removal
Efficiency
Unknown
87
83
91
91
81
93
77
90
89
99
95
94
87
89
83
71
90
87
98
92
94
87
Enrichment
Factor
>n.9
1.48
2.03
1.15
1.15
2.37
0.87
2.80
1.26
1.43
0.15
0.69
0.77
1.58
1.35
2.16
3.61
1.27
1.43
0.28
1.0
0.79

Beryllium was determined by SSMS.   The other elements,  except  fluorine,
were determined by ICPOES.

Mercury was determined by cold vapor analysis of SASS train  samples  taken
during test 203.
                                    4-33

-------
different size*.  Enrichment factors presented in the tables indicate that
beryllium, antimony, arsenic, chromium, manganese, nickel, vanadium, zinc,
selenium and mercury are enriched across the scrubber for both fuels.  Addi-
tionally, boron and zirconium are enriched during coal  firing and calcium,
magnesium, cadmium, cobalt and molybdenum are enriched  during oil firing.
     Trace element enrichment is principally due to the partitioning of
trace elements as a function of particulate size, and the greater collection
efficiency of the scrubber for large size particulates.
     To better characterize combustion generated solids in terms of trace
element distribution, the Electron Spectroscopy for Chemical Analysis
(ESCA) technique was used to determine surface and subsurface concentra-
tions of elements in the particulates.   ESCA results for particulates from
both fuels are presented in Tables 4-18 and 4-19 as normalized atom per-
centages for each particulate catch and penetration.  Scrubber inlet data
indicate that coarser particulate matter collected by the cyclone differs
somewhat from the finer particulates collected on the filter.  In the case
of coal-fired particulates, the principal  difference is the lower silicon
content of the coarser particulate.  For oil-fired particulate, the prin-
cipal difference is the higher carbon and lower silicon and oxygen contents
of the coarser particulates.   It is interesting to note that the filter
catch particulates at the scrubber inlet and outlet yielded very similar
                                                  o
ESCA analyses at the particle surface and at a 76 A penetration for  oil
fired particulates.  That this does not hold true for coal-fired particu-
lates may reflect the higher coarse particulate fraction generated and
subsequently higher particulate removal efficiency obtained for coal
firing.   That is, the compositions of coal  fired particulates at the scrub-
ber inlet and outlet might be expected to differ more significantly than
in the case of oil fired particulates due to the higher coarse particulate
loading at the inlet and, consequently, the higher particulate removal
efficiency during coal  firing.
  Silicon, iron and scandium have also been used by other investigators as
  a reference element in the computation of enrichment factors.  Notice
  that iron has no enrichment in this study while silicon and scandium
  were not measured.

                                    4-34

-------
TABLE 4-18.
DEPTH  PROFILE ANALYSIS OF COAL PARTICULATE WITH CONCENTRATIONS
EXPRESSED AS NORMALIZED  ATOM  PERCENT*  - TEST  201-1

Inlet Level II cyclone catch
Level II filter catch

Level II filter catch; 76 A
0
57
56

54.2
Na S SI Al
4 11 6 7
2.4 11.5 14.1 8

2.1 4.0 17.9 12.6
Fe Cl P
2 2 1
1.4 1.5 1.2

2.1 1.3 2.2
V Ca C K

2

1.0 2.7
Outlet Level II

Level II
Level II
Level II

Level II

Level II
filter

filter
filter
filter

filter

filter
catch

catch;
catch;
catch;

catch;

catch;

0
75 A^
150 A
300 A
e
500 A
O
700 A
45.7

48
48.3
48.3

47.9

47
5.5

7.4
9.1
8.8

7.3

7 3
13.2

11.5
10.0
8.0

6.7

6.1
7.1

9.0
10.1
10.6

10.8

11.6
2.2

5.2
7.7
9.6

13

11.0


1.2
1.2
2.1

1.7

? 3
1.2

1.1
1.2
1.0

1.2

n 9
1.1 0.7

1.1
1.2
1.2 0.5

1.1

1.5 0.5
1.3

1.1



1.2

1 0
14.9

12.1
10.0
8.0

8.1

8.8
7.1

1.8
1.2
1.8

1.1

1 6
    The atom percent of the 12 elements presented here adds up to 100 percent.  Other elements present In
    the cyclone and filter catches were not studied 1n ESCA. Hence, the atom percents 1n this table are
    normalized atom percents and not absolute atom percents.
TABLE 4-19.   DEPTH  PROFILE ANALYSIS OF OIL  PARTICULATE  WITH  CONCENTRATIONS
                EXPRESSED AS NORMALIZED  ATOM  PERCENT*  - TEST 202-4

Inlet
Level
Level
Level
Outlet
Level
Level


II Cyclone Catch
II Filter Catch
II Filter Catch; 76A

II Filter Catch
II Filter Catch; 76A
0

38.5
48.6
46.3

45.5
53.5
Na

3.2
4.2
4.7

5.7
3.2
S

12.9
10.7
6.5

9.7
6.8
S1

2.6
11.8
17.1

14.6
22,0
Al Fe

2.3
3.1
3.3 0.8

3.4 1.3
4.0
Cl

1.4
1.3
1.4

2.3
1.3
P

0.6
1.5
1.1

1.6
1.0
V Ca

1.2
1.7
3.3 0.9

1.7
2.0
C

37.4
17.2
12.9

14.1
6.2
K



117



     The atom percent of the twelve elements presented here adds up to 100 percent.  Other elements
     present 1n the cyclone and filter catches were not studied 1n ESCA.  Hence, the atom percepts 1n
     this table are normalized atom percents and not absolute atom percents.
                                           4-35

-------
     As indicated in Table 4-18, some elements, most notably sulfur and
carbon, appear to be enriched at the particle surface and somewhat depleted
in the bulk of the particle.  The opposite trend is observed for aluminum
and silicon which are enriched in the bulk of the particulate.  These obser-
vations indicate that some degree of surface coating of the particle has
occurred.   Assuming that the bulk of the particulate is homogeneous with
respect to aluminosil icates, the thickness of the surface coating can be
most readily estimated by considering the concentration of coating elements
relative to the concentration of aluminum or silicon.  The relative con-
centration may be plotted as a function of penetration to enable a graphical
estimation of coating thickness.   Aluminum was selected as the reference
element here rather than silicon because the ESCA analyses were run directly
on the filter and the silicon content of the filter would interfere with
interpretation of the data.
     Depth profiles for six  major elements in coal-fired particulates at
the scrubber outlet are depicted graphically in Figure 4-2.  These profiles
show that  sulfur and carbon  are more concentrated near the surface than
deeper inside the particles.  Both the sulfur and the carbon curves, how-
                          o
ever,  level  off after 275 A.  Hence, the thickness of the deposited layer
                                                               o
of sulfur  and carbon compounds appears to be approximately 275 A.   For
sulfur, these data indicate  that v,r  ° there may be higher surface concen-
tration of sulfur containing compounds in the particulates emitted from
the scrubber, some of these  compounds are probably deposited on particles
composed of solid sulfate or sulfite.  This would be the case if sulfuric
acid condensed on the sodium bisulfate (NaHSCL) or calcium sulfite hemi-
hydrate (CaS03'l/2 H20) particles that have been found to be present.   For
carbon, the depth profile data indicate that a fraction of the carbon,
either as  oil soot*, or as a carbon containing compound (such as carbonate
or bicarbonate), could be deposited on the surface of the fine particulates
emitted.  The leveling off of the carbon curve, however, indicates that
another fraction could be emitted as solid oil soot particles or solid
  Oil soot deposited in the duct-work downstream of the boiler durinq
                                                                    J
  oil firing.

                                   4-36

-------
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    fa fD
    -5 T3
    r+ r+
      ' -5
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 i ro

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    ro oo
    CD ->•
    — ' 01
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    — ' O
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       c
       r+

       fD
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      DJ
            <
            QC
        UJ
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        8
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        UJ
                                                                        D CARBON

                                                                        OSULFUR

                                                                           VANADIUM

                                                                        A CHLORINE

                                                                        • IRON

                                                                        • CALCIUM
                               100

-------
carbonate/bicarbonate particles.   The depth profile for iron, vanadium,
chlorine, and calcium is reasonably flat and indicates that the relative
concentrations of these elements  remain approximately constant.
     Although only low penetration analyses were performed on oil-fired
particulates, available data indicate trends similar to those observed
with coal fired particulates.  Elements which appear to be enriched on
the particulate surface include sulfur, phosphorous and carbon.  On the
other hand, vanadium and the typical  ash components aluminum and silicon
appear to be more concentrated in the bulk of the particulate matter.
     The composition of particulate at the scrubber inlet and outlet has
also been determined by PLM analyses.  Estimated weight percentages of
coal- and oil-fired particulate components are presented in Table 4-20.
It may be noted that a substantial fraction of the coal-fired particulates
at both the scrubber inlet and outlet is composed of oil soot.   This is
attributed to particulates deposited  in the boiler during previous oil-
fired operation and subsequent attrition during coal firing.   The increase
in weight percent of oil soot across  the scrubber is consistent with
results of ESCA analyses, as discussed previously.  Both the PLM analysis
and the ESCA analysis have shown  that oil  soot could be emitted as fine,
solid particulates.  Oil-fired particulates at the scrubber inlet are
composed primarily of oil soot, various sulfate/sulfite compounds and
fused ash while the outlet particulate is  composed largely of sulfates
and sulfites.  Noting that the total  quantity of particulate emissions
after scrubbing is comparable for coal and oil firing, these data indicate
that oil soot present during coal firing is finer than that generated
during oil  firing and is, therefore,  not as efficiently removed by the
scrubber.  This is consistent with the observation made during PLM analyses
that oil soot in coal particulate was fragmented while soot in oil partic-
ulates was  present as cenospheres with only partial fragmentation.
     Calcium sulfite hemihydrate  and  unknown sulfates comprise a principal
portion of scrubber outlet sample for both fuels, 50 to 65% for coal
particulate and 80 to 90% for oil particulate.  These materials were also
found to comprise 20 to 39% of the scrubber inlet particulates from oil
firing.  The CaS03'l/2 H20 and unknown sulfates identified at the scrubber
                                   4-38

-------
                 TABLE 4-20.  MAJOR PARTICULATE COMPONENTS
                              DETERMINED BY PLM ANALYSIS*
     Component
CaS03-l/2 H20 and
Unknown Sulfate
                                          Approximate Weight
Scrubber Inlet
                              Coal
            Oil
           20-39
 Scrubber Outlet
Coal
50-65
  Oil
Ash1"
Fused
Unfused
Minerals
Fe2°3
Fe304 (Magnetite)
Si02
CaC03
Oil Soot
Coke

15-30
50-65

1-5
10-15
< 2
10-20
< 2

13-23
1-4

< 1
< 1
5 3
43-57
_ .. _

— —
— —

15-25 8-16
1-5
25-40 2-8
_ _ _ M « •_
80-90
 Coal-fired samples were taken from test 201-1.  Oil-fired samples were
 taken from test 202-4.
t
 This is primarily composed of iron-aluminum silicates.
 outlet  during  coal  firing  are  mostly  generated  by  the  scrubber*.  As dis-
 cussed  previously,  the  unknown sulfates  may  be  composed  primarily of
 sulfuric  acid  aerosol and  sodium bisulfate.   Sulfate data  presented pre-
 viously indicate  that scrubber inlet  oil  particulates  contain  approxi-
 mately  40%  sulfate  ion.  Hence,  the PLM  estimate for CaSOs-1/2  H20 and
 unknown sulfates  weight  percentages of 20 to 39% appear  to be  somewhat
   Strictly  speaking,  CaS03»l/2  H20  is  formed  in  the  regeneration  of
   Na2S03  and  a  fraction  of  it is  carried  over with the  regenerated
          into the  scrubber.
                                    4-39

-------
 low.   Further, the CaSCL-1/2 H?0 would appear to be present only as a
                       0      £•
 minor  constituent.  This may indicate that tabulated inlet weight percent-
 age of oil  soot, the most difficult particulate component to quantify,
 is high with  respect to the true particulate composition.  Similarly,
 sulfate data  indicate that outlet particulates are approximately 63%
 sulfate ion.  Assuming that sulfate ions are combined with calcium or
 sodium, outlet particulates may consist of up to 92% sulfate compounds.
 Hence,  CaSO,-1/2 H20, if present in either the scrubber inlet or outlet,
 appears to  be a minor constituent of particulates generated during oil
 firing.

 Chloride, Fluoride, and Nitrate Emissions
     Specific anion analysis was performed on extracts from particulate
 catches from the Method 5 sampling train.  Emissions data for chloride,
 fluoride, and nitrate are presented in Table 4-21.   In the coal-fired
 test, chlorides and fluorides are removed with high degrees of efficiency,
 at greater than 99% and greater than 85%, respectively.   These are to be
 expected because the overall  removal efficiency of the trace element
 cations is greater than 99%.   In the oil-fired case, the fluoride removal
 efficiency is high, 85 to 89%,  and also corresponds to the trace element
 cation  removal efficiency of 87%.   The lower removal efficiencies for
chlorides  and nitrates in the oil  fired test, about 51% and 57%, respec-
tively, suggest that these anions  may be associated with the finer partic-
ulate  matter which is not efficiently removed by the scrubber.
     Comparison of the coal  and oil  tests shows that considerably higher
chloride and fluoride levels  were  emitted during coal  firing.   In the
case  of chloride,  this is as  expected, because of the  higher chlorine
 level  in the coal  fuel.   However,  in the coal test, only 14% of the fuel
chlorine was analyzed in  the  particulate extract from  the scrubber inlet.
 It is  possible that some  of the chlorine is emitted in the form of acid
 vapors, which would not be detected by analysis of  particulate extracts.
The lower removal  efficiency  of chlorides in the oil  fired test as com-
pared  to coal  firing can  be explained as resulting  from the lower partic-
 ulate  removal  efficiency  for  oil  particulates.
                                   4-40

-------
               TABLE 4-21.   CHLORIDE,  FLUORIDE,  AND NITRATE
                            EMISSIONS  FROM COAL  AND OIL  FIRING
Fuel Test
Inlet
ng/J
Coal 201-1 4.7
011 202-4 0.15
cr
Outlet
ng/J
<0.004
0.072-0.075

Remova 1
Efficiency,
t
>99
50-52

Inlet
ng/J
0.22
0.017
F"
Outlet
ng/J
<0.03
0.002-0.003

Removal
Efficiency,
*
>86
85-89

Inlet
ng/J
<0.48
0.076
N03"
Outlet Removal
ng/J Efficiency,
<0.25
0.033 57
     Comparison of fluoride and nitrate removal efficiencies for the coal
and oil tests is not possible because several of the fluoride and nitrate
concentrations were below the detection limit.

Organics
     Four methods of analysis were utilized in determining flue gas
organic loadings.  Continuous FID analyses were performed to determine
total organic concentrations assuming all carbon to be present as methane.
Bag samples of gas were collected over a 30 to 45 minute period and were
analyzed for organics in the C, to Cg range using a field chromatograph.
A laboratory chromatograph was employed to determine hydrocarbons in the
C-, to C,6 range in samples obtained from the SASS train  (GC/TCO).  SASS
train samples were also analyzed gravimetrically for higher molecular
weight organics.  For identification of organic compounds, infrared
spectroscopy analysis (IR) and low resolution mass spectrometry  (LRMS)
were performed on residues from gravimetric analysis, and samples from a
modified Method 5 sampling train (with an XAD-2 resin module) and from gas
bags were analyzed by gas chromatography/mass spectrometry (GC/MS).
     For C, to C,g organics, the subscripted carbon number refers to a
boiling range rather than a specific molecular structure.  The approximate
boiling ranges corresponding to each carbon are presented in Table 4-22.
A comparison of organic determinations for the coal- and oil-fired tests
is presented in Table 4-23.  Analytical results for the outlet resin
                                    4-41

-------
 samples from the SASS train were not available, so these were calculated
 using data from four oil-fired and ten coal-fired boiler tests which used
 similar sampling trains, and assuming the proportion of organic material
 in the resin sample to the rest of the material trapped in the sampling
 train to be constant.  These calculated values are good to a factor of 3
 to 4.

     Total organics determined as methane by FID show a slight increase
 across the scrubber for both oil  and coal firing.   As mentioned previously,
 this increase was determined to be statistically significant during the
 coal-fired test but insignificant during the oil-fired test.  The reason
for the increase is not known at  this time,   Organics in the C,  to Cfi
range were present, if at all, at sufficiently low concentrations that in
           TABLE 4-22.  APPROXIMATE BOILING RANGES CORRESPONDING
                        TO EACH CARBON NUMBER
Carbon
Number
Cl
C2
C3
C4
C5
C6
C7
C8
Approximate
Boiling Range
-160 to
-100 to
- 50 to
0 to
30 to
60 to
90 to
110 to
-100°C
- 50°C
0°C
30°C
60°C
90°C
no°c
140°C
Carbon Approximate
Number Boiling Range
Cg 140 to 160°C
C1Q 160 to 180°C
C^ 180 to 200°C
C12 200 to 220°C
C13 220 to 240°C
C]4 240 to 260°C
C15 260 to 280°C
C16 280 to 300°C
both tests they were not detected by the field chromatograph.   In the
range of C-, and above, the concentration of higher molecular weight
organics was greater than the concentration of volatiles.
                                   4-42

-------
-P=>

CO
                               TABLE 4-23.   COMPARISON OF ORGANIC DETERMINATIONS
                                            DURING COAL AND OIL FIRING
Method
Total as CH4
(Continuous FID)
CT - Cg (GC on Bag
Samples)
C7 - CIG (GC on SASS
Train Samples)
>C16
(Gravimetric on
SASS Train Samples)
Coal Fired
Test Inlet Outlet % Change
Not
200 3.8 4.6 Significant
200 <5.4 <5.4
200 0.34 0.27* -20
200 2.3 0.33* -85
Oil Fired
Test Inlet Outlet % Change
Not
202-1 2.9 3.3 Significant
202-1 <4.6 <4.6
203 0.17 0.02* -85
203 2.6 0.43* -83
        The values for the resin sample are calculated (see text).

-------
     Comparison of the oil and coal-fired results shows essentially
no difference in the organic loadings from the two fuels.  The rough
distributions of molecular weights are also very similar.  The scrubber
removal efficiencies show some variation:  20% for the Cy to C-|6 fraction,
coal fired, and 83 to 85% for the other fractions for which efficiencies
could be calculated.  However, since the outlet concentrations for the Cy
and above fractions are good within a factor of 3 to 4, the efficiencies
presented actually represent rather wide ranges.   Because the outlet
value for coal organics in the C7 to C,g range is 80% of the inlet value,
the factor of 3 to 4 uncertainty means that the 20% efficiency actually
represents a range of 0 to 97%.   Since the outlet values for the other
fractions are much lower, their  uncertainty affects the calculated
removal  efficiency less:  85% actually represents  a range of 50 to 98%.
Hence,  a conclusive comparison of the C-, to C,g removal  efficiencies for
coal  and oil  firing cannot be made.

      Results of IR analysis on the fractionated XAD-2 resin extracts from
 SASS train samples are presented  in Table 4-24.  As can be seen, the
 blank contained many organic materials presumably released by the resin.
 This was a source of difficulty in interpreting analytical results,
 especially because the amount of  resin-generated material seemed to vary
 from sample to sample.  IR analysis of several of the LC fractions did
 not identify any compounds which  could be directly associated with
 combustion.

      Table 4-25 summarizes the organics that were identified in gas bag
 samples by GO/MS analysis.  Again, none of the compounds is directly
 associated with combustion.  They are, however, representative of the
 types of compounds that are used  in the manufacture of the sample bags
 and the solvents used in the analysis.  This finding is consistent with
 GC,  gravimetric, and FID analyses indicating low organic emissions.
                                   4-44

-------
TABLE 4-24.  SUMMARY OF THE INFRARED ANALYSIS OF ORGANICS
             FROM OIL AND COAL COMBUSTION
Total Organlcs,
mg/m
Category
Aliphatic Hydrocarbons
Aromatic Hydrocarbons
Chlorinated Hydrocarbons
S11 1 cones
Heterocycllc Sulfur
Compounds
TMocarbonyl Compounds
N1tro Compounds
Ethers
Esters
Amides
Alcohols
Glycols
Phenols
Carbox/Hc Adds
Sulfontc Adds
Silicates
»
Not Analyzed.
LCI LCZ LC3 LC4 LC5 LC6 LC7 Total
Coal 011 Blank Coal 011 Blank Coal 011 Blank Coal 011 Blank* Coal 011 Blank Coal 011 Blank Coal 011 Blank Coal 011 Blank
0.14 0.09 0.02 0.06 0.05 0.03 0.12 0.03 0.01 0.37 0.04 0.02 0.95 0.28 0.10 0.06 0.02 1.70 0.51 0.18
Intensity
XM XM XM XM XM XM Xm Xm Xm Xm Xm
Xm Xm Xm XM XM XM XM Xm Xm Xm Xm Xm Xm
Om
Xm Xm Xm Xm Xm
Xm Xm Xm Xm Xm
Xm
XM Xm OM Om On Om
XM
Xm XM XM XM XM XM XM XM XM XM XH Xm
Xm Om OM Om
Xm Xm
XM XM XM XM
Xm OM
Xm XM XM XM XM XM XM
XM
XM
0 = At least one species suspected present. M = Major Component.
X • At least one species present. m • Minor Component.

