AN  EVALUATION  OF CONTROL STRATEGIES
 FOR STATIONARY FUEL  BURNING SOURCES
 IN  THE  THIRTY  INNER CITIES AND TOWNS
      OF THE METROPOLITAN BOSTON
INTRASTATE AIR  QUALITY  CONTROL  REGION
                  Prepared under
                Contract No. 68-02-0049
                   JUNE 1973
                   Prepared for

             DEPARTMENT OF PUBLIC HEALTH
           COMMONWEALTH OF MASSACHUSETTS
                Boston, Massachusetts

                     and

           ENVIRONMENTAL PROTECTION AGENCY
              OFFICE OF AIR PROGRAMS
                Raleigh, North Carolina
                .toward a better environment.. —

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AN EVALUATION OF CONTROL STRATEGIES FOR STATIONARY

 FUEL BURNING SOURCES IN THE THIRTY INNER CITIES

       AND TOWNS OF THE METROPOLITAN BOSTON

          INTRASTATE AIR QUALITY CONTROL

                      REGION
                  Principal Author

                Dr.  Richard D.  Siegel


                 Contributing Authors
                   •Edward W. Rich
                   Paul  Morgenstern
                     June 1973
                    Prepared for
             Department of Public Health
            Commonwealth of Massachusetts
                Boston, Massachusetts

                        and

          Environmental Protection Agency
              Office of Air Programs
             Raleigh,  North Carolina

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  Section
                              TABLE OF CONTENTS
Title
Paqe
     I        INTRODUCTION  	   1-1

             A.   Regulatory  Background	   1-1
             B.   Study  Objecti ves  	   1-1
             C.   Methodology 	   1-5

    II        SUMMARY  	   2-1

             A.   Emission  Reductions 	   2-2
             B.   Technical  Feasibility 	   2-11
             C.   Economic  Impact of Control Strategies 	   2-13
             D.   Administrative Requirements 	   2-16
             E.   Conclusions 	   2-16
             F.   Recommendations 	   2-19

   III        EMISSIONS AND EMISSIONS REDUCTION 	   3-1

             A.   Source and Fuel Inventory  	   3-1
             B.   Emission Factors 	   3-4

    IV        TECHNICAL FEASIBILITY  	   4-1

     V        CAPITAL AND OPERATING  COSTS  	   5-1

    VI        ADMINISTRATIVE REQUIREMENTS  	   6-1

   VII        REFERENCES	   7-1

APPENDIX A   SOURCE AND FUEL USE INVENTORIES  	   A-l

APPENDIX B   EMISSION  FACTORS  	   B-l



                                LIST OF FIGURES


Figure  No.                          Caption                             Page

   1-1        Boundaries of  the  Survey Area with Massachusetts  Plane
             Coordinate System  Overlay 	   1-4
   1-2        Flow Schematic of  Analysis Procedures  	   1-6
   3-1        Subdivision of Total Fuel Use by User  Categories  and
             Type of Use 	   3-2
                                      111
                                                              WALDEN RESEARCH CORPORATION

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                               LIST OF TABLES


Table No.                          Title                               Paje

  2-1       Particulate and S02 Emissions from Stationary Fuel Burn-
            ing Sources in the 30 Cities 	   2-3

  2-2       Fuel Consumption in 30 Cities 	   2-4
  2-3       Particulate and S02 Emissions from Stationary Fuel Burn-
            ing Sources in the 30 Cities when Natural Gas Particu-
            late Emissions are Assumed to be Zero  	   2-6
  2-4       1975 Particulate and S02 Emissions from Stationary Fuel
            Burning Sources in the 30 Cities	   2-8
  2-5       1972 Particulate and S02 Emissions from Transportation
            and Non-Fuel Burning Sources in the 30 Cities 	   2-9

  2-6       1973 Base Case Particulate and S02 Emissions from Non-
            Stationary and Non-Fuel Burning Sources in the  30
            Cities	   2-9
  2-7       Total Particulate and S02 Emissions from All Sources
            in the 30 Cities and Percent Reduction  (From 1973
            Base Case)  	   2-10
  2-8       Total Particulate and S02 Emissions from All Sources
            in the 30 Cities and Percent Reduction  (Percent of
            1973 Base Case) When Natural Gas Particulate Emissions
            are Assumed to be Zero  	   2-12
  2-9       Summary of  Capital and Annual Operating Costs of Each
            Control Strategy  	   2-14
  4-1       Procedures  for Control of Particulate  Emissions from
            the Stacks  of the Boston Edi son Company  	   4-5