-------
                  TABLE 4-25.  COMPARISON OF ORGANIC COMPOUNDS  IDENTIFIED  BY  GC/MS
                               IN THE FLUE GAS DURING COAL  AND  OIL  FIRING
Compound
Propionaldehyde
Nitromethane
Ethyl -n-butyl ether
Ethyl acetate
Hydrocarbon (CgH..)
Chloropropanol
4-methyl-3-pentene-2-one
Unidentified alcohol
Octanol
Ketone (MW 138)
Ketone (MW 140)
Phthalic anhydride
Amy! benzoate
Glycerol triacetate
Emission Rate, ng/J
Coal Fired Oil Fired
201-2 201-3 202-2 202-3
Inlet Outlet Inlet Outlet Inlet Outlet Inlet Outlet
0.075 0.17 0.024 — 0.075 — 0.052
0.023
0.88 0.66 0.400 0.66 0.64 -- 0.37
0.85
0.17
0.0017
0.21 0.13 0.01
0.0018
0.017
0.0074
0.0017 — 0.003 — 0.0053
0.011
0.0006
0.016
Methyl substituted
  aromatic
0.00075

-------
Polycyclic Organic Material
     Polycyclic organic material (POM) was not found in the scrubber inlet
or outlet samples at detection limits of 0.3 yg/m  during either coal  or
oil  firing.  This observation is consistent with the findings to date from
the EPA sponsored project  "Emissions Assessment of Conventional Combustion
Sources".  However, two POM compounds for which MATE values are below
        2
0.3 yg/m  are b°nzo(a)pyrene and dibenz(a ,h)anthracene.  The MATE values
                                                           3              3
for benzo(a)pyrene and dibenz(a.h) anthracene are 0.02 yg/m  and 0.09 yg/m .
respectively.  While available data indicate that many POM compounds are
not present at concentration greater than or equal to their MATE value
during oil firing, additional analyses at higher GC/MS sensitivity would
be required to conclusively preclude the presence of all POMs at concentra-
tions above their MATE values.
 Scrubber  Efficiency
      Flue  gas analyses  indicate  that  scrubber processing removes significant
 percentages  of  flue  gas  sulfur oxides  (S02> S03, and SO^"), total particulates
 and  organics  in  the  boiling  range  of  C^ and higher.  Scrubber removal
 efficiency dat;  for  these  flue gas  components are summarized in Table 4-26.
 The  average  removal  efficiencies for  both coal and oil fired tests have
 been  discussed  and compared  in previous subsections.  However, it is important
 to note that  it  is the  C7  and higher  hydrocarbons which are removed with the
 efficiencies  listed.  These  fractions  comprise 38 to 96%  and 32 to 69% of
 the  organics  measured at the scrubber  inlet for the oil- and coal-fired
 tests, respectively.  Hence, based  on  the total organics generated, removal
 efficiencies  of 32 to 84%  for oil  and  25 to 53% for coal were obtained.
 Although  the  average values  for  coal  were lower than 1 -r oil, these values
 were  calculated  using the  20% removal  figure for coal Cy to C^g organics.
 As discussed  previously, this 20%  efficiency for rc?l firing has a higher
 uncertainty  than  the 85% value for  oil firing and, therefore, these effi-
 ciencies  cannot  be reasonably compared.  Other than the inconclusive removal
 efficiency for  C  to C,g coal-fired organics, the data indicate that
 removal efficiency of organics greater than C7 is 83-85% and is essentially
 identical  for coal and  oil firing.
                                    4-47

-------
                            TABLE 4-26.   SCRUBBER EFFICIENCY DURING COAL AND OIL FIRING
I
-P>
CO
Fuel Test
Number
Coal 200
201-1
201-2
201-3
201-4
Average
Oil 202-1
202-2
202-3
202-4
203
Averaqe

so2 so3
97
97 33
97
97
95 32
97 32
97 29
97
97
98 28
__
97 29

S04= Total
Particulates
99
88 99
__
—
99
88 99
88
--
--
60 75
--
60 82

Cy to C"16
Organics
20
--
--
--
--
20
--
—
—
--
85
85

C-)7 and Higher
Organics
85
--
--
--
--
'85
--
—
--
--
83
83

-------
     It is not known by what process organics are so efficiently removed.
There are, however, at least three possible mechanisms:
     •  Sorption - Some organics could adsorb on participates.
     •  Condensation - High-boiling organics could condense
        and be removed as "particulates".
     t  Dissolution - Some organics are partially water
        soluble.  These compounds could be removed by dis-
        solving in the slurry.
     One or any number of these mechanisms may account for the high
removal efficiency of organics.

LIQUID WASTE
     As discussed previously, only one significant waste water stream is
produced.  The stream is a combination of water treatment waste, boiler
blowdown, and acid waste water from elsewhere in the manufacturing facility.
The quality of this combined stream is such that it is acceptable for
disposal into the municipal sewer system.  Liquid streams from the scrubber
operation are passed to the thickener and recirculated to the scrubber after
the filtration step.  There is no direct wastewater discharge from the
scrubber operation, as the process is designed to dispose of all of the
water that enters its system through evaporation and moisture entrained in
the scrubber cake.
     Because several streams are mixed together, it is not possible to
accurately determine what part of the effluent is attributable to the boiler,
However, the flow rate of the combined stream is approximately 10,000
liters/hr (40 gallons/min).

Hater Quality Parameters
     Table 4-27 summarizes the waste water parameters for the combined
waste water streams analyzed during coal and oil firing.  Note that these
values do not represent water produced solely by the boiler but also
include process waste.
                                    4-49

-------
Inorganics - Combined Waste Water Stream
     Analyses of major inorganic cations in the combined waste water stream
during coal and oil firing are presented in Tables 4-28 and 4-29.  These
data are based on the SSMS technique which is accurate to within a factor
of approximately 3.  Of the elevn elements analyzed, none exceeds its MATE
value for either fuel based on health considerations.   However, based on
the factor of 3 uncertainty in SSMS analyses, cobalt,  nickel, copper and
cadmium may exceed their respective ecological  MATE values during coal
firing.  Similarly, nickel  and copper may exceed their ecological MATE
values during oil  firing.

Test

200
201-1
201-2
201-3
201-4
Average

202-1
202-2
202-3
202-4
203
Average
TABLE 4-27.
pH

7.9
7.5
8.2
8.0
7.3
7.8 + 0.4

7.5
6.5
7.5
6.5
6.9
7.0 + 0.5
COMBINED STREAM WASTE
Hardness
(as CaC03) ,
mg/1
COAL FIRING
210
158
135
145
100
150+40
OIL FIRING
105
140
155
150
110
132 + 23
WATER PARAMETERS
Alkalinity
(as CaCOJ ,
mg/1

115
125
130
125
145
128 + 11

135
65
120
50
140
102+42

Cyanide,
mg/1

0
0
0
0
0
0

0
0
0
0
0
0
                                   1-50

-------
          TABLE  4-28.  WASTE WATER INORGANICS FOR COAL FIRING
Trace
Element
Be
F
V
Cr
Co
Ni
Cu
Sr
Cd
Sb
Pb
*
Flow rate

Element
Be
F
V
Cr
Co
Ni
Cu
Sr
Cd
Sb
Pb
mg/1
<0.001
0.8
0.003
0.002
0.1
0.005
0.02
0.5
<0.001
<0.001
0.01
of 10,000 1
TABLE 4-29
mg/1
<0.001
4
0.002
0.02
0.007
0.02
0.02
0.3
<0.001
0.001
0.006
9/hr
<0.01
8
0.03
0.02
1
0.5
0.2
5
<0.01
<0.01
0.1
MATE Value
Health
0.030
38
2.5
0.25
0.75
0.23
5.0
46
0.050
7.5
0.250
iters per hour, combi
WASTE
g/hr*
<0.01
40
0.02
0.02
0.07
0.2
0.2
3
<0.01
0.01
0.06
, mq/1
Ecology
0.055
--
0.15
0.25
0.25
0.010
0.050
--
0.001
0.20
0.050
ned waste
WATER INORGANICS - OIL
MATE Value, mg/1
Health
0.030
38.0
2.50
0.250
0.750
0.230
5.0
46.0
0.050
7.50
0.250
Ecology
0.055
„.
0.150
0.250
0.250
0.010
0.050
--
0.010
0.200
0.050
Degree of
Health
<0.033
0.021
0.0012
0.008
0.13
0.022
0.004
0.011
<0.02
<0.0001
0.04
water.
FIRING
Degree
Health
0.033
0.100
0.001
0.080
0.009
0.087
0.004
0.007
<0.02
0.0001
0.024
Hazard
Ecology
<0.018
--
0.02
0.008
0.40
0.50
0.40
--
<1.0
<0.005
0.20


of Hazard
Ecology
0.018
—
0.013
0.080
0.028
2.00
0.400
--
<0.004
0.005
0.005
Flow rate of 10,000 liters per hour.
                                  4-51

-------
Organics - Combined Haste Water
     Concentrations of C7 to Clg organics measured in the combined waste
water stream are summarized in Table 4-30.   High molecular weight organics
(>C,.-) were detected at a concentration of 0.21  mg/liter during coal firing,
   1 6
but these are probably attributable to process wastes generated at the
manufacturing site.  High molecular weight organics were not detected during
oil firing.  The only organics detected were the C-|g, C^> C^ and C^g
fractions during coal firing and the CIQ, C14 and C15 fractions during oil
firing.  Each of these fractions was detected at or below the 0.1  mg/liter
level  yielding a total output of Cj to C,g organics of 0.4 mg/liter during
coal firing and less than 0.3 mg/liter during oil firing.  As a basis for
comparison, the water MATE values for alkanes, alkenes and alkynes are in
the 500 to 14,000 mg/liter range based on human  health considerations and
in the 1.0 to 100 mg/liter range based on ecological  considerations.  Dis-
charge concentrations of organics in the combined waste water stream are
well within these MATE values for both coal  and  oil firing.

SOLID WASTE
     Three solid waste streams are produced by the system:
     0  Bottom ash;
     •  Fly ash;
     •  Scrubber cake.
     Approximate quantities of bottom ash and scrubber cake produced during
coal and oil  firing are presented in Table 4-31.  Only small  quantities of
fly ash were  collected during the test period due to  malfunction of the
multiclone.  The quantity of bottom ash produced during coal  firing is at
least a factor of 80 larger than that produced during oil firing due to the
difference in fuel  ash contents (9.9% for coal versus 0.02% for oil).
Similarly, the quantity of scrubber cake generated during coal firing is up
to 3 times greater than was produced during oil  firing.  This difference
would be reduced by proper multiclone operation  and the attendant  reduction
in solids content of the scrubber cake during coal  firing.
                                   4-52

-------
       TABLE 4-30.  SUMMARY OF C? - Clg ORGANICS  IN  THE  WASTE WATER
Carbon
Number

C7
C8
C9
C10
cn
C12
mg/1
Coal Firing Oil
*
ND
ND
ND
0.1 <
ND
ND

Firing

ND
ND
ND
0.1
ND
ND
Carbon
Number

C13
C14
C15
C16
Total
C7 " C16
mg/1
Coal Firing Oil

ND
0.1 <
0.1 <
ND

0.4 <

Firing

ND
0.1
0.1
ND

0.3
ND means none detected.
                 TABLE 4-31.  SOLID WASTE PRODUCTION  RATES

Test
200
201-1
201-2
201-3
201-4

202-1
202-2
202-3
202-4
203
Bottom
kg/hr
^80
•^80
^80
•^80
•v-80

< 1
< 1
< 1
< 1
< 1
Ash
yg/J
COAL FIRING
^753
^763
^735
^857
•v738
OIL FIRING
< 7.4
< 7.4
< 7.6
< 8.3
<11.1
Scrubber Cake
kg/hr
1100
1100
1200
850
840

400
550
380
Not
Not
pg/J
10.2
10.5
11 .0
9.1
7.8

2.9
4.1
2.9
Measured
Measured
*
 15 tons per week

^Scaled up to represent scrubbing  of 100% of the  flue  gas for boiler No. 4


                                   4-53

-------
     The scrubber cake produced after filtration has the appearance of a
clayey silt.  Its grain size is quite uniform and characteristic of silty
soils, but its behavior closely resembles a clay in many respects.  As
obtained from the vacuum filter, the scrubber cake consists of small lumps
and appears to be relatively dry; in actuality, however, the water content
generally ranges from about 30 to 50%.
     Assuming that calcium sulfite hemihydrate (CaS03'l/2 h^O) is the
principal product from S02 scrubbing and Na2$03 regeneration, data presented
in Table 4-32 represent the estimated composition of scrubber cake produced
during coal and oil firing.  Scrubber cake produced during coal firing
appears to be composed of 29% fly ash, 24% CaS03-l/2 H20 and 39 to 46% of
unbound water.  However, if the multiclone had been functioning properly
during the test period, more fly ash would be removed upstream of the
scrubber and the fly ash content of the scrubber cake would be lowered pro-
portionally.   The amount of cake produced could be reduced to 600-750 kg/hr,
on a wet basis, assuming a multiclone efficiency of approximately 60 to 80%.
     Although the scrubber cake production rate was not measured for test
202-4, it has been estimated as the average of production rates determined
for other oil-fired tests performed.  Data presented in Table 4-32 indicate
that the scrubber cake produced during oil firing is composed of 44 to 50%
unbound water and at least 47% calcium sulfite hemihydrate.  These data
reflect the low particulate emissions which are characteristic of oil firing
Only 1% of the scrubber cake is estimated to be particulate.  Assuming the
percentage of unbound water associated with scrubber cake particulate to
be the same as the percentage for scrubber cake as a whole, reduction of
the particulate content of the coal  firing scrubber cake to 1% yields
approximately 500 kg/hr of low particulate cake.   This corresponds well
with the oil  firing scrubber cake production rate of 443 kg/hr.
     Although the scrubber cake material  is composed predominantly of
relatively insoluble solids (calcium sulfite, calcium sulfate, and some
calcium carbonate), the intersititial water does contain soluble residues
of lime, sulfate, sulfite and chloride salts.  Trace elements in the fly
ash may also contribute to the leachate from the disposed scrubber cake
and are of special concern.  The concentrations of 20 trace elements in the
scrubber cake during coal and oil  firing  are presented in Tables 4-33 and

                                   4-54

-------
             TABLE 4-32.   ESTIMATED SCRUBBER CAKE MASS BALANCE
Contribution to Scrubber
Component
Fly Ash Removed by Scrubber
CaS03'l/2 H20 Formed from SC"2
Scrubbing and Na2S03 Regeneration
CaS04, CaCOs, NazSOs, Ca(OH)2
NaHS04 and Na2SC>4 Losses (Estimated)
Water
Total
kq/hr
Coal*
324
262
10-85
429-504 1
1,100

Oil*
5
210
6-35
93-222
4431"
Wei
Coal*
29
24
1-8
39-46
100
Cake
qht %
Oil*
1
47
1-8
44-50
100
Coal  firing data are from test 201-1 and oil firing data are from test 202-4,
Total  cake production rate was estimated from the average of tests 202-1,
202-2 and 202-3.

 4-34.   With  respect to human health based MATE values  for solids, boron  is
 the  only trace element from coal  firing which  does  not exceed  its MATE
 value,  and antimony, boron, molybdenum and zinc do  not exceed  MATE values
 during  oil firing.   With respect  to ecology based MATE values  for solids,
 all  trace elements  from coal and  oil  firing exceeded their MATE values
 with the exception  of boron and molybdenum which did not exceed their MATE
 values  during oil  firing.  This is a consequence of transforming a high
 volume, low concentration pollution stream to a low volume, high concen-
 tration stream which can be more  readily contained.  The degree of hazard
 for most of the trace elements in these scrubber cakes is sufficiently high
 to warrant the disposal of these  solid wastes in specially designed
 landfills.
      The concentrations of 20 trace elements present  in the coal firing
 fly ash are presented in Table 4-35.  Again, in almost every case, the
 trace element concentration in the fly ash has far exceeded its MATE value
 for solids.  Trace  element concentrations  in the bottom ash would be
 similar to those of the  fly ash, except  that the more volatile  elements
 and the elements that  form  volatile compounds would be more enriched in
                                     4-55

-------
TABLE 4-33   INORGANIC CONTENT OF SCRUBBER  CAKE FROM
             COAL-FIRING (DRY BASIS)  -  TEST 201-1
Element
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Concentration
ug/g
60,715
1,458
315
532
88
13
141
424
112
47,241
297
51
1,117
114
195
282
256
642
45,310
106
159,409
MATE Va
Health
4SO
180
15
0.5
93
0.1
0.5
1.5
10
3.0
0.5
0.5
150
0.45
5.0
50
0.10
92
160
15

lue, yg/g
Ecology
32
174
0.4
0.1
50
0.002
0.5
0.5
0.1
0.5
0.1
0.2
14
0.02
0.3
0.2
0.05
__
2.0
_-

Degree
Health
126
8.1
21
1,064
0.9
130
282
283
11
15,738
594
102
7.4
253
39
5.6
2,560
7.0
283
7.1

of Hazard
Ecology
1,897
8.4
788
5,320
1.8
6,500
282
848
1,120
94,482
2,970
255
80
5,700
650
1,410
5,120
--
22,655
--

                        4-56

-------
            TABLE 4-34.  INORGANIC CONTENT OF SCRUBBER CAKE
                         FROM OIL FIRING  (DRY BASIS) - TEST 202-4
Element
Ca
Mg

Sb

As
B

Cd
Cr

Co
Cu
Fe

Pb
Mn

Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Concentration
yg/g
200,000
3,799
*
3
*
15
40
*
1
15
*
19
16
2,164
*
6
6
*
14
132
203
36
*
9
239
1,684
37
208,450
MATE Val
Health
480
180

15

0.5
93

0.1
0.5

1 .5
10
3.0

0.5
0.5

150
0.45
5.0
50
0.10
92
160
15

ue, yg/g
Ecology
32
174

0.4

0.1
50

0.002
0.5

0.5
0.1
0.5

0.1
0.2

14
0.02
0.3
0.2
0.05
--
2.0
--

Degree
Health
417
21

0.2

30
0.4

10
30

13
2
721

12
32

0.1
293
41
0.7
90
2.6
11
2.5

of Hazard
Ecology
6,250
22

7.5

150
0.8

500
30

38
160
4,328

60
80

1
6,600
677
180
180
--
842
--

*SSMS  analyses  were  utilized  where  ICPOES  analysis  provided  upper  limit
 data  only.
                                   4-57

-------
TABLE 4-35.  INORGANIC CONTENT OF FLY ASH FROM
             COAL-FIRING - TEST 201-1
Element
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Total
Concentration
pg/g
378
2,478
438
1,015
20
18
434
408
320
129,330
438
121
1,288
165
376
179
378
728
109,450
187
248,149
MATE Val
Health
480
180
15
0.5
93
0.1
0.5
1.5
10
3.0
0.5
0.5
150
0.45
5.0
5.0
0.10
92
160
15

ue, ug/g
Ecology
32
174
0.4
0.1
50
0.002
0.5
0.5
0.1
0.5
0.1
0.2
14
0.02
0.3
0.2
0.05
--
2.0
--

Degree
Health
0.8
14
29
2,030
0.2
180
868
272
32
43,110
876
242
9
367
75
36
3,780
8
684
12

of Hazard
Ecology
12
14
1,095
10,150
0.4
9,000
868
816
3,200
258,660
4,380
605
92
8,250
1,253
895
7,560
__
54,725
--

                     4-58

-------
the fly ash.  Thus,  the  concentrations  of  arsenic,  antimony,  boron,
chromium, manganese,  nickel,  vanadium,  zinc,  selenium  and  zirconium would
all be lower  in  the  bottom  ash.   Oil  firing  produces little or  no  fly ash
and bottom  ash.   As  such, insufficient  material  was available to warrant
analysis.

     An overall  mass  balance  for  the  20 trace elements  has been performed
for coal and  oil  firing  tests.  Mass  balance  results are presented in
Tables 4-36 and  4-37  for coal  and oil firing, respectively.  The percent
of the trace  element  In  the fuel  feed that could be located in  the
effluent streams (i.e.,  scrubber  cake and  scrubber  effluent gas for oil
firing) is  used  as a  measure  of mass  balance  closure.   With the exception
of boron, copper, strontium and zirconium, very  good mass  balance  closure
was obtained  for trace  elements from  coal  firing.   These data support the
reliability and  accuracy of sampling  and analysis of trace elements and
flow rate measurements.

     Although good mass  balance closure was obtained for many trace
elements from oil firing, closure was not  generally as  good as was  observed
during coal  firing.  This is not  entirely  unexpected since concentrations
of most trace elements in fuel and effluent streams are substantially lower
during oil   firing than during coal firing  (Refer to Tables 4-4,  4-33  and
4-34).   Good mass balance closure was obtained for arsenic, boron,
chromium,  cobalt, copper, molybdenum, nickel, vanadium, zinc  and selenium.
Elements  for which effluent flow rates substantially exceeded  input feed
rates,  such  as iron and aluminum,  may show inordinately high  concentrations
in the  scrubber cake due to  the extremely high levels  attained during  coal
firing  and  subsequent contamination of the  recycle scrubber solution.
Magnesium  is the only element for  which  a poor mass  closure cannot  be
attributed  to  either very low element concentrations or possible contami-
nation  of  the  scrubber solution during coal firing.   Available analysis
indicate  that  magnesium was  discharged in the scrubber  cake at a constant
rate  during  both coal and oil firing.   Although this observation may  result
from  changes in the scrubber lime  feed,  a conclusive explanation is not
available  based on existing  data.
                                   4-59

-------
         TABLE  4-36.  MASS BALANCE ON TRACE ELEMENTS - TEST 201-1	

Element    Coal Feed    Scrubber      Scrubber      Bottom and     Percent
                          Cake      Effluent Gas     Fly Ash      Recovery
             g/hr         g/hr          g/hr           g/hr
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
N1
V
Zn
Se
Sr
Al
Zr
2,794
1,270
308
497
8.7
12.7
174
46.1
261
44,455
308
44
1,063
134
171
203
265
247
50,806
980
40,072
962
208
351
58
8.6
93
280
74
31,179
196
34
737
75
151
186
169
424
29,905
70
1.6
0.5
1.1
9.7
1.2
0.04
5.7
0.53
0.88
no
0.92
0.68
1.2
2.8
2.5
2.1
4.3
2.5
no
0.79
30
198
35
81
1.6
1.4
35
33
26
10,346
35
9.7
103
13
30
14
30
58
8,756
15
*
91
79
89
700
79
77
68
39
94
75
100
79
68
107
100
77
196
76
9
*
  For mass balance calculations,  bottom  ash  has  been  assumed  to  have  the
  same trace element concentrations  as  fly ash.  This  is an approximate
  assumption, as some trace  elements  are enriched  in  the fly'ash.

  Percent recovery is defined  as  the  ratio of  the  sum  of the  emissions for
  a trace element to the  trace element  in the  coal  feed.

  Percent recovery for calcium is  not calculated because most of the
  calcium in the scrubber cake is  from  the lime  slurry.
                                   4-60

-------
      TABLE  4-37.   MASS BALANCE OF TRACE ELEMENTS  -  TEST  202-4
Element
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Oil Feed
g/min
16.4
(12. 2)1"
( 2.4)
( 5.9)
(20.9)
(n.o)
3.6
( 3.9)
4.2
36.7
( 7.9)
( 1.2)
( 8.7)
47.7
108.8
8.9
( 2.0)
0.7
10.4
( 0.6)
Scrubber
Cake
g/min
50,000
950
*
0.8
3.9
10.0
0.2
3.9
*
4.7
4.1
541
*
1 .5
4.0
*
3.5
33.0
50.7
9.1
*
2.4
59.8
421
9.2
Scrubber
Outlet
g/min
2.8
1.2
0.2
1.2
1.5
2.6
0.7
0.5
0.3
n.o
0.5
0.2
1.0
7.9
32.3
2.7
0.2
0.04
18.9
0.04
Percent
Recovery
**
>1 ,000
42
68
55
25
125
133
105
>1,000
25
350
52
91
76
133
136
>1 ,000
>1 ,000
>1 ,000

SSMS data were utilized where ICPOES analysis provided upper limit
data only.

ICPOES data from the analysis of scrubber inlet particulates were
utilized when fuel  analysis provided upper limit data only-

Percent recovery of a trace element is 100 times the ratio of its  total
emission rate (scrubber cake plus scrubber outlet) to its feed rate.

Percent recovery for calcium is not calculated because most of the
calcium in the scrubber cake is from the lime slurry.
                                4-61

-------
     Scrubber cakes from coal and oil  firing were also analyzed for
organics but none were detected.  This is to be expected since the con-
centration of organics in the flue gas streams was extremely low.

ANNUAL EMISSIONS
     Estimated annual  controlled and uncontrolled emissions of the major
pollutants are presented in Table 4-38 for both fuels.   These estimates
were computed assuming that the boiler operates at 100% load for 87% of the
year (7,560 hours/year) and that either coal  or oil  is  the only fuel
burned.

AIR QUALITY  ASSESSMENT - COAL AND OIL  FIRING
     Simplified  air quality  models were  used  to  determine  relative air
quality  resulting  from uncontrolled and  controlled emissions.  The ambient
air quality  values are approximate only.  The  emphasis  should  be  placed on
the relative values for each case as  opposed  to  their  absolute values.

     Worst case  weather conditions and typical weather  conditions were
considered.   The worst case  was  assumed  to be  plume trapping.  An equation
proposed  by  Bierly and Hewson  [14]  was  used with the  following assump-
tions:   inversion  height 100 meters, wind speed  1.0 meter/second, D class
stability  (neutrally  stable) in  the mixing layer, and  effective stack
height of 50 m  (1640  ft).  The  typical case was  assumed to  correspond to
the standard Gaussian  convective diffusion equation,  [15].  The  following
conditions were  used:   wind  speed 4.0 meters/second and D  class stability.
These  conditions could reasonably be expected  to occur  almost  anywhere in
the country.  Typical  does not mean average.   It was assumed that all
species were inert.   No  photochemical  reactions  were considered.  (See
Appendix A for details).

     Figures 4-2 through 4-9 present plots of  approximate  ambient air
quality  as a function  of distance downwind from  a single 10 MW equivalent
source.   Data for  N0x,  CO, S02  and particulates  are presented.  The purpose
of  these  figures is not  to attempt to  accurately predict air quality but
to  compare the effects  of  controlled and uncontrolled  emissions under an

                                   4-62

-------
                                                       TABLE  4-38.   ANNUAL  EMISSIONS
                                                                TABLE  4-38.  ANNUAL EMISSIONS
-pa



oo

Pollutant

Gaseous N0x (as N02)
so2
so3
so4
CO
Organics (as CH.)

C7 " C16
>C16
Total Participates
10y


Scrubber Inlet
Coal Firing
500,810
1,127,300
6,184
67,214
16,119
5,870
<5,606
345
2,311
2,991,700
--
--
—
--
Oil Firing
164,230
906,202
7,249
20,894
4,991
2,272
<4,164
155
2,381
53,832
--
--
--
--
kg/year

Coal/011 Coal Firing
3.05 442,520
1.24 36,800
0.85 4,157
3.22 8,110
3.23 14,497
2.58 6,377
<5,606
2.22 274
0.97 335
55.6 18,856
11,691
5,657
1,320
188

Scrubber Outlet
Oil Firing
157,390
24,453
5,183
8,303
4,845
2,500
<4,164
18
392
13,686
11,359
1,642
634
0J


Coal/Oil
2.81
1.51
0.80
0.98
2.99
2.55
--
15.2
0.85
1.38
1.03
3.45
1.93
--
m /year
Liquid Blowdown/Uaste Water
Cooling Water
-v.76,000
^86,000
•v76,000
•v.86,000
•x. 1 -v.76,000
•v. 1 -x-86,000
•x-76,000
-x.86,000
•v- 1
•x. 1
kg/year
Sol id Bottom Ash
Fly Ash
Scrubber Cake
•x- 778,600
-x.1,800,000
0
•x, 7,600
•x-15,000
0
^103 -x. 778,600
•x-120 •x-1,800,000
8,054,100
•x. 7,600
-x-15,000
3,011 ,000
•x-103
•v.120
2.67
                Assuming 100% load,  45 weeks per year  (7,560 hrs/year).



                These values represent the detection limit of the instrument used.



                These values represent oil firing particulate with a  minimum of coal  ash  contamination.

-------
                                   ——— COAL. INLET
                                   — - — COAL. OUTLET
                                   —_— OIL. INLET
                                   	 OIL, OUTLET
                                                       PRIMARY AND SECONDARY
                                                       STANDARD:  ANNUAL
                                                       ARITHMETIC MEAN
100
                                                         '"^"""VWhrT^
                                                                    **imjtijtr.i
                                              8
                                                        T^
                                                        10
I
12
                               DISTANCE FROM STACK, km
    Figure 4-2.   Comparison of NOX  Air Quality Resulting From  Coal
                  and Oil  Firing  Under Worst  Case Weather Conditions
                  (Tests  201-1 and  202-1)
                                      4-64

-------
                                            COAL. INLET
                                   — - — COAL, OUTLET
                                         — OIL, INLET
                                            OIL, OUTLET
                                              PRIMARY AND SECONDARY
                                              STANDARD:  ANNUAL
                                              ARITHMETIC MEAN
                               T	'	1—	T
                                6         8         10
                             DISTANCE FROM STACK, km
Figure 4-3.
Comparison  of  NOX Air Quality Resulting  From Coal
and Oil Firing Under Typical Weather  Conditions
(Tests 201-1 and 202-1)
                                 4-65

-------
   24
   22-
   20- •
   18- •
   16- •
                           THE MOST RESTRICTIVE CO
                           STANDARD IS 10 mg/m3
                           (8-HOUR AVERAGE)
        COAL, INLET
— - — COAL, OUTLET
	OIL. INLET
	—« OIL. OUTLET
CO


"* 14-
   12- •
   10 • •
 I
 5 8 --
 CD
    6 - •
   4 - -
   2 - -
                                       6
                                                              I
                                                             10
                        12
                                  DISTANCE FROM STACK, km
        Figure 4-4.   Comparison  of CO Air Quality Resulting From  Coal and
                      Oil  Firing  Under Worst  Case Weather Conditions
                      (Tests 201-1  and 202-1)
                                         4-66

-------
m

~
o
e

in
 1-
 ui
                          THE MOST RESTRICTIVE CO
                          STANDARD IS 10 mg/m3
                          (8-HOUR AVERAGE)
                                                        COAL. INLET
                                                   	COAL. OUTLET
                                                   — — OIL, INLET
                                                        OIL, OUTLET
    1- -
                                     DISTANCE FROM STACK, km
          Figure 4-5.
Comparison  of CO Air  Quality Resulting From Coal
and Oil  Firing Under  Typical Weather  Conditions
(Tests  201-1  and 202-1)
                                            4-67

-------
    1800
    1800- -
    1400 - •
n
 cc
 i
 8
    1200 - -
1000 • •
     800 - -
     600 ' '
     400 . .
     200- -
                                       COAL. INLET
                                       COAL. OUTLET
                                       OIL. INLET
                                       OIL. OUTLET
                                                 SECONDARY STANDARD:
                                                 MAXIMUM 3-HOUR AVERAGE
                                                 PRIMARY STANDARD:
                                                 MAXIMUM 24-HOUR AVERAGE
                                          PRIMARY STANDARD:
                                          ANNUAL ARITHMETIC
                                     — „ MEAN___ ___  ___
                                         6
                                                               10
                                                                      I
                                                                     12
                                                                                     14
                                      DISTANCE FROM STACK, km
      Figure  4-6.   Comparison of  S02 Air  Quality  Resulting from Coal
                     Oil Firing under Worst Case Weather  Conditions
                     (Tests  201-1 and 202-1)
                                                                         and
                                        4-68

-------
400- -
       COAL, INLET
__-,_«. COAL, OUTLET
•— —•-— OIL, INLET
       OIL, OUTLET
              SECONDARY STANDARD:
              MAXIMUM W-HOUR AVERAGE
                                             PRIMARY STANDARD:
                                             ANNUAL GEOMETRIC MEAN
             ___ — — —. —— -i«
                               DISTANCE FROM STACK, km
 Figure 4-7-   Comparison  of S02 Air Quality  Resulting  From Coal
                and Oil  Firing Under  Typical Weather Conditions
                (Tests 201-1  and 202-1)
                                    4-69

-------
    3000-
]
 1
 Ul
 o

 8
 =  2000
 00
     1000- •
                                 	COAL. INLET
                               	COAL. OUTLET
                               	OIL. INLET
                                     OIL. OUTLET
                                                        ALL PRIMARY AND SECONDARY
                                                        STANDARDS ARE IN THE RANGE
                                                        60
                                        6          8

                                   DISTANCE FROM STACK, km
                                                            10
                                                                       12
                                                                                 14
        Figure  4-8.   Comparison of  Participate  Air Quality  Resulting  from Coal
                      and  Oil  Firing  under Worst Case Weather Conditions
                      (Tests 201-1 and  202-1)
                                          4-70

-------
1000- •
                                                    COAL. INLET
                                             	— COAL. OUTLET
                                             ___ OIL. INLET
                                             	OIL. OUTLET
                                     PRIMARY STANDARD:
                                     MAXIMUM 24-HOUR AVERAGE
                                          SECONDARY STANDARD:
                                          MAXIMUM 24-HOUR AVERAGE
               SECONDARY STANDARD:
               ANNUAL GEOMETRIC MEAN
                                               SECONDARY STANDARD:
                                               ANNUAL GEOMETRIC MEAN
 100- •
 Figure  4-9.
                  6        8        10
                 DISTANCE FROM STACK, km
Comparison of Participate Air Quality Resulting From
Coal and Oil Firing Under Typical Weather Conditions
(Tests 201-1 and 202-1)
                                4-71

-------
  arbitrary but realistic set of meteorological  conditions.   It is implicit
  in this approach that each set of meteorological  conditions  remains con-
  stant for a sufficient length of time for the  ambient  air  quality to reach

  steady state conditions at each distance.   Note  also  that  the plots re-
  present a single line extending directly  downwind  from the source.


       Table 4-39 presents  a summary of the  federal  ambient  air quality

  standards for each  pollutant.   The standards were  also shown  on  each plot.
             TABLE 4-39   NATIONAL AMBIENT AIR QUALITY STANDARDS
                          FOR CRITERIA POLLUTANTS
   Pollutant
                Pollutant Standard
       Primary*                    Secondaryt
Nitrogen Dioxide


Carbon Monoxide
Sulfur Dioxide
Total  Suspended
  Particulate
100 yg/m  (0.005 ppm)
annual arithmetic mean.

10 mg/m3 (9 ppm)
maximum 8-hour average;
40 mg/m3 (35 ppm)
maximum 1-hour average.

80 yg/m3 (0.03 ppm)
annual arithmetic mean;
365 yg/m3 (0.14 ppm)
maximum 24-hour average,
                               3
75 yg/rrf' annual geo-
metric mean:  260 yg/m
maximum 24-hour average.
Same as primary
Same as primary
1300 yg/m3 (0.05 ppm)
maximum 3-hour average
60 yg/m  annual geo-  .,
metric mean:  150 yg/m
maximum 24-hour average.
k
 Primary, necessary to protect the public health.

 Secondary, necessary to protect the public welfare.

-------
     Keeping in mind the caveats mentioned above, several observations can
be made:

     •  The NOX standard is exceeded under both weather conditions
        during coal firing.  Peak concentrations at 1.2 km from
        the stack were 3 to 4 times greater during coal firing than
        during oil firing.  During oil firing, the NOX standard was
        exceeded under worst case weather conditions but not under
        typical weather conditions.  Since the scrubber does not
        remove significant amounts of NOX, there is no substantial
        difference between the air quality resulting from inlet
        and outlet emissions.  (The boiler has no NOX controls.)

     •  CO standards are not exceeded under any conditions.  The
        most restrictive standard is 10 mg/m3 (10,000 yg/m3) and
        the maximutr, predicted level is only about 0.2% of this
        value.  As with NOX there is no substantial difference
        between the inlet and outlet concentrations.  Peak con-
        centrations at 1.2 km from the stack were 3.5 to 4 times
        greater during coal firing than during oil firing.

     •  All primary S02 standards are exceeded under both weather
        conditions for uncontrolled emissions from coal firing.
        Peak uncontrolled S02 concentrations were 1.7 times
        greater during coal firing than during oil firing.  Un-
        controlled emissions from oil firing exceeded both primary
        standards under worst case conditions.  Under typical
        conditions only the annual primary standard is exceeded
        by uncontrolled emissions.  For controlled emissions
        during both coal and oil firing, no standards are exceeded.

     •  During coal firing, all particulate standards are exceeded
        under both weather conditions for uncontrolled emissions.
        Peak concentrations at 1.2 km from the stack were approxi-
        mately 23 times greater for coal firing than for oil
        firing.  During oil firing, one primary and both secondary
        standards are exceeded by uncontrolled particulate
        emissions under worst case weather conditions.  No
        standards are violated under typical weather conditions
        during oil firing.  Controlled emissions for all cases
        are less than all particulate standards.
                                   4-73

-------
CONCLUSIONS
1)   Uncontrolled emissions of criteria pollutants produced during coal
     firing correspond well with emission factors from AP-42.  This
     observation does not generally hold true for oil  fired emissions.
     Full load NO  emissions from oil  firing were 19% lower than the AP-42
                 A
     emission factor, although they appear to be within the normal range
     for similar industrial units.  CO emissions from oil firing were
     nearly 63% lower than the AP-42 emission factor.   Oil-fired S02 and
     total hydrocarbons correspond well  with their respective AP-42
     emission factors.  Particulate emissions from oil firing, in the
     absence of coal  ash contamination, are approximately twice the value
     tabulated in AP-42.

2)   NO  emissions increased with increasing load for both coal and oil
       A
     firing, as expected.  Available data indicate that for boiler loadings
     between 90 and 100%, NO  emissions from c<
                            X
     three times greater than from oil firing.
between 90 and 100%,  NO  emissions  from coal  firing  are approximately
                       X
3)   Observed reductions of NO  em^-ions for coal  firing and early oil
                              A^
     firing tests appear to be due, at least in part, to air leakage into
     the scrubber outlet sampling line.   Data from  later oil firing tests,
     not known to be subject to leakage  problems, indicate that NO
                                                                  A
     removal  across the scrubber is on the order of 2%.

4)   Uncontrolled CO emissions from coal  firing were 15.9 ng/J (0.04 lb/
     MM Btu)  while those from oil  firing  were 5.47  ng/J  (0.01 Ib/MM Btu).
     This factor of three difference is  at variance with AP-42 data
     indicating that CO emissions from oil firing are 23% lower than those
     from coal firing.   Apparent reductions in CO emissions across the
     scrubber are not considered significant due to air  leakage in the
     sampling train and the low sensitivity of analysis  at the measured
     CO concentrations.
                                   4-74

-------
5)   Uncontrolled S02 emission rates during coal and oil  firing were
     1112 ng/J (2.59 Ib/MM Btu) and 993 ng/J (2.31  Ib/MM Btu),  respectively.
     Removal  data indicate an average scrubber removal  efficiency of 97%
     during both coal and oil firing.  Controlled S02 emissions for coal
     and oil  firing were 36.3 ng/J (0.08 Ib/MM Btu) and 26.8 ng/J (0.06
     Ib/MM Btu), respectively, which are lower than either existing or
     proposed NSPS limitations.

6)   Particulate loadings prior to scrubbing were 2951  ng/J (6.86 Ib/MM Btu)
     during coal firing and 59.0 ng/J (0.14 Ib/MM Btu)  during oil firing,
     in the absence of coal ash contamination.  Scrubbing removed 99% of
     the coal fired particulates and 75% of the oil-fired particulates.
     The lower removal efficiency obtained during oil firing is attributed
     to the increased fraction of particles smaller than 3 ym;  at least
     21% of the uncontrolled oil-fired particulates are less than 3 ym
     in diameter while substantially less than 1% of uncontrolled coal-
     fired particulates are under 3 ym.

7)   There appeared to be a net increase in emission rates across the
     scrubber for coal fired particulates less than 3 ym in size.  This
     net increase can be attributed to the poor removal efficiency of the
     scrubber for fine particulates, and to the sodium  bisulfate (NaHSO^)
     and calcium sulfite hemihydrate (CaS03*l/2 H20) particulates generated
     by the scrubber.  Both NaHS04 and CaSCyi/2 H20 have been  identified
     at the scrubber outlet but not at the inlet.  Although a very slight
     increase in oil-fired particulates in the 1-3 ym range was observed,
     a net decrease in particulates less than 3 ym was  observed during  oil
     firing.   Based on the results of coal firing tests, it appears reason-
     able that scrubber generated particulates were present in  the scrubber
     outlet stream during oil firing but that the high  fine particulate
     loading  associated with oil firing masked detection of these materials.
                                   4-75

-------
 8)  Of the 22 major trace elements analyzed in the flue gas stream
     during coal firing, 18 exceed their MATE values at the scrubber
     inlet and 4 at the scrubber outlet.  Similarly, for oil firing,
     11 exceeded their MATE values at'the scrubber inlet while 5 exceeded
     their MATE values at the scrubber outlet.   Elements exceeding their
     MATE values at the scrubber outlet and which are common to both
     fuels are arsenic, chromium and nickel.  Additionally, iron exceeded
     its MATE value at the scrubber outlet during coal  firing as did
     cadmium and vanadium during oil firing.  The overall  removal  of
     trace elements across the scrubber is 99% for coal  firing and 87%
     for oil firing.

 9)  Polycyclic organic material  (POM) was not found in the scrubber
                                                    3
     inlet or outlet at detection limits of 0.3 ug/m  for either coal  or
     oil firing.  MATE values for most ROM's are greater than this detec-
     tion limit.  However, since the MATE values for at least two  POM
     compounds - benzo(a)pyrene and dibenz(a,h)anthracene - are less than
             3
     0.3 yg/m , additional GC/MS analyses at higher sensitivity would  be
     required to conclusively preclude the presence of all  POM's at MATE
     levels.

10)  Beryllium emissions after scrubbing were less than  or  equal to the
     beryllium MATE value during  coal  and oil  firing.   At  the measured
     emission  concentrations, the National  Standard for  Hazardous  Air
     Pollutants limitation of 10  grams beryllium per day would only be
     exceeded  by boilers of 50 MW capacity for  coal  firing  and 100 MW
     capacity  for oil  firing.

11)  The combined waste water stream from the boiler operation may
     not pose  an environmental  hazard  in terms  of organic materials
     since the discharge concentrations  of organics are  well  below their
     MATE values for both coal  and oil  firing.   The same conclusion may
     be drawn  for inorganic compounds  with the  exception of cobalt, nickel,
     copper and cadmium for coal  firing  and nickel  and  copper for  oil  firing
     since these metals may exceed their MATE values.
                                   4-76

-------
12)  Organic emissions for coal and oil firing were very similar.   Total
     organic emissions were less than 9 ng/J (0.02 Ib/MM Btu) for  both
     tests, and these emissions appear to be primarily C,  to Cg hydrocarbons
     and organics heavier than C^.  While uncontrolled emission rates for
     both coal and oil firing are low, emissions of these organics were
     further reduced by about 85% in the scrubber unit.

13)  The organic compounds identified in the gas samples from both coal
     and oil firing were generally not representative of combustion-
     generated organic materials, but were compounds associated with
     materials used in the sampling equipment and in various analytical
     procedures.  This again confirms the low level of organic emissions.

14)  The fraction of fuel sulfur converted to SO-, during oil firing was
     50 to 75% higher than during coal firing.  In contrast, the fraction
     of fuel sulfur converted to sulfates during coal firing was twice
     that during oil firing.

15)  The relatively poor removal efficiency (approximately 30% in  both
     oil and coal-fired tests) for SO- across the scrubber is an indication
     that $03 is either present as very fine aerosols in the scrubber
     inlet, or is converted to very fine aerosols in the flue gas  stream
     as it is rapidly cooled inside the scrubber.

16)  Sulfates are more efficiently removed than S03  (60% removal for oil
     firing and 88% for coal firing).  This indicates that S04~ is probably
     associated with the larger particulates, which are more efficiently
     removed than smaller particulates.  The higher sulfate removal from
     the coal flue gases is explained by the higher particulate loading
     during coal firing.
                                   4-77

-------
 17)  Uncontrolled chloride and fluoride loadings were higher during coal
     firing (5 and 0.2 ng/J, respectively) than during oil firing (0.2 and
     0.02 ng/J, respectively).  This was attributed, in the case of
     chlorides, to a higher fuel chlorine content for coal than for oil.
     Chlorides were removed with better than 99% efficiency from coal flue
     gases and with about 51% efficiency from oil flue gases.  This
     difference was attributed to the higher particulate removal efficiency
     for coal particulates.  Fluorides were removed with greater than 86%
     and about 87% efficiency for coal and oil firing, respectively-
     Uncontrolled nitrate emissions were 0.08 ng/J during oil firing, and
     nitrates were removed from oil flue gases with 57% efficiency.

 18)  Mass closure for most trace elements from coal  firing has been found
     to be in the 75 to 107% range.  Mass closure for half of the trace
     elements from oil-firing is in the 50 to 136% range; closure for the
     remainder of oil  firing trace elements is poorer due to the extremely
     low elemental concentrations measured and/or contamination of the
     recycle scrubber solution during coal firing tests.

 19)  Scrubber cake production during coal firing was 3.3 times greater
     than during oil  firing.   Had the multiclone unit been functioning
     properly, this ratio would be reduced to 2.7, assuming 60% multiclone
     efficiency.  Available data indicate that the principal  difference
     between scrubber cake production rates from coal  and oil  firing is
     the particulate loading and associated unbound  moisture.
20)  The scrubber  cake  produced during coal  firing contained  29% cpal  fly
     ash;  during oil  firing it contained 1% oil  fly  ash.   The  trace  ele-
     ment concentrations  in the coal-fired scrubber  cake exceeded  their
     health  based  MATE  values,  with the  exception of boron.   In  the  oil-
     fired  scrubber cake,  all  trace elements  except  antimony,  boron,  moly-
     bdenum  and  zinc  exceeded their health based  MATE  values.   All  ecology
     based  MATE  values  were exceeded  by  trace  element  concentrations  during
     both oil  and  coal  firing.   Because  the trace elements  may leach  from
     the disposed  scrubber cake,  these solid  wastes  must be disposed  of in
     specially designed landfills.
                                   4-78

-------
                          REFERENCES FOR SECTION 4


1.    Sarofim, A.F. and R.C. Flagan.  NOX Control for Stationary Combustion
     Sources Prog. Energy Combust. Sci., Volume 2, 1976.

2.    Magee, E.M., H.J. Hall and G.M. Varga, Jr.  Potential  Pollutants  in
     Fossil Fuels.  Report prepared by ESSO Research and  Engineering  Co.
     for EPA under contract No. 68-02-0629.  June 1973.

3.    Ruch, R.R., H.J. Gluskoter and N.F. Skimp.  Occurrence and Distribution
     of Potentially Volatile Trace Elements in Coal:  A Final  Report.
     Illinois State Geological Survey Environmental  Geology Notes.   Number
     72.  August 1974.

4.    Hamersma, J.W. and M.L. Kraft.  Applicability of the Meyers Process
     for Chemical Desulfurization of Coal:  Survey of Thirty Five Coals.
     Report prepared by TRW Systems Group for EPA under contract No.
     68-02-0647.  September 1975.

5.    Koutsoukos, E.P., M.L. Kraft, R.A.  Orsini, R.A. Meyers, M.J. Santy,
     and L.J. Van Nice.  Meyers Process  Development for Chemical Desul-
     furization of Coal, Vol. I.  Report prepared by TRW  Systems Group for
     EPA under contract No. 68-02-1336.   May 1976.

6.    R.A. Woodle and W.B. Chandler, Jr.   "Mechanism of Occurrence of
     Metals in Petroleum Distillates".  Industrial and Engineering Chemistry
     44: 2591 , November 1952.

7.    R.L. Bennett and K.J. Knapp.  "Particulate Sulfur and Trace Metal
     Emissions from Oil-fired Power Plants".  Presented at AIChE meeting.
     June 1977.