  5-1       Summary of  Capital and Annual Operating Costs of Each
            Control Strategy  	   5-4
  5-2       Wholesale Fuel Oil Prices in the 30 Cities  (cents/
            gallon) 	   5-6
  5-3       Capital Cost of Electrostatic  Precipitation  Facility
            which will  Perform Fuel Washing  	    5-8
  5-4       Capital Cost of a Waste Treatment  Faci1ity	    5-8
  5-5       Operating  (Electricity) Cost for an  Electrostatic Pre-
            cipitation  Facility  which Performs  Fuel  Washing  	    5-9
  5-6       Capital Cost of Centrifugation  Facility which  will
            Perform Fuel Washing 	    5-9
  5-7       Steam Costs:   Block  Rate  A	    5-12
  5-8       Demand Rate Cost  of  Steam	    5-12
                                                             WALDEN RESEARCH CORPORATE

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                         LIST OF TABLES  (continued)


Table No.                          Title                                Page

  5-9       Retail  Fuel Oil Prices in the 30 Cities  	    5-13
  6-1       Annual  Manpower Requirements for Strategy A  (Conversion
            to Distillate Fuel Oil by All Sources with a  Heat  Input
            Less Than 10 MMBtu/hr) 	    6-2
  6-2       Annual  Budget Requirements for Strategy  A  (Conversion
            to Distillate Fuel Oil by All Sources with a  Heat  In-
            put Less Than 10 MMBtu/hr) 	    6-3
  6-3       Annual  Manpower Requirements for Strategy  B  (Annual
            Inspect!on and Peri odic Mai ntenance)  	    6-5
  6-4       Annual  Budget Requirements for Strategy  B  (Annual  In-
            spection and Periodic Maintenance)  	    6-6
  6-5       Annual  Manpower Requirements for Strategy  C  (Fuel
            Washing) 	    6-7
  6-6       Annual Budget  Requirements for Strategy  C  (Fuel
            Washing)	    6-8
  6-7       Annual Manpower Requirements for Strategy  E  (Sources
            with a Heat  Input of Less  Than 10  MMBtu/hr Switching
            from Oil to  Natural  Gas)  	    6-10
  6-8       Annual Budget  Requirements for Strategy  E  (Sources with
            a  Heat  Input of Less Than  10 MMBtu/hr Switching from Oil
            to Natural Gas)  	    6-11
  A-l       Estimated  1972 Consumption of  Natural  Gas  and Coal in
            the 30  Cities	    A-2
  A-2       Estimated  1972 Fuel  Oil  Consumption Inventory in the
            30 Cities  	    A-3
  A-3       Estimated  Number  of  Oil-Fired  Boilers in the 30 Cities
            in 1972  	    A-4
  A-4       Estimated  1973 Base  Case Consumption of  Natural Gas
            and Coal in  the  30 Cities  	    A-8
  A-5       Estimated  1973 Base  Case Fuel  Oil  Consumption Inventory
            in the  30  Cities  	    A-9
  A-6       Estimated  Number  of  Oil-Fired  Boilers in the 30 Cities
            in the  1973  Base  Case 	    A-10
  A-7       Population and Economic  Growth  Figures	    A-l3
  A-8       Estimated  1975 Consumption of  Natural  Gas  and Coal in
            the 30  Cities  	    A-l3
  A-9       1975 Fuel  Oil  Consumption  Inventory in 30  Cities  	    A-14
                                                             WALDEN RESEARCH CORPORATION

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                          LIST OF TABLES (continued)

Table No.                           Title                                Page

  B-l        EPA Emission Factors for Fuel  Oil Combustion  	    B-2
  B-2        Emission Factors for Natural Gas and Coal Combustion  ...    B-3
  B-3        Revised Emission Factors for Fuel Oil Combustion  	    B-4
  B-4        Emission Factors for Fuel 011  Combustion, Strategy B:
             Inspection and Maintenance 	    B-7
  B-5        Procedures for Control of Particulate Emissions from
             the Stacks of the Boston Edison Company  	    B-9
  B-6        Emission Factors for Fuel Oil  Combustion, Strategy C:
             Fuel Washing 	    B-10
                                      v1
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                             ACKNOWLEDGMENTS
     This work was supported under Contract No. 68-02-0049 by the Environ-
mental Protection Agency.  Portions of the information used in this program
were provided by the following organizations.  Their assistance and coopera-
tion are gratefully appreciated.