8.    Compilation of Air Pollution Emission Factors, AP-42, Part A.   Third
     Edition.  U.S. Environmental Protection Agency.  August 1977.

9.    Cato, G.A. , L.J. Muzio and D.E. Shore.  Field Testing:  Application
     of Combustion Modifications to Control Pollutant Emissions from
     Industrial Boilers - Phase II.  Report prepared by KVB for EPA under
     contract No. 68-02-1704.  April 1976.

10.  Steam-Electric Plant Air and Water Quality Control  Data.   Federal
     Power Commission.  March 1975.

11.  Kircher, J.F., A.A. Putnam, D.A. Ball, H.H. Krause,  R.W.  Coutant,
     J.O.L. Wendt and A. Levy.  A Survey of Sulfate, Nitrate and Acid
     Aerosol Emissions and their Control.  Report prepared by Battelle-
     Columbus Laboratories for EPA under contract No. 68-02-1323.  April
     1977.
                                   4-79

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12.  Proceedings:   Symposium on  Flue  Gas  Desulfurization.   Hollywood,
     Florida.   November 1977.

13.  Cleland,  J.G.  and G.L.  Kingsbury.  Multimedia  Environmental  Goals
     for Environmental  Assessment,  Volume^  1  and  II,  EPA-6GO//-/7-I36a,
     November  1977.

14.  Bierly, E.W.  and  E.W.  Hewson.  Some  Restrictive  Meteorological
     Conditions  to  be  Considered  in the Design of Stacks, J. Appl. Meteor.,
     1,3,  Pages  383-390.   1962.

15.  Turner, D.B.   Workbook  of Atmospheric  Dispersion Estimates.  U.S.
     Department  of  Health,  Education  and  Welfare.   1969.
                                  4-80

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                                SECTION 5
             COMPARATIVE ENVIRONMENTAL IMPACT ASSESSMENT

     Future energy policies will affect the social, economic, energy, and
physical environments.  One of the major policy issues involves intensifi-
cation of coal utilization and the effects of end use of coal relative to
fuel oil.  It is essential that these effects be determined so that national
energy policies involving the alternative energy systems may be developed.
     This section evaluates the difference in impacts resulting between
emissions from coal and oil combustion in industrial boilers.  Absolute im-
pacts resulting from either oil or coal combustion are also analyzed to the
extent necessary to evaluate the significance of the differential  impacts.
The analysis is conducted in five parts.  The first part introduces back-
ground information pertinent to the development of the environmental assess-
ment, including a review of relevant studies, plant emissions, and air
quality forecasts.  In the succeeding parts, the major health, ecological,
societal, and economic impacts resulting from oil and coal-firing  in well-
controlled boilers are estimated.  The final section assesses the  implica-
tions of the impacts for energy development by considering:  1) the addi-
tional controls which may be needed to mitigate the expected damage levels,
and 2) the potential effect of such control needs on energy cost and
energy resource development.
INTRODUCTION
     Economic and environmental concerns over the nation's energy  develop-
ment policies have precipitated several research efforts to evaluate the
consequences of the various energy system alternatives.  These efforts deal
with all phases of energy development, from fuel production to fuel end use.
To organize the various efforts into a systematic, coordinated, environ-
mental assessment structure, the Environmental Protection Agency is imple-
menting a Comprehensive Combustion Environmental Assessment  (CCEA) Program.
This program has been established for the purpose of integrating together
separate data generated by past and current studies into a complete environ-
mental assessment of conventional combustion processes.  The integration
procedure involves coordination and information exchange between EPA related
studies to:  1) determine the extent to which the total environmental,

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economic, and energy impacts of conventional combustion process can be
assessed, 2) identify additional information needed for complete assessment,
3) define the requirements for modifications or additional developments of
control technology, and 4) define the requirements for modified or new
standards to regulate pollutant emissions.  The CCEA Program coordinates
and integrates current and future studies encompassing a wide spectrum of
environmental assessment areas and conventional combustion processes.  Inte-
gration of these studies, including the present effort, will  provide the
basis for energy policies which result in the expanded use of conventional
combustion processes at reasonable environmental, economic, and energy
costs.
     A major research program of particular significance to the industrial
combustion assessment activities is the Integrated Technology Assessment
(ITA) Program.  One current study [12] under the ITA Program will examine growth,
impacts, and characteristics of the industrial  boiler sector under alter-
native energy, economic, and environmental policies.  This study is to be
coordinated under the CCEA Program and will accept the range of data
available from CCEA program outputs, including data from the present study.
Ultimately, the ITA study will develop an industrial combustion environmental/
economic model and combine this with the simulation model  of the electric
utility system (already under development in a related ITA  study) to permit
interactive examination of economics and energy policies, and regulations for
each combustion sector.
     Various studies of the CCEA/ITA Program are relevant to the present
study.  While there are major uncertainties associated with the findings of
the various studies, and many improvements in the analyses are needed before
the extent of environmental effects can be determined with certainty, the
conclusions and findings are important and the methodologies  used in the
analyses are valuable tools which are considered and utilized in the present
effort.  This study contributes to reducing the uncertainties by alleviating
two major drawbacks common to previous studies.  First, previous studies
evaluated the effect of coal combustion on an absolute basis, without com-
parison to the effects of alternative fuel uses or a "business as usual"
fuel use scenario.  If coal is to be used instead of other fuels, the real
impact of this use is the difference between the effects of the coal use and
the other probable alternatives.  The present study addresses this issue by
                                    5-2

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developing a comparative environmental assessment between the emissions
resulting from coal combustion and the most probable alternative, oil
combustion.  Second, the previous analyses rely on limited emissions data
and numerous assumptions regarding the probable magnitude of the "regulated
pollutants" and especially the trace contaminants.  The present study avoids
the need for these assumptions by generating actual emissions test data
for both coal firing and oil firing at a representative industrial boiler
site using typical fuels.  The tests are plant and fuel specific, and
caution should be used in extrapolating study results to the continuum
of probable boiler and fuel scenarios.
Plant Emissions
     Emissions data from the previous chapters reveal there are significant
differences between emissions from 'controlled oil  and  coal-fired  boilers
of 10 MW capacity.  Table 5-1 reviews the distinctions for the various
pollutant species.  Emissions of nitrogen oxides  (NO ) from coal firing are
                                                    /\
twice the level produced during oil firing.  For both oil and coal firing,
the total NO  emission rate exceeds the rates permitted by the New Source
            A
Performance Standards (NSPS) for larger utility boilers.  However, this is
not surprising since the boiler was not equipped with NO  control equipment.
                                                        P\
The emissions rates for particulates and sulfur oxides (SO ) are essentially
                                                          X
the same for both oil and coal firing, and the level of these emissions is
relatively low considering the level which is permitted by the NSPS for
larger utility boilers.  The particularly low level of S02 emissions (despite
the use of high sulfur fuels) observed in tests was due to the high effi-
ciency (greater than 95%) of the flue gas desulfurization system.  This
system, plus mechanical separators, is also effective in removing particulate
matter.  Emissions of carbon monoxide (CO) during  both oil and coal firing
are relatively insignificant, and coal firing produces about two to three
times the amount of CO as oil-firing.
     Emissions of trace elements (as particulates) during controlled
coal firing are not significantly different from  that occurring  during oil
firing (Table 5-1).  This occurs despite the fact  that,  prior  to  control,
combustion flue gases contained appreciably greater concentrations of  trace
elements than the oil-fired flue gases.
                                    5-3

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                                   TABLE 5-1   EMISSION RATES FROM A WELL-CONTROLLED
                                               OIL- AND COAL-FIRED INDUSTRIAL BOILER
en
Pollutant
so2
NOX
Particulates
CO
As
Cd
Co
Cr
Cu
Mo
Ni
Pb
Se
Emissions, gm/sec for 10 MW Boiler9
Coal Firing'3
1.10 (15.8)
12.8 (8.8)
.59 (1.4)
.44
2.7 X ID'3
1.2 X 10"5
1.5 X 10"4
1.6 X 10~3
2.4 X 10"4
3,3 X 10-4
7.7 X ID'4
2.6 X KT4
1.2 X 10-3
Oil Firingb
1.17 (13.1)
6.06 (4.8)
.73 (1.6)
.17
3.2 X 10-4
7.0 X 10"4
1.3 X 10~4
1.9 X 10"4
7.4 X 10"5
2.6 X 10-4
2.2 X lO-3
1.4 X 10-4
6.4 X 10-5
     Data are based on 2 separate tests of nearly equivalent boiler loading (100% capacity during oil burn-
     ing and 97.5% during coal burning).  The composition of the fuels which were used in the test burns is
     discussed in Chapters 5 and 6.
     Figures in  parentliesis  are emission  levels corresponding to new source performance standards for utility
     boilers to  a  10  MW  industrial  boiler.

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Impact on Air Quality
     The duration of exposure is important in determining effects of
changing air quality.  The highest concentrations occur for short periods
(usually less than one hour) under meteorological conditions causing plume
fumigation.  The stack emissions are trapped under an inversion layer,  with
the plume spreading downward.  The frequency of occurrence and the severity
of such fumigation conditions varies depending on the site.  As a conser-
vative worst case estimate in this study, fumigation conditions were
assumed to persist for periods as long as three hours.  Typical 24 hour
maximum concentrations were estimated assuming Gaussian steady state plume
dispersion under conditions of low wind speed and stable atmosphere.
Typical 24 hour levels were translated to annual expected concentrations
by applying ratios for the one day maximum and annual mean as empirically
derived from the Continuous Air Monitoring Project [18,19,20,21],  Effective
stack heights were estimated based on assumed meteorological conditions and
actual stack parameters measured during the oil and gas-firing tests.
     Table 5-2 shows the maximum predicted levels for "criteria pollutants"
in the vicinity of an industrial plant.  The short term maximum concentra-
tions present the most significant air pollution problem.  Of the present
ambient air quality standards, the 24 hour NO  standard appears to be  the
                                             J\
most difficult for either coal or oil-fired facilities to meet.  Coal-firing
is more apt to produce violations of the federal ambient standards for NO
                                                                         /\
as the forecasted maximum incremental increase in ambient NOX from a
single plant alone is more than one-half the ceiling level imposed by  the
NAAQS ceiling value.  The next most difficult air quality standards for the
coal and oil-fired boiler to meet are short term standards for S0£ (3  hour
average).  Coal-firing and oil-firing are estimated to cause maximum incre-
ments of 50 and 33 g/m , respectively, directly downward of the source.
For the case of CO and total suspended particulates, the estimated short
term increases from both oil and coal combustion are appreciably less  than
the ambient standards.  For any of the pollutants, it should be noted that
the short term maximum concentrations generally occur infrequently  (depending
on site meteorology) and are usually of very brief duration (usually about 1
hour or less).
                                    5-5

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TABLE 5-2.  COMPARISON OF FEDERAL AIR QUALITY  STANDARDS  WITH  AIR QUALITY  PREDICTED
            TO RESULT FROM OIL AND COAL COMBUSTION IN  A  10  MW INDUSTRIAL  BOILER

S02
Single plant, coal
Single plant, oil
Cluster of plants,0 coal
Cluster of plants,0 oil
MAAQS
PSD Class I incrementd
PSD Class II increment01
Total Suspended Participates
Single plant, coal
Single plant, oil
Clustered plants,0 coal
Clustered plants,0 oil
NAAQS
PSD Class I increment
PSD Class II increment
3
Maximum Concentration, ug/m
1-3 Hour9

50
33
225
150
1300 (3 hrs.)
25 (3 hrs.)
700 (3 hrs.)

26
21
118
95



24 Hourb

12
8
50
33
365
5
100

7
5
29
21
260
10
30
Annual Average6

3
2
13
8
80
2
15

2
1
7
5
75
5
10

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                           TABLE 5.2.  (Continued)
en
I
NOX
Single plant, coal
Single plant, oil
Clustered plants,0 coal
Clustered plants,0 oil
NAAQS
CO
Single plant, coal
Single plant, oil
Clustered plants,0 coal
Clustered plants,0 oil
NAAQS


582
170
2640
770


20
5
400
157
40,000 (1 hr).
1,000 (8 hrs)

146
43
400
180
250

5
1.2
21
5



39
11
100
45
100

1
0.3
5
1


      Based on worst case meteorological conditions (plume fumigation).

      Based on typical meteorological conditions for 24 hour period.

     °As a crude means of approximating the effect of an aggregate of plants, the 3 hour and 24 hour levels
      were adjusted by assuming the additive effect of a plant "cluster."  A cluster of plants was assumed to
      consist of a line of 5 industrial boilers (10 MW each) spaced equally at 200 m apart and aligned with
      the prevailing wind direction.

      Prevention of significant deterioration standards.

     eThe expected annual average levels were estimated based on the conservative end of the range of typical
      ratios for 24 hour maximum to annual averages as reported in the Air Quality Criteria Documents [18,19,20,21]

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z
UJ
O
Z
o
o
        For example,  Figure  5-1  shows  that  the  short  term peak resulting from coal
        firing would  be  attained  about 1000 m downwind  and that ambient concentra-
        tions would be diminished to one-half the  peak  level  another 2000 m further
        downwind.   The maximum concentration due to oil  firing occurs further down-
        wind (due  to  a higher plume rise) at 'about 1200 m from the source, diminish-
        ing to one-half  this value about 2500 m further downwind.
      50 - •
      40 - -
      30 - •
      20 - •
      10 - -
                          12     16     20     24     28     32     36

                           DISTANCE FROM SOURCE, HUNDREDS OF METERS
40
          Figure 5-1. Ground  level  concentration  of  S02  in  vicinity of
                      industrial  boiler  under  conditions  of plume  fumigation.
             Federal standards limiting deterioration of  air quality  are  generally
        more  restrictive than the NAAQS,  Table  5-2  lists  the  allowable  increment
        of  deterioration for the three classes of  growth  and development  areas.
        Based on  the maximum concentrations of S02 and TSP resulting  from either
        coal  or oil-firing, industrial boilers would not  be permitted in  Class  I
        areas (areas meant  to be maintained pristine) but might  be  permitted in
                                           5-8

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Class II or III areas, depending on the existing air quality.  Consequently,
siting of the plants would be a major consideration in their environmental
acceptability, since areas which already experience marginally acceptable
air quality could not tolerate the increases projected to occur.  In this
respect, it appears that the deterioration standards pose a slightly more
difficult attainment problem for coal-fired  plants  than for oil-fired plants.
     Table 5-2 also shows the estimated impact on air quality for a cluster-
ed configuration of industrial plants.  The estimates are based on the
additive result of ambient levels contributed by multiple sources for a
siting scenario in which five 10 MW industrial boilers are spaced 200
meters apart in a line.  The scenario is by no means the most adverse case
probable for an industrial setting.  Many industrial zones may contain a
greater concentration of sources, and sources of greater magnitude as well.
However, the siting scenario of the four clustered plants illustrates the
potentially high short term concentrations which may occur when well-con-
trolled oil or coal-fired industrial boilers are sited closely together,
and underscores the necessity for careful siting of sources to avoid poten-
tial violations of the NAAQS and Significant Deterioration Amendments.
      Fuel  selection  exerts  a  significant role  in  the  environmental  accepta-
 bility  of the  clustered  array  of  plants.   Table 5-2 shows  that  short  term
 ambient levels  of NO   in the  vicinity of the cluster  will  violate  the NAAQS
                     s\
 when boilers  are  coal-fired  but will  meet  standards when  oil  is  burned.
 This  finding  applies  to  a boiler  operating without  NO  control.  Burning
                                                      /^
 of coal  also  produces  concentrations  of CO four times that estimated  for
 oil  burning,  however,  the magnitude  of the CO  levels  are  inconsequential
 with  respect  to  the  NAAQS.   Coal-burning produces only  slightly  higher
 levels  of TSP  and S02  than oil-burning.
 COMPARATIVE HEALTH  IMPACT
     The health effects  of exposure to  high  concentrations of the
 various pollutants are well known and  have been tabulated throughout the
 literature, [4]. However, the specific  extent  to which  health is affected by
ambient pollutant exposure levels  (dose response relationships)  is  unclear.
Moreover,  it is unclear  how pollutant  specific dose response  curves may be
related to the over all  health effects  of  the  gas-aerosol complex  associated
with fossil fuel  combustion products.

                                    5-9

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     Most attempts to establish dose response functions for ambient  pollu-
 tion levels involve the formulation of some indicator which is  then  assumed
 to  represent the entire spectrum of primary and secondary  pollutants present.
 The  indicator  (usually sulfur dioxide, total particulates, or sulfates)  is
 then related to mortality or morbidity data for various areas by  various
 statistical approaches designed to factor out effects of other  variables
 (e.g.,  population age, climatology, etc.).  Dose-response  curves  derived
 from these studies are then employed to estimate health effects of air
 quality changes resulting from proposed projects.
     Recently  the health effects model by Lundy and Grahn[5] has  been
 developed for  application in the National Coal Utilization Assessment
 Studies being  conducted at Argonne National Laboratories.  The  model
 combines mortality functions for suspended sulfates as developed  by Morris
 and Novak[6] and age-dependent and established response curves for cigarette
 smoke.  The mortality dose-response functions for suspended sulfates are
 based on statistical  studies of various populations experiencing  different
 sulfate exposures.  Unlike the dose-response air pollution studies, inves-
 tigations of smokers  have been relatively well  controlled with respect to
 age, degree of exposure, and effect.   Thus, to expand the predictability
 of the  sulfate dose-response curves to populations of different age distri-
 bution  (e.g.,  future  populations), the cigarette response curves  are adjusted
 to fit  the observed mortality/sulfate data, resulting in a model which pre-
 dicts age-specific death rates.  This elaboration is important because death
 rates vary exponentially with age, and shifts in the age distribution of a
 population will result in substantial shifts in total  mortality.  Accordingly,
the Lundy Grahn Model  utilizes projections of the population age  distribution
 to estimate the age-specific and total  death rates due to air pollution at
 any specific time in  the future.   The basic relationship of the model is:
                                          » bX
                        B(X, Xo)  -  	?e
where B is the number of excess deaths per year for the population of age
X which was exposed to the sulfate concentration S ( in M9/m3) since age Xo.
The constants a,b,c and d are coefficients to fit the model to cigarette
smoking mortality data and response data for a specific population subgroup
exposed to air pollution.
                                   5-10

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     The Lundy Grahn Model is being used in the ongoing National  Coal  Utili-
zation Assessment program to estimate excess mortality resulting from in-
creased coal utilization.  Air diffusion modeling was conducted first to
predict a population-weighted exposure increase for suspended sulfates.
The Lagrangian Statistical Trajectory Model of Argonne National Laboratory[10]
which assumes a constant transformation of S02 to sulfate, is employed in
the estimation procedure.  Then, based on the predicted exposure increase
and projections of the population age distribution, excess death rates are
calculated for each age and summed to yield the expected mortality associated
with coal combustion.  Table 5-3 shows the estimated effects of an average
exposure increment of 8.95 Mg/m3 suspended sulfates predicted to result
from coal-firing of power plants throughout the Central United States.
(The degree of power plant coal firing is assumed to increase in the region
from the current level of 178 million tons per year to 820 million tons  per
year in 2020).  The projected levels of power plant coal utilization are
predicted to cause significant health effects in future years.  These fore-
casts may be adjusted to approximate the additional health impact which  can
be expected to result from coal combustion in industrial boilers.  The
results of Table 5-3 are adjusted to reflect:  1) the emissions rate for
coal-fired industrial boilers relative to power plant boilers, and 2)  the
relative amount of industrial boiler coal use relative to utility consumption.
                 TABLE 5-3.  EFFECTS OF COAL COMBUSTION IN
                             POWER PLANTS IN CENTRAL U.S. [7]
Year
1985
2000
2020
Increase in Death
Rate, Number of
deaths/Million
persons/Year
28-130
181-809
150-665
Reduction In
Expectation of Life
At Birtha
17 - 79 days
136 days - 1.7 years
160 days - 1.8 years
            a.  The  range of  values  represents  the expected and upper
               80%  confidence  limit given by Morris and Novak.[6]  The
               effects  are calculated  corresponding to3an expected
               average  exposure  increment of 8.95 ^g/m  suspended
               sulfateSo
                                   5-11

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        Figure  5-2  presents  the  adjusted  projections for the industrial boiler

  scenario.  No distinction  is  necessary between oil  and coal  firing, since

  the emission rates for S02 were  found  to  be  essentially the  same (see

  Table 5-2).  The lower emissions rate-from industrial  boilers accounts for

  suspended sulfate levels appreciably less than those  projected for the

  utilities.  It is noted that the adjustments for  industrial  effects in

  Figure 5-2 do not include an adjustment for the spatial  aspect of popula-

  tion exposure.   Because the industrial boilers are  typically located in

  more urban areas than power plants, the population-weighted  exposures  under-
tr
o


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CO
<
HI
CC
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to
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-------
lying the estimates of Figure 5-2 are understated for the industrial  sit-
uation.  However, the understatement is probably minor, since the formation
and transport of airborne sulfates is a long range and region wide problem,
and effects of localized sulfate formation from the source are generally
minimal.  It is also noted that the comparisons are applicable to the spe-
cific fuels and boiler types, and caution is advised in extrapolating the
results to fuels of different compositions.
     Figure 5-2 shows that the expected health effects caused by air  pollu-
tion (as indexed by suspended sulfates) from oil or coal-firing of well-
controlled industrial boilers are minimal compared to the effects which
might result from utility boilers emitting SOp at the rate prescribed by
the NSPS, and substantially less than that which would be expected under
current industrial boiler controls.  The maximum impact is expected to
occur in the year 2000, when the proportion of population in the highest
risk age groups will be greatest.  For each million persons, the number
of increased deaths expected to occur annually due to well-controlled
industrial boilers is 12 to 55 in the year 2000.  Based on the tests  of  the
present study, and the sulfate health effects model, there is no indica-
tion that the difference in mortality rates resulting from well-controlled
coal-firing and well-controlled oil-firing would be significant.  The test
data and the sulfate mortality model also indicate that relative mortality
effects would not be significantly different between uncontrolled coal and
uncontrolled oil firing.  (See Volume II.)  However, the absolute levels for
expected mortality rates due to uncontrolled coal or oil combustion would
be roughly 30 times greater than that expected from well-controlled
combustion.
     Health effects caused by sulfate  levels may also  be  expressed in terms
of morbidity.  Table 5-4 presents data  for  increases  in  incidents of  health
disorders due to ambient sulfate exposures.  In those  areas which already
experience high sulfate levels, respiratory diseases may  increase signifi-
cantly with slight increases of suspended sulfates due  to  industrial   boiler
                                                                   3
emissions.  For example, in areas where the threshold  level  10 ug/m   is
                                           3
exceeded regularly, the increase of  .6 yg/m  of sulfate concentration as-
sociated with well controlled industrial boilers would  be  estimated to  pro-
                                   5-13

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                                    TABLE 5-4.   HEALTH IMPACTS  OF SULFATE  AEROSOL[11]
en
I
Pollutant and
Health Effect
Sul fates
" Mortality
Aggravation of
Heart and Lung
Disease in Elderly
Aggravation of
Asthma
Lower Respiratory
Disease in Children
Chronic Respiratory
Disease
Nonsmokers
Smokers
Population at Risk
Total Population
Same as above for
oxidants function
Same as above for
oxidants function
Same as above for
nitrogen dioxide
function
62 percent of
population age 21
or older
38 percent of
population age 21
or older
Assumed Baseline
Frequency of
Disorder within
Population at Risk
Daily death rate of
2.58 per 100,000
Same
Same
Same
Two percent
prevalence
Ten percent
preval ence
Pollutant
Concentration
Threshold
For Effect
25 vg/m3 for
one day or
more
9 vg/m3 for
one day or
more
6 vg/m3 for
one day or
more
13 vg/m3 for
several years
10 pg/tn3 for
several years
15 vg/m3 for
several years
Effect Increase as x
of Baseline Per
Pollutant Unit Above
Threshold
2.5% per 10 vg/m3
14. U per 10 vg/m3
33. 5% per 10 pg/m3
76.92 per 10 pg/m3
134% per 10 pg/m3
73.8% per 10 pg/m3

-------
duce an 8% increase in the incidence of chronic respiratory disease caused
at the threshold level.  Once again, adverse effects are no more likely to
occur by oil-firing than by coal-firing in the well-controlLed boiler.
     In addition to potential health effects created by long range sulfate
levels from industrial boilers, high concentrations of pollutants in the
range of the industrial complex pose a potentially serious health problem.
The Lundy-Grahn model may  also be applied to estimate mortality effects
caused by ambient  levels of SCL and total suspended particulates.  The model
gives the following relationships when fitted  to Lave and Seskin dose re-
sponse data[12] for S02 and TSP:
             ir>6    -i           090   -064X
         Per 10  males:  	1^3^	   (<835 Tsp  +  >?15     }
                         1  + 100e.12(X-Xo)                       2

             1A6  ,,   ,           n(-c   -088X
         per 10  females:   	.056  e	  (.835  TSP  +  .715  S02)
                           1  + 100 e"-2(X-Xo)
 If the model  is  applied to typical  concentrations  expected to  occur in  the
 vicinity of a clustered array of industrial  sources,  the  expected increase
 in mortality is  appreciable.   (See Table 5-2.)  Figure  5-3 illustrates  the
 estimated impact on mortality.   For example, when  boilers are  coal-fired,
 populations of the age 50 are predicted to experience increases  in death
 rates of 306 male and 200 female deaths per million persons per year.  When
 boilers are fired with oil, the increased death rate is about  one-third
 less that experienced under ambient exposures from coal-firing.   The dif-
 ference is attributable primarily to the higher plume rise of the oil-fired
 boiler emissions which lends to greater dispersion and lower ambient con-
 centrations of S02 and TSP in the vicinity of the sources.  The absolute
 impact of both the well-controlled oil-fired and coal-fired boilers is
 relatively minor when compared to the anticipated impact of either current
 industrial boiler emissions or even those emissions levels corresponding
 to the NSPS.  (See Figure 5-2.)  It is reminded that the NSPS for utility
 boilers permit an S02 emissions  rate twelve times greater  than  the emission
 rate measured for the reference well-controlled coal-fired boiler, and
 eight times greater than  the emissions for the reference oil-fired boiler.
 Emissions  at  the  rate associated with the NSPS would yield average ambient

                                    5-15

-------
   cc

   UJ

   DC
   UJ
   Q.


H  1
rf  P"


"  I
<
111  0.
0  Z
Z  O


S  d
2  5
CC  DC
(J  UJ
7  0-
    UJ
    Q
    O
    Z
         600- •
         500-•
         400- •
         300- •
         200- •
         100- -
              MALE RESPONSE
                 BOILERS

                 AT NSPS
                                          MALE RESPONSE, COAL FIRING
                                           MALE RESPONSE, OIL FIRING
                                           FEMALE RESPONSE, COAL FIRING
                                           f FEMALE RESPONSE, OIL FIRING
                   30    40     50     60


                     POPULATION AGE
     Figure 5-3.   Increase  in  mortality rates in vicinity* of clustered
                   industrial boilers0

*Based on the ambient air quality  forecasts, the sphere of effect is assumed
 to extend several km outside  the  clustered array of plants.  (See Volume III)
 The increased mortality rates  are based on the maximum annual average concen-
 tration of TSP and SCL expected in the vicinity of the industrial plant
 cluster.
annual S09 levels between  60  and  160  ng/m ,  jeopardizing the primary stan-
               o
dard of 80 yg/m .

Effect of Trace Elements--

     Trace elements from coal  combustion  emissions enter the atmosphere

and are then dispersed to  the  upper atmosphere or deposited in the environ-

ment around the sources.   The  principal  routes of entry to man are by  in-

halation, drinking water and  food.

     Table 5-5 summarizes  the  annual  average atmospheric concentrations  of

various elements expected  in  the  vicinity of a single well-controlled  coal

or oil-fired industrial boiler of 10  MW  capacity.  The estimates are based

                                   5-16

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     TABLE 5-5.  EXPECTED TRACE ELEMENT CONCENTRATIONS IN
                 VICINITY OF A 10 MW CONTROLLED INDUSTRIAL BOILER
Element
As
Cd
Co
Cr
Cu
Mo
Ni
Pb
Se
Annual Ambient
Concentration,
g/m3
Coal -Firing Oil -Fir ing
7.7 X 10"3
3.4 X 10"5
4.2 X 10"4
4.5 X 10"3
6.8 X 10"4
9.4 X 10"4
2.2 X 10"3
7.3 X 10"4
3.4 X 10"3
5.7 X TO"4
1.3 X 10"3
2.3 X 10"4
3.4 X 10"4
1.3 X 10~4
4.6 X 10"4
3.9 X 10"3
2.5 X 10"4
1.1 X 1Q"4
Typical
Urban Air
Concentration9
yg/m3
1 X 10~2
3 X 10"1
-4
2 X 10
1 X 10"2
5 X 10"2
1 X 10"1
1.4
2.4
2 X 10"4
Allowable
Exposure
Level b
ug/m3
50
20
10
50
100
500
100
20
20
 Based on data reported in Reference 22.
 Based on ambient air objectives proposed for hazardous waste  management
 facilities,[23].

on the assumption that trace elements exhibit the same  relationships  as
described earlier for estimation of total suspended particulates.   Also
included in Table 5-5 is a listing of concentrations considered  acceptable
for continuous ambient exposure.  The allowable concentrations are  based
on proposed regulations for control of air pollution from hazardous waste
management facilities, as required by Section 3004 of the Resource  Conser-
vation and Recovery Act.  It is clear that the air concentrations  of
elements resulting from operation of the industrial boiler are several
orders of magnitude (4 to 6) below the "allowable exposure level."   More-
over, the predicted maximum concentrations are also substantially  below
typical urban ambient background levels with the exception of selenium and
cobalt concentrations which approach or slightly exceed the endogenous
levels.  Considering the error bound of a factor of three associated with
the trace element analyses of this project,  it is concluded there  is only
                                   5-17

-------
a slight difference between the expected ambient levels of trace elements
from either coal  or oil-firing with the possible exception of cadmium.
Ambient cadmium levels from oil-firing are about 40 times greater than
that caused by coal-firing.
     Clustering of plants  or increases in amounts of trace elements in fuels
could increase the expected concentrations of trace elements by an order
of magnitude.  However, even with such an increase, the concentration of
most elements listed in Table 5-5 would be an order of magnitude less than
typical urban maximum concentrations, and the concentration of all elements
would still be several orders of magnitude less  than the "allowable exposure
level."
     A primary concern in  emissions of trace  elements is the contribution
of these elements to body  burden due to exposure to water and food.  To
estimate this contribution, pollutant deposition rates are approximated
by the product of the ambient concentrations  and the deposition velocity
of the pollutant.  The deposition rate is dependent on particle size.
Table 4-10  (Vol. II) shows that particles emitted from the controlled oil
and coal-fired industrial  boiler of this study are predominantly three
microns or less in diameter.  The deposition  velocity of particles this
size over grass surfaces is approximately 0.1  to 0.2 cm/sec,[13].   Accord-
ingly, the  deposition rates of the various trace elements were approximated
and are shown in Table 5-6.
     The significance of the deposition rates is evaluated by considering
the associated effect on drinking water and diet.  The pathway to drinking
water is by run-off of soil particles containing deposits of trace elements,
and the pathway to the diet is by plant uptake from trace elements in the
soil.  In either pathway,  the incremental concentration of elements in the
soil determines the extent of the potential  impact.  Table 5-7 summarizes
the maximum predicted soil  concentration in the  vicinity of the scenario
of five clustered industrial boilers of 10 MW each.  The concentrations
are estimated by assuming  mixing of the deposited elements to a depth of
10 cm, and over a period of 40 years.  For the majority of the trace elements,
only minor increases over  the background soil  levels would be expected.
However, the concentration of a few elements  may increase significantly.
It is predicted that coal  firing will cause a 60% increase in the selenium

                                   5-18

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en
i
                                  TABLE 5-6.  ANNUAL  DEPOSITION OF TRACE  ELEMENRS  IN
                                              VICINITYb OF CONTROLLED  INDUSTRIAL PLANTS

Element

As
Cd
Co
Cr
Cu
Mo
Ni
Pb
Se
2
Annual Deposition Rate,3 g/m -yr
Coal Firing
Single
Plant
2.4 X 10"4
1.1 X 10"6
1.3 X 10"5
1.4 X 10"4
2.1 X 10"5
3.0 X 10"5
6.9 X 10"5
2.3 X 10~5
1.1 X 10~4
Cluster
1.0 X ID"3
4.5 X 10"6
5.3 X 10"5
5.8 X 10"4
8.6 X 10"5
1.2 X 10"4
2.8 X 10~4
9.5 X 10"5 ,
4.5 X 10"4
Oil Firing
5 ingle
Plant
1.9 X 10"5
4.1 X 10"5
7.2 X 10"6
1.1 X 10"5
4.1 X 10"6
1.5 X 10"5
1.2 X 10"4
7.9 X 10"6
3.5 X 10"6
Cluster
7.8 X 10"5
1.7 X 10"4
3.0 X 10"5
4.5 X 10"5
1.7 X 10"5
6.2 X 10"5
4.9 X 10~4
3.3 X 10"5
1.4 X 10"5
                      Calculated  by  assunnng  a  particle  deposition velocity of 0.2 cm/sec.  The
                       deposition  velocity  is  multiplied  by  the annual average concentration to
                       estimate  the total deposition  rate0
                       The  deposition  rate  is  calculated  for  the  location where the maximum
                       average  annual  concentration  occurs.

-------
en

o
                           TABLE' 5-7.   LONG TERM EFFECT OF EMISSIONS  FROM  CLUSTER  OF
                                       CONTROLLED INDUSTRIAL  BOILERS  ON  SOIL  CONCEN-
                                       TRATIONS OF TRACE ELEMENTS
Element
As
Td
Co
Cr
Cu
Mo
Ni
Pb
Se
Increased Soil
Concentration
After 40 years,9
Coal
2.7 X 10"1
1.2 X 10"3
1.4 X 10"2
1.5 X 10"1
2.3 X 10"2
3.2 X 10"1
7.5 X 10"2
2.5 X 10"2
1.2 X 10"1
Oil
2.1 X 10"2
4.5 X 10"2
8.0 X 10"3
1.2 X 10"2
4.5 X 10"3
1.7 X 10"2
1.3 X 10"1
8.8 X 10"3
3.7 X 10"3
Typi cal
Soil
Concentration^
ug/g
6.0
.06
8
40
20
2
40
10
.2
Increase Over
Average Soil
Concentrations, %
Coal Oil
4.5 .35
2.0 70
.2 .10
.4 .03
.1 .02
16 .80
.2 .4
.3 .08
60 1.8
                         aBased on deposition rate (Table 5-6), an assumed mixing depth of
                          10 cm and soil  density of 1.5 g/cm^.

                          Based on data compiled in Reference 3.

-------
soil concentration and a 16% increase in molybdenum levels.  Oil-firing is
apt to cause less impact on trace element soil levels, but is predicted to
cause a 70% increase in cadmium concentrations.  The significance of the
elevated soil concentrations is evaluated by considering the associated
increase in trace element concentration in plant tissues and drinking water.
     The concentration of elements in plant tissues is related to the
biologically available fraction of the elements in the soil.  This is
often expressed as the soluble concentration in the soil, and is  some
fraction of the total endogenous concentration reported in Table  5-7.
Plants possess the ability to concentrate elements from dilute soil
solutions.  This ability is dependent on the concentration of elements in
the soil, and usually increases with decreasing soil concentration.   The
ratio of concentration of elements in plants to the concentration in the
soil is known as the concentration ratio.  Table 5-8 lists average plant
concentration ratios for various elements.  The data are based on various
published data as complied in a study by Battelle,[3]. The effect of
increased trace element soil loadings (caused by 40 years of boiler cluster
emissions) on concentration of the elements in plants is then estimated by
assuming that the soluble portion of the loadings are available for plant
takeup (Table 5-8).  The estimates reveal that seven of the nine  elements
show incremental burden in plants amounting to one half to 1/700  the
typical plant concentration levels.  Thus, for these seven elements, the
increase in plant concentration would appear to be insignificant  in terms
of effect on human health by route of the food chain, or in terms of actual
plant life itself.  For most elements, coal-firing appears to exert a
slightly greater impact on trace element plant burden, however, this dif-
ferential effect may be considered nearly insignificant in view of the
uncertainities associated with chemical analyses employed to determine
stack emissions rates.  The elements predicted to produce the most notable
burdens in plant tissue are cadmium and molybdenum.  Oil firing is pre-
dicted to result in plant concentrations of cadmium an order of magnitude
greater than the endogenous levels, and coal-firing is expected to produce
a thirty-fold increase in typical molybdenum concentrations.
     Cadmium is considered highly toxic to plants and animals.  Mammals
tend to absorb cadmium continually, accumulating high body levels which

                                   5-21

-------
           TABLE 5-8.  LONG TERM EFFECT OF EMISSIONS  FROM CLUSTER
                      OF CONTROLLED BOILERS ON CONCENTRATIONS
                      OF ELEMENTS  IN PLANTS
'l Element
;
As
Cd
Co
Cr
Cu
Mo
Ni
Pb
Se
Concentration
Ratios9

4.2
222
87
250
1000
900
331
2
4
Solubility
Of Elements9

9
40
.4
.004
.1
9
.1
—
21
Typical Con-
centration
in plants,
yg/g
.08 - -55
.04 - .50
.05 - .25
.23
14
.9
3
2.7
.2
Increase in
Concentration
of plants,
Coal Oil
.1 .008
.1 4.0
.005 .003
.001 .0001
.02 .005
26 1.4
.03 .04
.05 .02
.1 .003
     Extracted from Reference 3.
     Calculated by multiplying concentration ratio by the incremental
     increase in soil concentration  (Table 105) by the concentration ratio
     by  the  fraction of the element which is soluble.

adversely affect  the  respiratory,  cardiovascular,  nervous,  and  reproductive
systems, disrupt  kidney  and  liver  functions,  and cause  intestinal  disorders.
Cadmium levels  as  low  as  15  pig/g in  plants may cause injury to  man. [24]
Cadmium levels  in  some  areas  are believed  to  be approaching threshold
levels, and it  is  believed that  cadmium concentrations  in  cigarettes might
cause smokers  to  exceed  thresholds of observable symptoms  of cadmium
poisoning if exposed  to  additional sources of cadmium,[25]  . Consequently,
the addition of cadmium  to the  environment in significant  quantities  is  a
serious concern.   However, it should be noted that present day  levels  of
cadmium emissions  from  non-controlled industrial boilers  are substantially
greater than those well-controlled levels  discussed here.
     In contrast  to cadmium,  molybdenum is considered to  exhibit a low
order of toxicity.  Molybdenum  has been found to be a necessary trace
element in the  body for  the  proper functioning of  flavoprotein  enzymes.[26]
                                   5-22

-------
Still, incidents of animal injury have been reported in the vicinity of
steel plants where livestock were observed to develop inflammation of bowels
and degenerative changes in liver cells.  The injury was associated with
high molybdenum levels in the cows' blood.[27]   The  threshold  diet levels for
animals or man are unclear.  The incident of cow injury was caused by
grazing in a pasture containing 20 to 100 yg/g of Mo.  It should also be
noted that the occupational air exposure threshold for molybdenum is two
orders of magnitude greater than that for cadmium, and the potable water
standard for Mo is 40 times greater than the cadmium standard.
     The actual impact of trace element emissions on plant burden depends
greatly on many site-specific variables, such as temperature, precipitation,
soil type, water chemistry, and plant species at a given site.  Of major
concern are the endogenous concentrations of elements in soil, water, and
the atmosphere.  Where trace element concentrations are approaching thres-
hold limits, emissions from industrial plants will exert a greater in-
fluence on health impacts.  This consideration is particularly relevant
with respect to environmental buildup of cadmium because high background
levels of this element already exist in many areas.  The impact on trace
element burdens in plants from controlled boilers,  whether  oil or coal-
fired, may be significantly less than that from existing boiler control.
Based on the present study, the major difference between trace element
buildup from oil versus coal firing of well-controlled boilers is the
higher cadmium levels associated with oil 'burning.
     Trace elements also enter the plant via foliar absorption.  Intake
from the leaf surface to the interior occurs through stomatal openings,
walls of epidemal cells, and leaf hairs.  Although relatively little is
known regarding the efficiency of foliar intake, it would appear that the
plant burden produced by soils containing long term deposits  is several
orders of magnitude greater than that which could be transferred from
foliar interception of trace elements in the atmosphere.  Soil concentra-
tions are the result of accumulation of elements over the long-term, and
crops raised in these soils tend to concentrate the trace elements in the
plant tissue.  By contrast, the foliar intake rate can be no  greater than
the deposition rate on the plant surface, and there is much uncertainty
regarding the efficiency of the plant in absorbing the deposited particles.
                                   5-23

-------
Thus, it is clear that the soil  uptake scenario (Table 5-8) represents
the more adverse case for.pi ant uptake of trace elements.  This scenario
assumes no interference (e.g., animal  .or crop uptake) with trace element
buildup in soils over a 40 year period, and a fixed concentration of
elements in the soil  despite crop uptake.
     Trace element emissions  also affect the quality of drinking water.
The impact of trace element particle deposition on runoff water concen-
tration will  be related to the relative increase in soil  concentration due
to long term atmospheric deposition of elements.  The actual  runoff con-
centrations may be estimated by applying average sediment burden rates for
representative runoff per unit of watershed area.   The sediment is assumed
to carry the cumulative deposits of metals orginating from the boiler emis-
sions.  Table 5-9 summarizes  estimates of increased soluble metals con-
centrations for runoff waters in the vicinity of a cluster of industrial
plants.  The estimated concentrations  are three to seven  orders of mag-
nitude less than the standards for livestock drinking water and potable
water.  Two elements, selenium and molybdenum, are predicted to exceed
background concentrations for metals in runoff waters after 40 years of
coal-firing in the plant cluster.  The concentration of metals in runoff
waters due to oil firing is predicted  to be slightly less than that
occuring from coal firing; in either case, hazard  to human health by
drinking water is remote.
IMPACT ON ECOLOGY
     The ecological environment will be affected by air emissions and by
solid 'waste residuals generated by air pollution control  equipment.
Operation of the controlled industrial  boilers is  not expected to produce
significant water pollution problems,  since wastewaters produced are
generally acceptable to the municipal  water treatment systems.
Effect of Air Emissions
     A major ecological impact category most likely to be affected by
industrial boiler emissions is plant life.  Of the major  gaseous pollutants
emitted by fossil fuel combustion, plant life is most affected by S0? and
N0x in the concentration ranges expected.  Concentrations of CO and hydro-
carbons produced by a single  industrial boiler or  a clustered arrangement
of boilers are considered to  cause negligible impact on vegetation.[21 ,28]
                                   5-24

-------
                     TABLE 5-9.  TRACE ELEMENT CONCENTRATION IN RUNOFF WATER IN
                                 VICINITY OF CLUSTERED CONTROLLED INDUSTRIAL BOILERS
Element

As
Cd
Co
Cr
Cu
Mo
Ni
Pb
Se
Typical
Background
Concentration
of Soluble
Metals In
Runoff Water3
yg/ml
4 X 10"4
1 X 10"4
3 X 10"5
1 X 10"5
2 X 10"5
1 X 10"6
1 X 10 "4
7 X 10"4
8 X 10"5
Increase In
Soluble Metals
Concentration
In Soil After
40 years"
yg/ml
Coal
2.4 X 10~2
.5 X 10"3
.6 X 10~4
,6 X 10"5
2.3 X 10"5
2.9 X 10"2
7.5 X 10"5
2.5 X 10"2
.2 X 10"1
Oil
1.9 X 10"3
1.8 X 10~2
3.2 X 10"5
.5 X 10"6
4.5 X 10"6
1.5 X 10"3
1.3 X 10~4
8.8 X 10"3
.7 X 10"3
Increase In
Soluble Metals
Concentration
In Runoff Water0
After 40 years
yg/ml
Coal
2.4 X 10"5
.5 X 10"6
.6 X 10"7
.6 X 10"8
2.3 X 10"8
2.9 X 10"5
7.5 X 10"8
2.5 X 10"5
.2 X 10"4
Oil
1.9 X 10"6
1.8 X 10"5
3.2 X 10"8
.5 X 10"9
4.5 X 10"9
1.5 X 10"6
1.3 X 10"7
8.8 X 10"6
.7 X 10"6
EPA Proposed
Maximum
Acceptable
Concentration
For Livestock
uQ/ml

2 X 10"1
5 X 10"2
1
1
5 X 10"1
	
^_
1 X 10"1
5 X 10"2
Standard
As Critical
Concentration
In Potable
Water
yQ/ml

1 X 10"2
1 X 10"2
5 X 10"2
2 X 10"2
1 X 10"2
5 X 10"1
5 X 10"2
1 X 10"2
1 X 10"2
en
I
ro
en
        aBased on average  soil  particle  runoff  rate of  1000 yg/ml of runoff water, and soluble endogenous
         concentration of  metals  in  soils.3

        bBased on increase in  trace  element  concentration  (Table 5-7) and solubility of elements (Table 5-8).
        cBased  on  average  soil  particle  runoff  rate of  1000 yg/ml of runoff water, and increased soluble
         metals  concentration  in  soil  after  40  years.

-------
The levels of NO  and SCL expected to occur in the vicinity of industrial
                A       £
boilers approaches the threshold injury values for these pollutants.  Only
very sensitive plants in the vicinity of a cluster of industrial  boilers
are likely to suffer injury, and such injury would be limited to a downwind
sector and a range of about 2 km length beginning a few hundred meters from
the perimeter of the cluster.
     While neither hydrocarbon or nitrogen oxides would be expected to
cause plant injury at the ambient doses predicted near the boilers, the
secondary pollutants (ozone and peroxyacylnitrates) formed by reaction of
these pollutants are considerably more toxic.  The formation of secondary
compounds in boiler stack plumes and the impact of the boiler nitrogen
oxides emissions on urban photochemical smog depend on complex relation-
shops which are not yet totally understood.  Therefore, it is not possible
to reliably estimate the effect of NO  emissions levels to photochemical
                                     X
compounds.  However, based on typical regional emissions figures, it appears
that emissions from industrial fuel  combustion provide a significant source
of the regional emissions of NO  necessary for photochemical smog.  Approxi-
                               A
mately 20% of the nation's NO  emissions are produced by industrial fuel
                            A
combustion,[29].
     If NO  emissions from industrial boilers are a significant contributor
          A
to photochemical smog, then there is valid concern that boiler emissions may
contribute to plant injury.  Coal-firing presents the greatest concern.
NO  emissions from coal-firing of the boiler of the present study were
  A
measured to be twice the magnitude produced during oil-burning.  The boiler
is not equipped with NO  control.  The effects of photochemical air pollution
                       A
on plant life have been observed frequently at various different severities
throughout the United States.  In addition, the effect of the major consti-
tuents of photochemical smog (products of nitrogen oxides and organic
compounds) on plants has been investigated separately.  The pigmentation of
small areas of palisade cells is characteristic of ozone injury,  and a
bronzing of the undersurface of leaves is typical for peroxyacyenitrate
injury.  Table 5-10 illustrates the  relatively low levels of ozone which will
produce significant plant injury to  crops.  The concentrations shown are
typical of many areas experiencing photochemical  air pollution, and suggest
the necessity for concern over sources emitting high levels of NOY.
                                                                 A
                                   5-26

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 TABLE  5-10.
PROJECTED OZONE CONCENTRATIONS WHICH WILL PRODUCE, FOR
SHORT-TERM EXPOSURES, 20 PERCENT INJURY TO ECONOMICALLY
IMPORTANT VEGETATION GROWN UNDER SENSITIVE CONDITIONS, [30]
— 	 : 	 	 .— -
Concentrations producing injury in three types of plants, ppm
Time, Hr

0.2
0.5
I I-"
] 2.0
I 4.0
| 8.0
a 	
Sensitive

0.40-0.90
0.20-0.40
0.15-0.30
0.10-0.25
0.07-0.20
0.05-0.15
Intermediate

0.80-1 .10
0.35-0.70
0.25-0.55
0.20-0.45
0.15-0.40
: 0.10-0.35
	 i 	
Resistant

1 .00 and up
0.60 and up
0.50 and up
0.40 and up
0.35 and up
0.30 and up

     Nitrogen oxides may also cause injury to vegetation  by direct  contact.
The significant oxides of nitrogen are NO and N02-   The major oxide in  com-
bustion emissions is NO.  However, after residence  in the atmosphere, NO  is
converted to N02 by photolysis and by photochemical interaction with hydro-
carbons.  The effect of N02 on plant life has been  studied under controlled
laboratory conditions.  Acute injury is characterized by  collapse of cells
and subsequent development of necrotic patterns.  Chronic injury, caused  by
exposure to  low concentrations over long periods, is characterized by
chlorotic or other  pigmented  patterns  in  leaf tissue.  Such  injury results
in  reduction of  growth  and reproduction.  Only  limited data  are available to
characterize the effect of NO on  plants.  Generally,  it  appears that NO leads
to  effects  somewhat similar  to those observed for N02, but at slightly  higher
threshold concentrations.  Therefore,  for worst case  evaluations of the
impact of ambient  NOX levels, it  is  assumed  that NOX exists  as  N02, and that
the NO  levels  are  not  depleted by the photochemical  reactions  which typical-
       A
 ly  occur in urban  areas.
      Figure 5-5 illustrates  the  threshold concentrations at which  various
 degrees of damage  result from exposure to N02.   Based on the expected  con-
 centration of NO  in the vicinity of the coal-fired industrial plant cluster,
 and the assumption it is converted entirely to  N02, it appears that acute
 leaf damage may be anticipated to occur as  a result of short term plume
 fumigations, and that chronic effects (including growth  and yield reductions)

                                    5-27

-------
       1000-r
    D_
    D-
     C\J
    O
        100- r
o

2    10
    o
    o
        1.0- r
         0.1
              0.01
             -h-
                     0.1
 DAYS
  1.0
—I—
10
100
                                                                : -1000
           0.1
                                                            ; -100
                                   THRESHOLD FOR FOLIAR LESIONS
            METABOLIC AND GROWTH EFFECTS
                            •4
                 1.0
                                10
        100
                                                                - '10
                                                                       C\i
                                                                      o
                                                                      CD
                                                                •: -1.0
      1000
     10,000
                      DURATION OF EXPOSURE (HOURS)
               Figure 5-5.  N02 threshold  concentrations for
                            various  degrees  of plant injury,[31].
may be. noticed over the long term.  The extent  of the damages would

be localized within a one or two km range  from  the plant cluster, and would

be expected to occur to those plants most  sensitive to N02 injury (e.g.,

cotton, navel orange, spinach, etc.).  However,  N02 injury to plants from oil

firing is not as likely to occur.  Maximum short term ambient concentrations of

NO  near the plant cluster are estimated to  be  about one third that result-
  A
ing from coal-firing, or below the threshold levels which induce plant

injury0  (See Figure 5-5.)
                                   5-28

-------
     Acute (short term) injury to vegetation by SCU exposure is  characterized
by damaged leaf areas which first appear as water soaked spots,  and  later
appear as bleached white areas or darkened reddish areas.   Chronic S02
injury is usually characterized by chlorosis (yellowing) which develops
from lower concentrations over extended periods of time.  Either acute or
chronic S02 injury may result in death or reduced yield of the plant if  the
extent of the damaged tissue exceeds 5 to 30 percent of the total  amount of
foliage.
     The impact of the expected S02 concentrations varies  with the plant
species.  Threshold injury in sensitive plants may be caused by  short-term
S02 levels as low as  30 ng/m3,[17]. Table 5-11 summarizes the broad cate-
gories of sensitivity for different plants.  Grain, vegetable, pasture,  and
forage crops are susceptible to S02 damage for most of the growing season.
These crops may suffer yield reductions in areas where industrial  boilers
have been sited together in clusters.  However, the damage would be  highly
localized, and the extent of the most severe injury would probably result
in only minor yield losses.  Figure 5-6 shows that peak S02 concentrations
expected to occur near the clustered network of controlled industrial
plants will probably cause only traces of leaf damage to occur in the
more sensitive plant species.  However, certain adverse combinations of
frequent fumigations and boiler sitings could result in crop damage  of
significant extent.  If ambient levels of S02 are approaching plant  damage
thresholds in the vicinity of the industrial boilers, the potential  effect
of the type of fuel utilized could be significant.  Based on the boiler
tested in the present study, and the dose-response relationships of  Figure
5-7, it appears that once ambient S02 levels are equivalent to leaf  des-
truction thresholds, coal-firing would result in total  leaf destruction
rates significantly higher than that produced by oil firing.
     It should be noted that the plant damage thresholds illustrated by
Figure 5-6 apply to conditions of temperature, humidity, soil moisture,
light intensity, nutrient supply, and plant age which cause maximum  sus-
ceptibility to injury.  The occurrence of such conditions are rare.   In
fact, in the unlikely event that all such conditions are met, the dose-
response curves indicate that plant injury could occur without a violation
of the federal air quality standard for the 3 hour or 24 hour concentration

                                    5-29

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TABLE  5-11.  SENSITIVITY OF COMMON PLANTS TO  S09 INJURY,[2]
Vegetation
Sensitive
White pine
Goldenrod
Cottonwood
Virginia creeper
Aster
Gooseberry
Elm
Wild grape
American elm
White ash
Virginia pine
Tulip tree
Intermediate Resistant
Maple Sugar maple
Virginia creeper Phlox
White oak Oak
Elm Maple
Shortleaf pine Shrubby willow
Aster
Linden





Crops
Sensitive
Alfalfa
Barley
Oats
Rye
Wheat
Sweet potato
Soybean
Sweet clover
Cotton Tobacco
Clover


Intermediate Resistant
Irish Potato Corn
Clover , Sorghum
Sweet clover









       3.0-
       2.5
     I
      -2.0
     o
     o
       1.5
       1.0
       0.5
                           S02 DOSE-INJURY CURVES
                         FOR SENSITIVE PLANT SPECIES
                                DAMAGE LIKELY
                INJURY OR DAMAGE
                    POSSIBLE
                (THRESHOLD RANGE)
7860
6550
            NO
           INJURY
5240
3930
2620
1310
e
5.

z
o

o1
                   23456
                       DURATION OF EXPOSURE, h
    Figure 5-6.   S02  Dose-Injury Curves for  Sensitive
                   Plant  Species5[i7].
                                5-30

-------
                                period of exposure
                                (hrs.)
                                concentration of
                                gas  (ppm)
                                  100% LEAF DESTRUCTION
                                      t (C - 2.6) = 3.2
                                  50% LEAF DESTRUCTION
                                     t (C- 1.4) = 2.1
                                  TRACES OF LEAF
                                  DESTRUCTION APPEAR
                                    t (C - .24) = .94
                          1        2        3
                         TIME (t) OF FUMIGATION - HOURS
    Figure 5-7.   Dose-Response  curves  for Alfalfa exposed to
                  S02  under conditions  of maximum absorption,[is],
of S02.  Additional susceptibility may  also  result  from  synergistic effects
of sulfur dioxide and other pollutants.   Particularly  relevant  to  the  urban
environment are combinations  of  sulfur  dioxide  and  ozone.   Moderate to
severe injury of tobacco  plants  have  been observed  for four hour exposures
to concentrations of 0.1  ppm  (262  ug/m3)  S02 in combination with 0.03  ppm
ozone.  Because high ozone  levels  are a frequent problem in the vicinity  of
urban areas, susceptibility to plant  injury  by  SO-  pollution is probably
greater in those areas where  industrial  boilers are typically sited.   One
of the major concerns associated with fossil fuel  utilization is acid  pre-
cipitation resulting from wet deposition  of  suspended  sulfur and nitrate
compounds„  Data show that  there has  been an intensification of acidity in
the northeastern region of  the U.S. since the mid  1950's.   Precipitation
in a large portion  of the eastern  U.S.  averages between pH 4.0 and 4.2
annually.  Values between pH  2.1 and  3.6  have been  measured for individual
storms at distances several hundred miles downwind  of  industrial centers.
The areas experiencing highest acidity  are typically downwind of the  areas
                                   5-31

-------
where sulfur emissions are highest ,[25], [31].
     Acid rain affects plant life in varying degrees depending on the pH
and the type of plant species.   Experiments show that the effects on plants
may include reduction in growth or yield,  leaf damage, death, and chlorosis.
Acid rain also has been shown to affect aquatic organisms, and it is be-
lieved that thousands of lakes  are now experiencing reductions in fish pop-
ulation due to acidification between pH 5.0 and 6.0,[31] .
     The impact of fossil  fuel  combustion  in controlled industrial  boilers
boilers on  acid precipitation and plant damage is  relatively  minor.   Based
on stack tests as  the reference boilers, the resulting levels  of sulfates
would be essentially the same whether the  controlled boilers are coal
fired or oil  fired.   In the  previous discussion,  it was estimated that
                                                                  3
controlled  industrial boilers would  account for a  level of .6  ug/m  sus-
pended sulfate in  the central  region of the U.S.   This level  is  substantially
below ambient sulfate concentrations associated with areas experiencing
significant acid precipitation.   Typical ambient sulfate levels  prevalent
in the U.S. are shown in Figure 5-8.  However, it should be noted that the
NSPS for utility boilers permit a greater  sulfur oxides emission rate
than that rate which was  measured from the  controlled industrial  boiler.
Thus, typical (non-controlled)  industrial  boilers  burning coal or oil and
emitting at rates  equivalent or higher than that of the NSPS would cause
suspended sulfate  levels an  order of magnitude higher than that resulting
from control!ed boilers.
     Plants may also sustain injury from elevated  levels of trace elements.
As shown previously  (Table 5-8), trace element concentrations  in vegetation
near clustered industrial boilers would not be expected to exceed levels
observed to be toxic in plants.  However,  under conditions which would
cause the most adverse 40 year  accumulations of trace elements in soils
e-ound the  emission sources, it is possible that both molybdenum and cad-
mium could  be concentrated in vegetation at levels causing plant injury.
The effects of cadmium toxicity in plants  are wilting, chlorosis, necrosis,
and reduction of growth.   Substantial declines in  yield of the soybean,
wheat and lettuce  have been  observed when  the tissue concentration of cad-
mium in foliar parts of these species was  as low as  7, 3 and  11.5 ^g/g
respectively.  Molybdenum is considered to be one of the least toxic of

                                   5-32

-------
                      (A) Urban Levels
                       (B) Rural Levels
Figure 5-8.   Geographical distribution of typical  sulfate
              levels in the United States ,[2].
                          .5-33

-------
 trace elements.  However, it is concentrated heavily by the uptake  system
 of most plants, and it is estimated it may be present in concentrations  up
 to 26 jug/g  (i.e., 30 times the maximum background level) in the foliar tissue
 of plants near an industrial boiler cluster.  It is not clear  if this Mo
 level is destructive to vegetation, but dietary concentrations as low as
 5 ,ug/g have been known to cause diarrhea in cows, and Mo levels from
 20-100 jug/g in grazing pastures have resulted in death of cows, [32].
      Based  on  tests of the reference industrial boiler, it appears  that
 emissions  from oil  firing will  result  in  potentially  high  cadmium plant  burdens
 while coal  firing  is  more apt  to  cause elevated  levels  of  molybdenum.  While the
 evaluation  is  based on most adverse potential conditions,  it does illustrate
 the  need to consider  fuel use,  as well as other site specific  issues (e.g.,
 magnitude and  location of sources, stack heights, background levels of
 trace elements), in planning for  adequate protection of vegetation  and
 agriculture near industrial boiler plants.
 Effect of Solid Wastes
     A major environmental concern involving the use of fossil fuels is
 the  generation of coal ash and flue gas desulfurization (FGD) sludges.  The
 quantity of such wastes depends on the proportion of coal utilization and
 the  amount of S02 removed from stack gases.  It has been estimated  that by
 1985 coal ash will  be generated at a rate of 92 x 10  tons/year and FGD
 sludges at a rate of 33 x 10° tons/year (dry basis).  Landfill is the
 common means of disposal for these wastes.  By 1980 it is estimated that
 0.4  to 0.7 acres of land per MW of boiler capacity will be required for
 disposal purposes,[36]. The composition of the wastes will depend on the fuel
 source,  the boiler  design,  and  the flue gas  desulfurization system.
 Most FGD processes  generate  a  waste sludge consisting  predominantly of
 calcium sulfite and sulfate.   Various_trace  elements are also found in the
 FGD  sludge.   The trace elements originate  from reagents  used in SO  removal,
 from process water,  from trace  elements in the combusted coal  or oil,  and
 from fly ash (noncombusted  portion of  coal)  which  is collected  by the  FGD
 scrubber system.   Fly  ash and  bottom  ash usually  consist of about 80 per-
 cent silica, alumina,  iron  oxide,  and  lime.   The  composition of trace  ele-
ments found  in  bottom  and fly  ash  is  similar
                                   5-34

-------
     Table 5-12 shows the quantities of coal ash and FGD sludge collected
during operation of the reference 10 MW industrial  boiler studied in this
project.  Coal-firing of this controlled boiler produces approximately
three times more scrubber cake than oil firing produces; this is due to
the higher rate of particulate matter generated by coal  combustion and the
subsequent collection of the particulate matter by the FGD scrubber system.
The quantities of bottom ash and fly ash generated by oil burning is
relatively insignificant.  A portion of the fly ash generated by coal
burning is collected with the scrubber cake of the FGD system, while most
of the fly ash is recovered by  cyclone  collectors  upstream of the scrubber.
Bottom ash generated by coal firing represents a significant waste disposal
problem, and is generally managed in  conjunction with the scrubber cake
wastes.
     Based on the test results of scrubber cake produced by the reference
boiler, it appears that coal firing produces a greater enrichment of trace
elements in the scrubber cake.  Table 5-13 shows that only four elements
exhibited higher concentrations in the scrubber cake produced by oil firing.
However, either scrubber cake contains sufficient amounts of heavy metals
and toxic substance to pose difficult waste disposal problems.
         TABLE 5-12.  GENERATION RATE OF SOLID WASTE FROM
                      10 MW CONTROLLED INDUSTRIAL BOILER

Waste
Bottom ash
Fly ash
Scrubber cake
Rate of Production,
Coal Firing
80
240a
1100
kg/hr.
Oil Firing
1
2a
400
      This is amount of  fly ash  recovered by  cyclone collector.
      Approximately 25%  of the fly ash  is recovered in scrubber
      and removed with scrubber  cake.
                                   5-35

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              TABLE 5-13.  COMPOSITION OF F6D SCRUBBER CAKE
Element
Ca
Mg
Sb
As
B
Cd
Cr
Co
Cu
Fe
Pb
Mn
Mo
Ni
V
Zn
Se
Sr
Al
Zr
Concentration
Coal Firing
60715
1458
315
532
857
13
141
424
112
47241
297
51
1117
114
195
282
256
642
45310
106
» MQ/9
Oil Firing
192030
1776
122
135
2405
7
33
231
35
3867
104
15
666
148
161
19
128
163
4625
39
Relative
Concentrations,
Coal /Oil
.3
.8
2.6
3.9
.4
1.9
4.3
1.8
3.2
12.2
2.9
3.4
1.7
.8
1.2
14.9
2.0
3.9
9.8
2.7
     F6D scrubber wastes  and coal  ash  are  usually  disposed in  impound-
ment ponds or landfills.   The major concern  in  either disposal  approach
is the release of trace elements  to ecosystems  in  localized areas  sur-
rounding the disposal  sites.  Lateral  and  upward movement of trace elements
through the soil  to plant rooting  zones  may  be  possible,  and contamination
of ground and surface  waters may  occur.  Additional  adverse consequences
include the diversion  of  land from other uses,  and aesthetic degradation
at the disposal  site.
                                   5-36

-------
     Because of  the  limited  experience  concerning  land  disposal of wastes,
and the  long time  lags  preceding  future potential  adverse  impacts, there
is significant uncertainty regarding  the  level  of  restrictiveness necessary
to assure the environmental  adequacy  of various  land disposal methods.
Because  of such  uncertainty,  it seems likely  that  stringent waste disposal
regulations will be  proposed  to stabilize waste  sludges, preventing their
migration in the terrestrial  environment  and  the movement  of leachate to
underground water  sources.
     Disposal of FGD sludges  and  coal ash is  already subject to regulations
at the state level.   Recent  federal legislation  (the Resource Conservation
and Recovery Act)  now requires that criteria  be  developed  to classify
wastes and suitable  disposal  management techniques.  Under the proposed
criteria, due in fall of  1978, it is  plausible that FGD sludges and coal
ash may  be classified as  hazardous waste, and that disposal of these wastes
will be  restricted by the stringent requirements now being proposed for
hazardous waste  management facilities.  Typically, these requirements would
restrict the land  disposal of hazardous wastes to  "secure  landfills" designed
to provide protection for all-time of the quality of ground and surface
waters.  By definition, the  secure landfill would prevent  significant adverse
impact to certain  environmental sectors  (i.e., public health and ecology).
Unfortunately, the secure landfill, is, by definition, an  ideal design which
cannot be attained except at  very great cost.  There is, therefore, a need
to define reasonably  attainable land  disposal designs which offer a high
level of environmental  protection.
     Various recent  efforts  have  been conducted  to define  appropriate land-
fill criteria.    In one  pertinent  study,[16] the  effectiveness of three
scenario landfill  designs for the disposal of FGD scrubber cake were
evaluated.   The  scrubber cake considered  is that generated by the Double
Alkali  FGD system  utilized at the reference industrial boiler of this
study.   Migration  of  leachate to  the  groundwater and the loading rate of
dissolved solids into the groundwater were estimated by considering the
permeability of  the  landfill  layers and the solubility of  solids as deter-
mined from laboratory tests.  Table 5-14 summarizes the analysis of the
three landfill  cases.   As indicated,  permeability of the soils and the
scrubber waste is  the primary factor  in  initiating leachate migration.

                                  5-37

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            TABLE  5-14.    LEACHING  RATES FOR THREE  LANDFILL  DESIGNS
Case


I

II

III
LI
(feet)

18

18

20
Lj
(feet)

2

2

1
L
(feet)

10

10

10
R
(cm/sec)
s
10
5
10
5
10
K
(cm/sec)
6
10
_6
10
9
10
K3
(cm/sec)

10
_8
10
it
10
K ff
(cm/sec)
_6
7.7 x 10
_a
1.5 x 10
_8
3.0 x 10
t
(years)

1

200

100
t
(years)

20

6000

3000

(Ib/fl /yr)

1.04

0.0033

0.0066
              Liner or
              Compacted
              Filter Cake
i Double
Alkali
Filter Cake
V

^••^;y.}?:'(::^::^ L2
y/'3'//^-//-s?//i://^//^/£z//2
\ Soil
/ 	 '
1
?fr/A *
\ j
(
Ground
Water
Table
1^ = Depth  of uncompacted filter cake  (feet)

L£ = Depth  of compacted filter cake or liner (Case III)  (feet)

L, = Depth  of soil (feet) -

KI( K2,  K3  = Coefficients of permeability of layers I,  2,  and 3, respectively
            (cm/sec)

Keff  Effective permeability of overall filter cake plus  soil layers (cm/sec)

t^ = Time for migration of leachate to groundwater table (years)

t^ = Time for washout of major dissolved solids from filter  cake (years)

Qg = Loading rate of total dissolved solids to groundwater (Ib/ft2/yr)
                                          5-38

-------
In the first case, all net precipitation becomes leachate, and the time to
reach groundwater is about one year while the time to wash out the major
portion of the soluble solids is about 20 years.  The overall washout rate
of soluble solids during the 20 year period is calculated to be 1  Ib/ft2/yr.
Contamination of ground water sources over significant landfill areas at
this washout rate is clearly unacceptable.  In the second and third cases,
200 and 100 years elapse before leachate reaches groundwater, and  leaching
of soluble substances occurs at the low loading rate of 003  x  10"3 Ib/ft2/yr
and 007 x  10"  Ib/ft2/yr,  respectively.  The  time for total washout of all
soluble solids would be 3000 and 6000 years, respectively.  The extent of
impact of  such a leaching rate would depend on the size of the landfill
and the flow of the underground aquifer.  For example, for case II,
a 1 acre landfill over a small underground water source flowing at one
million gallons per year would cause an increase of 2 ppm in the dissolved
solids content of the underground water.  Most of the 2 ppm increase woul"1
be composed of lime and sodium sulfate and sulfite salts.  As indicated by
Table 5-13, trace elements would comprise a small fraction of the  incre-
mental increase, and considering the low solubility of the trace elements,
their concentration in the underground water would be at least three orders
of magnitude less than the lime, sulfate, and sulfite concentrations, and
well below the standard for potable water (see Table 5-9).  The rate  >f
leaching can be minimized still further by mixing bentonite with a layer
of soil to provide a layer over the filter cake after it has been  landfilled
to the desired level.  The bentonite soil mixture  achieves  a low  permeability
of 10"9 cm/sec.  By contrast, the permeability of silty clay and permeable
soils is about 10"8 cm/sec, and 10~4 cm/sec, respectively.  The permeability
of the double alkali scrubber cake is 10"  cm/sec, whereas it  is about
10   cm/sec for lime/limestone type scrubber sludges.
      Estimated leaching rates can be confirmed by tracking  the migration
of leachate in the experimental landfill at the reference industrial boiler
site.  Analyses of this landfill, which contains no seal or  barrier other
than the native clay silt  (permeability of 10"  cm/sec), shows that no
leachate has migrated as far as six inches below the  disposal  layer after
the first  year of operation.  The results and analyses indicate that  land-
fills of untreated scrubber cake can be constructed such that  significant
adverse impacts will not occur.  Moreover, it is conceivable that a completed

                                    5-39

-------
landfill can be reclaimed for use as a park or farmland, provided a
sufficient soil cover is applied and care is exercised not to disrupt the
stabilized waste or to permit its migration entry into the terrestrial
envi ronment.
      The impact of landfill ing scrubber cake produced by coal firing is
clearly greater than the impact caused by oil firing due to higher concen-
trations of elements in the cake and larger quantities of cake produced.
However, analysis shows that if proper landfill  design is employed, utilizing
impervious soils, the impact of leaching can be minimized to an insignificant
measure whether the scrubber cake orginates from a coal-fired or oil-fired
boiler.  It is expected that such designs will become mandatory under the
rules established by the authority of the Resource Conservation and Recovery
Act.
COMPARATIVE SOCIETAL IMPACT
      A major societal  impact resulting from air pollution and solid waste
is aesthetic damage.  Emissions of particulate matter and sulfur oxides
cause soiling of materials, visibility reduction, and corrosion damage.
Solid waste disposal sites are unattractive and generally result in
diversion of land use and depreciation of land values.
Effect of Air Emissions—
      The primary source of aethestic damage is  suspended particulate matter.
One obvious esthetic effect of suspended particulates is soiling of property
(e.g., homes,  automobiles).   Soiling results in  increased frequency of
cleaning and associated economic cost.   Particles also cause corrosion of
metals.   Hygroscopic particles such as sulfate and chloride salts  and
sulfuric acid aerosol  are responsible for accelerating corrosion of metals
exposed to the atmosphere.   Reliable estimates of the cost of material
damage due to pollution are difficult to develop because adequate  damage
functions are generally not available.   However, some preliminary  studies
have developed functions which may permit crude  indications of the poten-
tial  impact of increased air pollution.  Most of these studies have been
concerned with the corrosive aspects of suspended particulates.
                                   5-40

-------
     A regression analysis[33] of the  corrosion  rate of  low carbon steel
panels and ambient  levels of S02 at  various  sites  in the  Chicago area
indicated high correlation  between these  variables.  Similar  high correla-
tion was found between  sulfate levels  and corrosion rates.  The regression
equation fitting the  data was  given  as:

                             y =  .021  S  + 9.5

where y = annual corrosion  weight  loss (g/100 g  panel),  S = average  SCL
                    3
concentration, yg/m .
      Other  studies confirm the above findings.  Zinc  specimens were formed
 to corrode  more  rapidly in industrial  areas where total  suspended  parti-
 culate  levels were highest.  Figure 5-9  illustrates the atmosphere of
 cities  with greater concentration of particulates and  sulfur oxides -
 produces  the greater rates of corrosion.
                                     NEW YORK CITY
                                      (INDUSTRIAL)
                                           KEARNY, N.J.
                                           (INDUSTRIAL)
                               234
                               EXPOSURE, YEARS
       Figure 5-9.  Rate of corrosion caused by various  levels of
                    TSP and S02  in the Atmosphere ,[20].
                                    5-41

-------
     The relationships developed from the studies above may be used to
evaluate in a gross sense the potential impact of industrial boiler
emissions on the corrosive properties of the atmosphere.  The estimated
annual concentration of S02 in the vicinity of a cluster of industrial
coal-fired boilers is 13 yg/m3.  (See Table 5-2.)  In urban areas where the
annual S02 levels are 80 jug/m3 and TSP is 75 yg/m3 (the primary standards), the
boiler cluster could be expected to increase the corrosion  rate of steel and zinc
by  about 2.7% and 12% respectively.  This impact would be localized within
a one or two km range of the industrial cluster, and would  be reduced to one
forth the effect 5 km away.  The expected impact when the industrial boil-
ers are fired with oil is reduced somewhat:  the predicted  maximum increases
in  corrosion rates are 1.5% for steel and 8.5% for zinc.  It should be
noted that the extent of this impact is minor compared to that which occurs
in  the vicinity of typical non-controlled industrial boilers.

     Soiling of structures is particularly noticeable in atmospheres bearing
high levels of particulates and sulfur oxides.   Particles may soil painted
surfaces and cause staining and pitting.   Soiling of textiles (clothing,
curtains, upholstery) also contributes to direct costs  associated with
additional  cleaning and replacement of damaged  property.   A soiling cost
study[34] of the Washington, D0C. area has determined the cost damage function
of residential  soiling.   The relation was derived by  correlating  time in-
tervals  between  cleaning and maintenance  with  levels  of suspended particu-
lates  in  several  areas within the Washington,  D0C0  area.  By translating the
frequency of cleaning and maintenance into cost,  the  following  relationship
was  developed:
                             y  =  (1.85  x  ) -42
where  y  = cost per capita of soiling  damage,  x  =  particulate concentration,
       This  model  may be  used  to  estimate  roughly  the  potential  impact of
 controlled  boiler emissions on residential  soiling  damages.   The  in-
 crease in annual  TSP levels caused  by  a  cluster of  controlled industrial
 coal  fired  boilers was estimated to be 7  ng/m3.  This  represents  an annual
 cost  increase of  $13 per person  due to additional cleaning  and  maintenance'.
 In an area  currently experiencing particulate  levels  equivalent to the
                                   5-42

-------
federal air quality standard, annual cleaning costs associated with air
pollution are $96 per person.  Hence, it seems clear that particulate
emissions from  a  controlled  industrial  plant complex may cause sig-
nificant soiling  damage, however, these damages are limited to a relatively
small area within 1 or 2 km of the industrial complex.  According to the
emissions test  data, the damage occurring in the localized "hotspot" of
air pollution is  greater (40%) when the controlled boilers are coal-
fired as opposed  to oil-fired.  However, controlled firing of the boilers,
whether with coal or oil, results in significantly less soiling damage
than would occur  from boilers emitting at typical (uncontrolled) levels.
      One of the most obvious aesthetic effects of air pollution is decreased
visibility.  Visibility reduction occurs as a result of absorption and
scattering of light by suspended particles.  Visibility is affected most
dramatically by a narrow segment of the suspended particle size range, from
about 0.1 to 1.0 micron.  Visual range through suspended particulate
matter is given as,  [20]:
                                 i  _ 750
                                 L    C
                                                                        3
where L = visual range in miles, C = concentration of particulates, yg/m .
                                                  3
For typical  urban concentrations, such as 100 yg/m , the visibility is
                                                       3
7.5 miles, and for rural  concentrations such as 30 yg/m , the visibility
would be 25 miles.
     The visibility model  may be applied to estimate the impact of the
cluster of industrial  boilers on visibility.  Figure 5-10 illustrates the
variation in particulate concentration downwind of a coal-fired boiler
cluster under plume fumigation conditions.   The concentration profile is
constructed by superimposing the effect of a line of five single plants
which are spaced 2 km apart.  Because the concentration is non-uniform,
application of the visibility model is somewhat awkward.  In the vicinity
immediately downwind of the plant cluster, visibility would be reduced to
about one half an assumed background level  of 7.5 miles.  However, at a
distance 10 miles from the plant cluster, the concentration diminishes to
     q
6yg/m , and visibility would not be impaired significantly.  The impact on
visibility is not significantly different when the boilers are oil fired.
It should be noted that the plume fumigation conditions are short lived,

                                   5-43

-------
Z
o
<
DC
I-
z
UJ
O
O °
J  ^
UJ  *1
>  a
UJ
O
Z
o
oc
o
           120T
           100- •
                         COAL FIRING
            40- •
            20- •
                                12
                                      16
                                            20
                                                  24
                                                        28
                                                              32
                                                                    36
                                                                          40
                                   DISTANCE FROM SOURCES, Km
    Figure 5-10.  Ambient ground level concentration of suspended
                  particulates downwind of cluster of oil or coal-
                  fired industrial boilers.
 and that the concentration downwind diminishes dramatically after reaching
 a peak ground level  concentration about 1  km from the end of the cluster.
It is also noted that the vertical plume spread is limited, therefore,
scattering and absorption of light do not occur throughout the atmosphere,
as assumed by the visibility model.  Hence, the actual effect on visibility
is expected to be appreciably less than a 3.75 mile reduction in visual
range, and this effect would be highly localized.   Under more typical
meteorological  conditions, producing peak downwind levels of 29
suspended particulate, the visibility reductions occurring from an urban-
sited industrial  cluster would not be noticeable.
     The impact of visibility reductions depend greatly on the characteris-
tics of the existing environment.  If an industrial boiler cluster is  to be
sited in a scenic  vista where visibility exceed 50 miles, the impact  of
                                                o
atmospheric concentrations which exceed 100 ug/m  could be severe, although
highly localized and short-lived.  The impact would be essentially the same
whether  the controlled  boilers  were  burning  coal  or  oil.
                                    5-44

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Effect of Solid Waste—

     The major difference between impacts associated with  disposal  of  scrubber
cake from oil firing and coal firing concerns the overall  land requirements.
Because coal firing produces three times more solid waste  than oil  burning,
diversion of land use for landfills will be more extensive for coal-fired
plants.  Assuming landfill of waste to a depth of 20 feet, disposal  of the
scrubber cake from the controlled 10 MW coal-fired boiler  will  require
approximately an acre of land area every 2 years while disposal  of  the
scrubber cake from oil firing will require one acre every  6 years.   It may
be difficult to secure such land areas in the vicinity of  many boiler  sites,
and the threat of aesthetic degredation and depreciation of land values is
a major concern wherever disposal sites are chosen.

COMPARATIVE  ECONOMIC  IMPACT
     The direct economic  impacts  associated with residuals of fuel  combus-
tion involve the costs of damages  (or  benefits)  sustained when the
residuals enter the environment.   Second order  economic impacts
associated with the residuals involve  the alterations that occur
in employment, the tax base, energy prices,  income, and land values
due to the damages (or benefits)  resulting from combustion residuals.
The quantification of direct economic  impacts involves the difficult  task
of ascribing economic values to environmental changes.  Quantification
of second order economic effects  are yet more difficult because of gaps
in knowledge which make it impossible  to determine  the complex relation-
ships between  cost  and  the  numerous socio-economic factors involved.
        A number of ongoing energy  related studies  are attempting to
develop sophisticated economic models  which will  predict  the cost of
environmental damages,[2],[5],[41].  The models  address the cost of visi-
bility reduction, health effects  (morbidity  and mortality), and certain
second order effects.  Utilization  of  the models requires  substantial
input data involving  regional demography and emission source distributions.
The models require further refinement  and are currently under  continuing
                                   5-45

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 development.  The data base or scope of the present program did not permit
 the  adaption and utilization of such models.
      The  comparative extent of the economic impacts resulting from residuals
 of oil-fired and coal-fired boilers will be proportional to the extent of the
 comparative environmental damages identified previously.  The analyses have
 shown that the  differential impact of emissions from coal firing and oil
 firing is generally insignificant with  the possible exception  of some
 differences which occur in a limited localized area near clusters  of boilers.
 The  localized mortality rate for coal  firing is about  50% greater than
 from oil firing, localized soiling damages may be  40%  greater  from
 coal firing,  localized crop damage may  be significantly greater, and
 land requirements for waste disposal  are three times greater for coal
 firing.  The  economic cost of these incremental differences  will be
 significant in the limited and affected areas.   Medical costs  and  loss
 of productivity will  be experienced to  a greater extent in the area
 of coal-firing, annual  cost of cleanup  and maintenance for soiling
 damages will  be about $4 more per person in the most affected  area,
 revenue for crop crop sales will  be reduced somewhat,  and esthetic
 blight in the area of landfills will  diminish  the  value of land and
 activities nearby.  The extent of these economic effects is  substan-
 tially less than that which would be expected  from a cluster of
 either oil firing or coal  firing of uncontrolled industrial  boilers.
 Because the significant differences in  direct  economic impacts occurring
 from controlled oil-fired  and  coal-fired boiler emissions are  limited
to a relatively small  area near the source, the total  costs  of the
incremental  environmental  damages are apt to be insignificant  on a
regional  basis.   Consequently, significant incremental  second  order
economic impacts, such  as  changes in  hospital  employment, alteration of
tax bases, or changes in income would  be unnoticeable  between  controlled
oil and coal-fired industrial  boilers.
 IMPACT ON ENERGY
     The comparative  effect'of environmental residuals  from  controlled
 coal  combustion versus oil combustion will influence potential restrictions

                                   5-46

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on the production and use of coal or oil.  If additional  controls are re-
quired to assure the environmental acceptability of coal  or oil  firing in
industrial boilers, these requirements will affect the economics of coal
utilization and the shaping of energy policy.  If it is shown that coal
and oil-fired industrial boilers can be controlled adequately at reasonable
cost, then policies may be developed to support the use of either of these
fossil fuels.  Presumably, the use of coal is desirable,  given that the
associated degree of environmental insult is no worse than that of alter-
native fuels.
     The results of this study tend to support the national energy plan
for the intensified utilization of coal.  It was shown that both coal and
oil-fired industrial boilers may be controlled with reasonably available
technology and siting requirements to meet existing environmental standards,
and more importantly, that the difference in impact between oil and coal
firing in well-controlled boilers is relatively insignificant with the
possible exception of effects resulting from a threefold difference in the
amount of solid waste generated, as well as potential differences in NO
                                                                       A
emissions levels.  The reference boiler of this study was  not controlled
for NO  emissions, and the tests showed that coal firing produced two times
      A
more NO  emissions than oil firing.  A twofold difference  in  the uncontrolled
       A
NO  emissions levels could translate to potentially significant differences
  A
in ambient levels of photochemical air pollution, and the difference in solid
waste generation rates from controlled boilers would lead to greater
impacts on land use where waste disposal sites are selected.  If additional
controls are employed for coal burning plants to mitigate these differences,
the cost of coal utilization will increase, and energy policy will be im-
pacted.  Whether or not increased coal utilization will be economically
attractive will depend on the extent of the incremental control costs for
NO  and solid waste disposal relative to the total cost of coal and oil
  A
utilization in boilers.
                                   5-47

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     Table 5-15  illustrates  the  component  costs  for operation  of a  large
oil  or coal  burning  boiler.   The cost  of NOY  emissions  control  is relatively
                                           /\
insignificant compared to  SO  and particulate control.   The  annualized  cost
                            /\
of an FGD and particulate  control  system may  increase  the  cost of a large
boiler by 20 to  30%; the relative increase is still  greater  for smaller
boilers.  The annualized cost of FGD and particulate control systems is
significantly greater for  coal-fired boilers  than  oil-fired  boilers because
greater quantities of solid  waste (scrubber cake)  are  generated during
     TABLE 5-15.   ANNUAL  COST  OF  OPERATING  UTILITY  BOILERS,[38],[39],[40]
Cost Category
Capital cost of plant
Fuel
Fuel Storage
Flue Gas Desulfurization (wet
lime/limestone scrubber)
Solid Waste Disposal
NO control (low excess air
Tiring and staged combustion)
Operation and Maintenance
TOTAL
Cost in Mills/Kwhr. !
Coal
4.05
3.14
.08
1.6

1.4
.03

.39
10.69
Oil
3.38
4.04
.04
1.6

.4
.03

.21
9.70
                                  5-48

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coal firing.  Because landfill waste disposal methods for scrubber cake
appear to be environmentally acceptable, additional  technology (such as
regenerative FGD systems) or special mitigation measures (such as special
landfill reclamation techniques) may not be required for either coal or oil
combustion.  Whatever the comparative extent to which additional  controls
may be required for oil versus coal-fired boilers, the comparative cost of
such controls will probably be relatively minor compared to the overall
operating cost of a boiler and other factors affecting the overall costs.
The most significant single factor affecting the operating costs  of the
boiler is the cost of fuel.  Any comparison of costs between coal and oil
utilization is difficult because of the financial uncertainities  associated
with future fuel prices.  At present, the total generation cost for a coal
plant are roughly competitive with those of an oil-fired plant, but may be
significantly different if fuel costs change markedly.
     Oil prices are determined by a complex set of political and economic
considerations.  Whether the relative coal prices remain the same, and
whether capital will be available to exploit the coal reserves, depends on
the existence of a long term market for coal.  Unclear and changeable
issues such as air pollution regulations, levels of oil imports, natural
gas prices, and the cost of capital, create uncertainties for the future
coal market.
     While the differential impact between combustion in well-controlled
coal-fired and oil-fired industrial boilers may pose a relatively minor
issue with respect to energy production or utilization, the absolute im-
pacts of fossil fuel combustion may produce serious concerns in the long
term.  Although the predicted pollutant loadings may meet environmental
standards, it is not entirely clear whether the increasing use of fossil
fuels may be continued at the forecasted levels of control technology
without potential long term environmental damages.  If it is found that
long term effects of pollution (e.g., trace metals accumulation, lake
acidity, land use) are unacceptable, then more stringent environmental
regulations can be expected, and it is clear that energy use may be affected.
Energy cost will increase with increasing control requirements, possibly
to the level where significant social impacts may occur, and other fuel
types may become more feasible alternatives.

                                   5-49

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     In conclusion, it appears that the comparative analyses of
this study support energy proposals to intensify coal  utilization.  The com-
bustion of either coal or oil  in controlled industrial boilers produces.
similar environmental  effects  and the cost associated  with mitigating any
significant differences in environmental  insult are relatively minimal.
In supporting the policy for increased coal  utilization,  the comparative
impact of coal  versus  oil  firing carries  implications  for many impact sectors
associated with the overall  coal utilization policy.   The impacts are
observed among  all aspects of  energy supply and use,  including mining, fuel
production, transport, and fuel  end use.   The affected impact sectors of
the social and  economic environment include employee  demand at develop-
ment areas, services provided  by affected communities, balance of revenues,
cost of living, demography,  and quality of life.  Major impact sectors
affected by energy policies  in the physical  environment include land use by
mining operations, water resources and their quality,  and ecological
systems.  The multi-faceted  assessment of increased coal  utilization poli-
cies in terms of the overall energy systems  trajectories  (e.g., mining-
production, etc.) is being conducted in various ongoing studies funded by
the federal government.  The EPA is currently implementing the CCEA program
to coordinate many of these  studies into  an overall  environmental assess-
ment structure.  The present study comprises one element of the CCEA program,
and focuses specifically on  fuel end use  by assessing  the comparative impact
of environmental  residuals resulting between oil firing and coal  firing in
controlled industrial  boilers.
SUMMARY
     Major general conclusions evolving from the environmental analysis are
as follows:
     •  The difference in environmental  insult expected to result between
        coal  and oil combustion emissions from a single controlled
        10MVJ industrial boiler is insignificant.  This is because:  1)
        there are only slight  differences in the emissions levels of the
        pollutants, or 2)  the  absolute impact of either fuel use is insig-
        nificant.
     a  The environmental  impacts of emissions from a  cluster of con-
        trolled 10 MW industrial boilers  are potentially  significant.
        The impacts include  health effects, material  damages, and eco-
        logical effects from high levels  of SCL, NO  and suspended partic-
                                              t-    /\

                                   5-50

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        ulate matter; health effects and ecological  damage  due  to  trace
        metal accumulation in soils and plants;  and  esthetic  degradation
        from visibility reduction and waste disposal  sites.

     •  The risk of environmental damage from emissions  of  controlled
        industrial  boilers, whether oil or coal-fired,  is considerably less
        than the risk posed by emissions from uncontrolled  industrial
        boilers.  It should be noted that this finding  is based on an ex-
        ceptional  facility.  The reference facility  is  very well  run and
        maintained, and emissions are low.

     •  The environmental acceptability of a cluster of controlled industrial
        boiler emissions is more dependent on site specific factors
        (e.g., background pollution levels, location  and number
        of other sources) than type of fuel utilized.  Careful  control of
        the site specific factors can avert potential environmental  damages
        and generally compensate for any differential effects arising be-
        tween the use of coal or oil.

     t  With the possible exception of ambient levels of NO,  the  risk of
        violating the NAAQS due to operation of clusters  of controlled
        industrial  boilers is essentially the same whether  the  fuel  combusted
        is coal or oil.  Based on tests of the reference 10 MW  boiler  (which
        was not controlled for NO  emissions), localized NO  concentrations
        produced by coal-firing are estimated to be  twice tne level  of that
        resulting from oil-firing, and greater than  the  levels  permitted by
        the NAAQS for 24 hour and one year averaging periods.

     •  Short term (3 hour and 24 hour averaging times)  maximum ambient
        concentrations present the most significant  air pollution  problem
        resulting from operation of controlled industrial boilers.
        Restrictions imposed by the NAAQS for short  term ambient levels
        would be most constraining to boiler operation  in areas where air
        quality is  already only marginally acceptable.   Expected long term
        concentrations arising from boiler emissions  would  not  appear to
        pose a risk for violation of the NAAQS.

     •  Coal firing appears to produce a greater enrichment of  trace elements
        in the flue gas desulfurization cake than oil firing  produces.  How-
        ever, the scrubber cake resulting from either coal  or oil  firing
        contains sufficient amounts of heavy metals  and  toxic substances to
        pose difficult waste disposal problems.

The above conclusions are supported by the data summary  of  Table 5-16 which

tabulates estimates of the of the comparative potential  impacts resulting
from oil firing and coal firing of a clustered configuration of controlled
industrial  boilers.  The impact categories considered include public

health, ecology, societal impact, economic impact, and  energy.   The specific

findings with respect to the various impact categories  are  summarized

briefly below.

                                   5-51

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                   TABLE  5-16    ESTIMATED  ENVIRONMENTAL  IMPACTS  RESULTING  FROM  OIL  FIRING  AND  COAL  FIRING
                                      OF  A  CLUSTER  OF  CONTROLLED  INDUSTRIAL  BOILERS
                                      Analysis Tool
                                                                              Ixtent  or
                                  Coal  Firing
                                 OilFiring
                                                                                                                      Comparative Assessment of  Impacts
en
i
en
ro
             Publ it Heal til
             Mortality
             Pub I 1L Heal th
             MorLidi ty
             Public Health  -
             effects from
             plant takeup of
             trace elements.
             Public  Health -
             effects  from trace
             elements  in runoff
             waters.
             Vegetation  (crops)
lundy/Grahn Sulfate ModelJ
(regional  effects3)
Lundy/Grahn S02  & TSP Model
fitted to  Lave & Seskin data.
EPA Health Effects Estima-
tion Model 11
40 year deposition of atmos-
pheric trace  element loadings
and plant  concentration
ratios.3
Application of  average
sediment burden  rates for
representative  runoff per
unit watershed  to cumula-
tive soil  deposits of metals
originating from the
joiler emissions.

Empirical  data  from NOX
laboratory studies'9
                                Jupirical  data  from  SO,,
                               Laboratory Studjesl8
                                'valuation of acid  rain
                                'rom SO^ washout.
                             [50 deaths/10  persons/yr.
                             Mn Central  U.  s.
                             550 deaths/106persons/yr.
                             in localized area  near
                             bofler cluster.

                             5% increase in incidence of
                             chronic respiratory.disease
                             at threshold level .

                             Produces 30 times  increase in
                             endogenous  plant concentra-
                             tions for Mo.   Incremental
                             burdens of other elements in
                             Same as  coal-firing.

                             ;370 deaths/106 persons/yr.
                             [in local ized  area near
                             fcoiTer cluster.

                             Same as  coal  firing.
                             Produces  lOx  increase in
                             endogenous  plant levels
                             for Cd  and  1.5 x for Mo.
                             Incremental burdens of other
plant tissue are from 1/2 to  (elements  in plant tissue are
                                                            1/230 the typical  plant
                                                            levels.
                                                          j from  1/10  to 1/2300 the
                                                          typical  plant levels.
                             Se and  Mo estimated to
                             exceed  background levels for
                             metals  in runoff waters.
                             However, levels of all ele-
                             ments are three to seven
                             orders  of magnitude less than j
                             drinking water standards.
                             Levels  of all elements are
                             three  to seven orders of
                             magnitude less than drink-
                             ing  water standards.
                             Localized acute leaf damage  (Maximum  short term concen-
                             may occur during short term  Itrations of NOX expected to
                             plume  fumigations.  Localized Ibe below threshold level
                             growth  and yield reductions
                             may  be  expected over the long
                             term.

                             Potential for localized plant
                             damage  is remote except in
                             area where S02 levels already
                             approach plant damage tnresh-
                             hold  (typical in areas, where
                             NAAQS  are violated).

                             Insignificant effect on
                             plants  due to relatively
                             insignificant levels of
                             suspended sulfates pre-
                             dicted  from controlled
                             boilers
                                                                                         for plant damage.
                             Same  as coal , although
                             slightly more remote chance
                             of leaf damage.
                             Same  as  coal firing.
No difference

Localized mortality rate from coal-
firing is about  505! greater than
from oil  firing.

No difference
Both oil  firing  and coal firing
could produce  elevated  levels of a
trace element  in  plant  tissue
approaching  the  injurious level to
man.  Coal  produces this increase
for Mo and oil  produces  it for Cd.
The effect  from  other trace ele-
ment burdens  is  believed to be
insignificant.

Concentration  of  metals in runoff
waters from  oil  firing  expected to
be slightly  less  than that occur-
ring from coal firing.  Hazard to
human health  in  either  case is
remote.
                                                          Difference  in localized crop
                                                          damage  could be significant,
                                                          but  isolated to about a range
                                                          of 1  to  3 km from the boiler
                                                          cluster.
Minor difference.
                                                          Ho  difference.

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                      TABLE  5-16.    (Continued)
                      Impact Category
         Andlys i b  Tuul
                                                                                       Extent of Impact.
      Coal Firing
      Oil Firintj
                                                                                                                                 Comparative Assessment of Impacts
en
 i
en
CO
                    Materials
                    Property
                    Visibility
                    Public Health
                    Drinking water,
                    crops
                    Land  use
                                       Compdrison  of  expected
                                      i trace  element  concentrations
                                      | In  plants with  acceptable
                                      !levels.
 Corrosion effects.
i Regression equation from ex-
 perimental data33 using
 SOj as determinant, and
i experimental  data for
 corrosion of  zinc in TSP
 laden atmosphere.

 Soiling cost  damage
 function derived  in
 Washington D.C.
 Reduction of visibility
 based on relationships
 determined from ambient
 measurements. 20
 Calculation  of  leaching
 rates  based  on  perme-
 ability data and  labora-
 tory analyses of  scrubber
 cake.
I

[Calculation  of  leaching
I rates  based  on  perme-
jability data and  labora-
Uory analyses of  scrubber
 cake.

 Calculations  of landfill
 acerage requirements based
 on  20  ft solid  waste layer.
 Insignifii ant  effect  on
 plants.   Possible  exception
 would  be  localized  plant
 damage due  to  elevated levels
 of Mo  in  plant tissue.

 Localized  increase  in corro-
 sion rate of steel  and zinc
 by 2.71 and 12% respectively
 (in areas marginally  in
 compliance with NAAQS).
Annual cost  of  $13
per person.


Maximum potential visibility
reduction of 4 miles where
background visibility is
typically urban at 7.5 miles.
Effect is extremely
localized.

Insignificant impact when
proper landfill  design
employed.
Insignificant impact when
proper landfill  design
employed.
                                                                    1/4 acre/year
                                                                     otential  reduction  in
                                                                    property value  near
                                                                    landfill.
                                                             Insigni ficant effect uit
                                                             plants wi th possible ex-
                                                             ception of localized plant
                                                             damage due to high Cd levels.
                                                                                                  Localized  increase  in corro
                                                                                                  sion  rate  of steel  and zinc
                                                                                                  by  1.5;-, and 8.5% respectively
                                                                                                  (in areas  marginally in
                                                                                                  compliance with NAAQS).
Annual  of  $9
per person.


Same as coal-firing.
                                                                                                  Same as coal  firing.
Same as  coal  firing.
                              1/12 acre/yr.
                               otential  reduction  in
                               roperty  value  near
                               andfill.
                               Minor  difference.
                              Slightly greater corrosion
                              damage expected from coal firing,
                              but difference is localized to
                              relatively small area near boiler
                              cluster
 Localized  soiling damages are
 40i  greater  from coal  firing.


 No difference.
                              No  difference.
No difference.
                             Coal firing requires three
                             times more land use for waste
                             disposal.
                   a.  This application of the  Lundy/Grahn  model  pertains to effects from suspended sulfate.  The formation of airborne  sulfates  is a long
                       range and regionwide problem  and  is  treated  by considering emissions levels from industrial boilers throughout  the  region.

                   b.  The incidence of disease would  increase only  in those areas where the threshold level of 10/jg/m3 sulfate  is  exceeded  regularly.

                   c.  The environmental  impact of wastewater from  the boiler operation was presumed insignificant.   The wastewater  is delivered  to the
                       municipal sewage treatment facility.

-------
Health Effects —

     •  Based on the  Lundy/Grahn  Model  for  health  effects  associated  with
        suspended sulfate  levels,  regional  emissions  levels  from
        controlled oil  or  coal-fired  industrial  boilers would  not  be  ex-
        pected  to cause a  significant impact  on  regional health.   Emissions
        from uncontrolled  boilers  would result in  substantially greater
        levels  of regional  suspended  sulfate  levels,  and the associated
        health  effects  would  be an order of magnitude greater.

     •  Emissions from  clusters of controlled industrial boilers are
        expected to cause  significant adverse health  effects in a  localiz-
        ed area near  the plant cluster.   Oil  firing would  be expected to
        result  in localized health effects  about one  third less severe
        than those resulting  from  coal-firing.   The increase in mortality
        attributable  to either well-controlled coal or oil-firing  is  appre-
        ciably  less than that associated with uncontrolled industrial
        boilers emitting higher levels  of particulates and SO
                                                            /\

     •  The impact of solid waste  generation  on  health is  essentially the
        same for controlled coal  firing and oil  firing, provided suit-
        able land disposal  techniques are employed to assure minimal  leach-
        ing rates and migration of trace elements  to  groundwater and  the
        terrestrial environment.

     •  Addition of cadmium to a  localized  environment in  the quantities
        produced by clustered controlled industrial boilers jnay cause
        levels  of cadmium  concentrations in plants approaching levels in-
        injurious to  man.   Because cigarettes contain significant  cadmium
        levels, smokers are more  apt  to achieve  thresholds of observable
        symptoms for  cadmium  exposure when  consuming  additional cadmium via
        the food chain.

     e  The concentration  of  metals in  runoff waters  due to  controlled
        oil-firing is predicted to be slightly less than that occurring
        from controlled coal  firing;  in either case,  hazard  to human
        health  by drinking water  is remote„

     •  Trace element emissions from  clusters of controlled  industrial
        boilers may significantly  increase  local background  levels  in drink-
        ing water, plant tissue,  soil,  and  the atmosphere; however, the ex-
        pected  increases in the levels  of such elements are  generally
        several orders  of  magnitude less than allowable exposure levels.
        Oil -firing is estimated to cause cadmium burdens in  plants  approach-
        ing levels injurious  to man,  and coal firing  may produce plant
        concentrations  of  molybdenum  which  are injurious to  cattle.
Ecology--
        The potential  for crop  damage  from  either controlled  coal
        firing or oil  firing  depends greatly  on  ambient  levels  of NO  ,  S0?,
        or trace element  soil concentrations.   If such levels are presently
        high, localized  plant damage would  be  expected to  occur within  a 1
                                  5-54

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        to 2 km range from a  controlled  boiler  cluster.  Leaf destru-
        tion from SO, exposure  would  be  expected  to  be slightly more severe
        in the vicinfty of a  cluster  of  controlled  boilers which are
        coal-fired as opposed to  oil-fired.   For  boilers uncontrolled for
        NO  emissions, plant  damage would  be  expected to be significantly
        griater in the vicinity of the coal-fired cluster, owing to higher
        levels of ambient  NO  produced.  The  likelihood of damage occurring
        in plants due to emissions of trace elements from either
        controlled oil or  coal  firing is remote,  with the possible ex-
        ception of injury  due to  elevated  levels  of  molybdenum and cadmium
        in plant tissue resulting from coal firing  and oil firing,
        respectively.

     9   The effect of emissions from  industrial boilers on trace element
        burdens in plants  is  greater  via soil  uptake than by foliar inter-
        ception.  This is  because soil concentrations are the result of
        accumulative long  term  exposure  to boiler emissions whereas foliar
        exposure is determined  by the immediate deposition rate of emissions
        on the plant surface  and  the  lifetime of  the leaf.

     9   The impact of fossil  fuel combustion  in controlled oil or coal-
        fired boilers on plant  damage via  acid precipitation would be rela-
        tively insignificant.  The levels  of  suspended sulfate  (the origin
        of acid rain) would be  essentially the same  whether the
        led boilers are coal  or oil-fired.

     e   Measurement and analyses  of  leaching  rates  at experimental waste
        disposal sites indicate that  landfills  of untreated flue gas desul-
        furization system  scrubber cake  can be constructed such that signi-
        ficant adverse impacts  will  not  occur.
Societal--
        The impact of boiler emissions  on corrosion  in  the  local  area  near
        a cluster of controlled  industrial  boilers will  be  significant.
        The corrosion rate will  be slightly greater  when the  boilers are
        coal-fired.  However, the  extent of this  overall  impact  (oil or coal)
        is minor compared to that  which occurs  when  industrial boilers are
        uncontrolled.

        The increase in annual  TSP and  soiling  damages  in the vicinity of
        a cluster of controlled industrial  boilers  results  in additi-
        tional  cleaning and maintenance costs about  10  to 15% greater  than
        that already experienced in a typical urban  area.  The cleaning
        costs may be slightly greater when  the  boilers  are  coal-fired.

        Emissions of particulate matter from controlled industrial
        boilers will result in visibility reduction. This  aesthetic
        degradation will occur in a localized area  near the boiler  cluster,
        and occurs to essentially the same  extent whether the boilers  are
        oil or coal-fired.

        Total land disposal requirements for scrubber cake  waste  generated


                                   5-55

-------
        by controlled  coal  firing  are  three  times  greater  than  those
        for for  controlled  oil  firing.  Waste disposal of  the scrubber
        wastes  may result  in  significant  depreciation  of  property value
        and aesthetic  degredation  in  the  area of the disposal site.   These
        impacts  would  be more severe  if boilers  use coal  rather than  oil.
Energy--
        At the present time,  the  comparative  assessment  of  the  effects  of
        emissions  from controlled oil  and  coal-fired  industrial  boilers
        tends  to  support  the  national  energy  plan  for intensified  utilization
        of coal.   The  fuel  choice of oil or coal is a relatively minor
        issue  concerning  the  environmental acceptibility of controlled
        industrial  boilers; other site specific  and plant design factors
        exert  a greater effect  on environmental  damages.  While  it was
        shown  that fuel choice  caused  significant  differences in impacts
        to occur when  the boiler  is uncontrolled for  NOX emissions,  these
        differences may be  mitigated by the addition  of  NOX control
        technologies with minimal  overall  cost impact.

        As concern for environmental protection  increases,  the  issue may
        not be whether coal or  oil use is  more environmentally acceptable,
        but whether the increasing use of  fossil fuels can  be continued at
        the present levels  of control  technology without  potential long
        term damages.   If it  is found  that long  term  effects of pollution
        (e.g., trace metals accumulation,  lake acidity from acid rains)
        from fossil  fuel  combustion and other sources are environmentally
        unacceptable,  it  is clear that energy use  may be  affected.   Energy
        cost will  increase with increasing control requirements, possibly
        to the level where other  cleaner forms of  energy  become more
        competitive.
                                  5-56

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                        REFERENCES FOR SECTION 5


1.    Department of Health, Education, and Welfare, "Report of the Committee
     on Health and Environmental Effects of Increased Coal Utilization,"
     December 1977.

2.    Argonne National  Laboratory, "A Preliminary Assessment of the Health
     and Environmental  Effects of Coal Utilization in the Midwest,"
     January 1977.

3.    B. Vaughan,  et  al,  Battelle Pacific Northwest Laboratories,  "Review  of
     Potential Impact  on Health and Environmental Quality from Metals
     Entering the Environment as a Result of Coal Utilization," August 1975.

4.    G. Waldbott, "Health Effects of Environmental Pollutants," 1973.

5.    R. T.  Lundy  and D.  Grahn, Argonne National  Laboratory,  "Predictions of
     the Effects  of  Energy Production on Human Health," a paper presented at
     the Joint Statistical Meetings of the American Statistical Association
     Biometric Society,  Chicago, Illinois, August 1977.

6.    S. Finch and S. Morris,  Brookhaven National  Laboratory, "Consistency of
     Reported Health  Effects  of Air Pollution,"  BNL-21808.

7.    Argonne National  Laboratory, "An Integrated  Assessment of Increased  Coal
     Use in the Midwest:  Impacts and Constraints, Volume II," National  Coal
     Utilization  Assessment,  October 1977.

8.    Angonne National  Laboratory, "An Integrated  Assessment of Increased
     Coal  Use in  the Midwest:   Impacts and Constraints, Volume I," National
     Coal  Utilization  Assessment, October 1977.

9.    Synfuels Interagency Task Force, Department of Interior, "Synthetic  Fuels
     Commercialization  Program — Draft Environmental  Statement,"  ERDA-1547,
     December 1975.

10.   C. Sheih, "Application of a Langrangian Statistical  Trajectory Model to
     the Simulation  of  Sulfur Pollution over North Eastern United States,"
     Preprints of Third  Symposium on Atmospheric  Turbulence, Diffusion,  and
     Air Quality, 1976.

11.   W. Nelson, J. Knelson, V. Hasselblad, Health Effects Research Laboratory
     of Environmental  Protection Agency, "Air Pollutant Health Effects
     Estimation Model,"  EPA Conference on Environmental Modeling  and Simula-
     tion,  Cincinnati,  April  1976.

12.   Teknekron ,  Ongoing program sponsored by Environmental Protection
     Agency, "Cooperative Development of an Industrial  Assessment Model
     Under Existing Integrated Technology Assessment,"  Contract No. 68-
     01-1921.
                                   5-57

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13.   G.  Sehmel,  Battelle  Pacific Northwest Laboratories,  "Pacific Northwest
     Laboratory  Annual  Report for 1972,"  BNWL 1751,  Vol  II, 1973.

14.   L.  Wilson,  "Seasonal  Sediment Yield  Patterns of U.S.  Rivers," Water
     Resources  Res.  8:1470-1479, 1972.

15.   John Hoover,  Division of Energy  and  Environmental  Systems,  Argonne
     National  Laboratories,  Personal  Communication,  Feburary 1978.

16.   R.  Krizek  and J.  Fitzpatrick, Northwestern University, "Double Alkali
     Landfill  Tests  Evaluation," Technical  Report 120,  April 1976.

17.   Argonne National  Laboratories,  "The  Environmental  Effects of Using Coal
     for Generating  Electricity," prepared for Nuclear  Regulatory Commission,
     Washington  D.C.,  May  1977.

18.   U.S. Department of Health,  Education and Welfare,  "Air Quality Criteria
     for Sulfur  Oxides,"  AP-50,  March  1967.

19.   U.S. Department of Health,  Education,  and Welfare,  "Air Quality Criteria
     for Nitrogen  Oxides," January 1971.

20.   U.S. Department of Health,  Education,  and Welfare,  "Air Quality Criteria
     for Particulate Matter," January  1969.

21.  U.S. Department of Health,  Education and Welfare,  "Air Quality
     Criteria for Carbon Monoxide," March 1970.

22.  "Effects of Trace Contaminants from Coal Combustion," Proceedings of
     a Workshop Sponsored by Division of Biomedical  and Environmental
     Research and Development Administration, August 1976, Knoxville,
     Tennessee.

23.   Draft of proposed rules for "Standards Applicable  to Owners and
     Operators of Hazardous Waste Treatment, Storage and Disposal Facili-
     ties," Obtained from Office of Solid Waste, Environmental Protection
     Agency, March 1978.

24.   W.  Berry and A. Wallace, "Trace Elements in the  Environment - Their
     Role and Potential Toxicity as Related to Fossil Fuels," University of
     California  Laboratory of Nuclear Medicine and Radiological  Biology,
     1974.

25.   Argonne National  Laboratory, "Assessment of the Health and Environ-
     mental Effects  of Power Generation in the Midwest," Vol. II Ecological
     Effects, April  1977.

26.   H.  Thienes  and T.  Haley, "Clinical Toxicology," Published by Kimpton
     Publishes,  London 1972.

27.   G.  Waldbott,  "Health Effects of Environmental Pollutants," Published
     by Mosby Company,  1973.
                                   5-58

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28.  Department of Health Education, and Welfare, "Air Quality Criteria
     for Hydrocarbons," March 1970.

29.  U.S. Environmental Protection Agency, "1972 National  Emissions  Report,"
     June 1974.

30.  Department of Health, Education and Welfare, "Air Quality Criteria
     for Photochemical Oxidants," March 1970.

31.  N. Glass, Office of Health and Ecological Effects, "Ecological  Effects
     of Gaseous Emissions from Coal Combustion," November 1977.

32.  Committee on Food Protection, Food and Nutrition Board, National
     Research Council, "Toxicants Occurring Naturally in Foods," Published
     by National Academy of Sciences, 1973.

33.  J. Upham, "Atmospheric Corrosion Studies in Two Metropolitan Areas,"
     Journal of Air Pollution Control Association, June 1967.

34.  I. Michelson, "The Household Cost of Living in Polluted Air in the
     Washington D.C.  Metropolitan Area," a report to the U.S. Public
     Health Service.

35.  R. Wilson and D. Minnotte, National Air Pollution Control Administra-
     tion, "A Cost Benefit Approach to Air Pollution Control," Journal of
     the Air Pollution Control Association, May 1969.

36.  Environmental Protection Agency, Office of Research and Development,
     Office of Energy Minerals and Industry,  "Health and Environmental
     Impacts of Increased Generation of Coal Ash and FGD Sludges," Report
     to the Committee on Health and Ecological Effects of Increased Coal
     Utilization, November 1977.

37.  Federal Energy Administration, "Project  Independence,"
     November 1974.

38.  Argonne National Laboratory,  "Environmental Control Implications of
     Generating Electric Power from Coal," Technology Status Report
     Volume I, Coal Utilization Program, December 1976.

39.  TRW, "Evaluation of Emission  Control Criteria for Hazardous Waste
     Management Facilities,"  prepared for U.S. Environmental Protection
     Agency, Office of Solid  Waste, April 1978.

40.  Science and  Public  Policy Program, University of Oklahoma,  "Energy
     Alternatives:  A  Comparative  Analysis,"  May 1975.

41.  Ford,  A,  and H.W. Lorber, Los Alamos Scientific Laboratory, "Metho-
     dology  for the  Analysis  of the  Impacts  of Electric Power Production
     in  the West," January  1977.
                                   5-59

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5-60

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                                TECHNICAL REPORT DATA
                         (Please read Instructions on the reverse before completing)
, REPORT NO.
EPA-600/7-78-164b
            3. RECIPIENT'S ACCESSION NO.
 T.TLE AND SUBTITLE Environmental Assessment of Coal-
and Oil-firing in a Controlled Industrial Boiler;
Volume n. Comparative Assessment
            5. REPORT DATE
             August 1978
            6. PERFORMING ORGANIZATION CODE
          c> Leavitt, K.  Arledge, C. Shih, R.  Orsini,
 W. Hamersma, R. Maddalone,  R. Beimer, G. Richard, and
 M. Yamada	
            8. PERFORMING ORGANIZATION REPORT NO.
 PERFORMING ORGANIZATION NAME AND ADDRESS
TRW, Inc.
One Space Park
Redondo Beach, California 90278
            10. PROGRAM ELEMENT NO.
            EHE624A
            11. CONTRACT/GRANT NO.

            68-02-2613, Task 8
12. SPONSORING AGENCY NAME AND ADDRESS
 EPA, Office of Research and Development
 Industrial Environmental Research Laboratory
 Research Triangle Park. NC 27711
            13. TYPE OF RE PORT AND PERIOD COVERED
            Task Final; 5/77-7/78	
            14. SPONSORING AGENCY CODE
              EPA/600/13
is. SUPPLEMENTARY NOTES jjERL-RTP project officer is Wade H. Ponder,  Mail Drop 61, 919/
541-2915.
is. ABSTRACT
              repOrt gives results of a comparative multimedia assessment of coal-
 versus oil-firing in a controlled industrial boiler,  to determine relative environmen-
 tal, energy, economic, and societal impacts. Comprehensive sampling and analyses
 of gaseous, liquid, and solid emissions from the boiler and its control equipment were
 conducted to identify criteria pollutants and other species.  Major conclusions include:
 (1) While the quantity of particulates from oil-firing is  considerably less than from
 coal-firing, the particles are generally smaller and more difficult to remove, and the
 concentration of particulates in the treated flue gas from oil-firing exceeded that from
 coal-firing.  (2) NOx and CO emissions during coal-firing were about  triple those du-
 ring oil-firing. (3) Sulfate emissions from the boiler during coal-firing were  about
 triple those during oil-firing; however, at the outlet of the  control equipment, sulfate
 concentrations were essentially identical.  (4) Most trace element emissions (except
 vanadium, cadmium, lead, cobalt, nickel, and copper) are higher during coal-firing.
 (5) Oil-firing produces  cadmium burdens  in vegetation  approaching levels which are
 injurious to man; coal-firing may produce molybdenum levels which are injurious to
 cattle. (6) The assessment generally supports the national  energy plan for increased
 use of coal by projecting that the environmental insult from coal-firing is not signif-
 icantly different from that from oil-firing. -
                             KEY WORDS AND DOCUMENT ANALYSIS
                DESCRIPTORS
                                           3.IDENTIFIERS/OPEN ENDED TERMS
                                                                    c. COSATI Field/Group
Pollution
Assessments
Boilers
Combustion
Fuel Oil
noal
Dust
                     Nitrogen Oxides
                     Carbon Monoxide
                     Sulfates
                     Sulfur Oxides
                     Trace Elements
                     Chemical Analysis
Pollution Control
Stationary Sources
Environmental Assess-
   ment
Industrial Boilers
Particulate
13B
14 B
13A
21B
2 ID

11G
07B
06A
07D
 3. DISTRIBUTION STATEMENT

 Unlimited
EPA Form 2220-1 (9-73)
19. SECURITY CLASS
Unclassified
      168
20. SECURITY CLASS (This page)
Unclassified
                         22. PRICE

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