     Bureau of Air Quality Control, Commonwealth of Massachusetts; Region
I Staff, Environmental Protection Agency; Boston Air Pollution Control
Commission; Maryland Bureau of Air Quality Control; Frank  I. Rounds Co.;
Cleaver-Brooks; Combustion Service of New England; U.S. Carl in Company;
Atlantic Fuel Oil Co., Inc.; J. A. Marino Automatic Heating Company;
Packer Commercial Combustion Co.,  Inc.; Better Home Heat Council, Inc.;
Babcock and Mil cox Research Center; Combustion Engineering  Inc.; New
England Fuel  Institute;  Atlantic  Richfield Company; C. H.  Sprague & Son
Company; Buckley and Scott Company; Gibbs Oil  Company; Northeast Petroleum
Corp.; Quincy Oil Company; Union  Oil  Company;  White Fuel Corp.; General
Electric Company; Long Island  Power and Light  Company; DeLaval  Separator
Company; R. W. Beck & Associates;  Environmental  Protection Agency,  Re-
search Triangle  Park; Petrolite Corp.; Boston  Edison  Company;  Commonwealth
Gas  and  Electric  Company; Cambridge Steam Company;  Edison  Electric  Insti-
tute; Department  of Public Utilities, Commonwealth  of Massachusetts;
American Gas  Association Laboratories;  Illinois  Institute  of Gas Tech-
nology;  Bethlehem Steel  Corp.; Mystic Valley Gas; Algonquin Gas Trans-
mission  Company;  Boston  Gas Company;  Harvard University, School of  Public
Health;  Combustion  Engineering Associates;  National Oil  and Fuel  Insti-
tute; Esso  Research and  Engineering Company; Battelle Memorial  Institute;
Ralph Keys  Assoc.; and New  England Power Service Company.
                                                            WALDEN RESEARCH CORPORATION
                                     vn

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I.  INTRODUCTION

    A.  REGULATORY BACKGROUND

        The 1970 Amendments to the Clean Air Act specified that each of the
states must submit a plan to the Administrator of the Environmental Protec-
tion Agency by January 31, 1972 for the implementation, maintenance and en-
forcement of the national primary and secondary air quality standards.  The
objective of these plans was to establish a set of procedures to achieve
the designated primary air quality standards by 1975 and the secondary air
quality standards "within a reasonable time."  The Metropolitan Boston In-
trastate Air Quality Control Region was granted an eighteen month extension
for the development of a plan to attain secondary standards for total sus-
pended particulate matter and sulfur dioxide concentrations (Federal Regis-
ter, Vol. 37, No. 105, May 31, 1972 - 37CFR10846).  Simultaneously, EPA
approved an extension of the deadline for achieving these standards in the
Region until eighteen months after the 1975 compliance date for the attain-
ment of the primary standards.  However, a recent federal court interpreta-
tion of EPA's legal authority negated all such compliance extensions, neces-
sitating attainment of the mandated secondary standards by mid-1975.

    B.  STUDY OBJECTIVES

        Wai den Research  Corporation has been retained by the Environmental
Protection Agency to evaluate a number of emission control strategies spec-
ified by the EPA and the Commonwealth of Massachusetts Bureau of Air Quality
Control for fuel burning sources within 30 inner cities and towns of the
Metropolitan Boston Intrastate Air Quality Control Region.  This project
was designed to provide  information for the Bureau to assist them in the
development of a plan for attainment of the national secondary air quality
standards for particulates and sulfur dioxide.  Although the strategies are
aimed at compliance by 1975, the year 1973 was selected as the base year*
*
 By base year, we refer to the use of an adjusted 1973 source and fuel in-
 ventory as the basis for our estimates of emission reductions, technical
 feasibility, capital and operating costs, and administrative requirements
 for each of the strategies.
                                    _]                      WALDEN RESEARCH CORPORATION

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for analysis and evaluation since reliable growth factors were not readily
available (1) for projecting fuel combustion in the Boston area and (2) for
estimating contributions from other sources (solid waste incineration,
process losses, transportation) to the total participate and sulfur dioxide
emission burden in the area in 1975.

        The objective of the program,  as defined by EPA, was to determine
the emission reduction associated with each control strategy and to estab-
lish the technical feasibility, capital  and operating costs, and administra-
tive requirements associated with each of the selected approaches.  The
strategies included in the evaluation  were:

        (a)  Conversion to distillate  fuel  oil  by all sources
             with a heat input of less than 10 MMBtu/hr,*
        (b)  Annual inspection and periodic maintenance pro-
             gram for all  sources to assure optimum combustion
             conditions,
        (c)  Application of fuel  washing techniques to remove
             particulates  from fuel,
        (d)  Purchase of steam from a  local steam generating
             station for heat, and
        (e)  Sources with  a heat input of less than 10 MMBtu/hr
             switching from oil to natural  gas.

These control measures can be applied  singly or in various combinations.
The combinations which were examined  in addition to the basic strategies
were:

        (f)  Conversion to distillate  fuel  oil by all sources
             with a heat input of less than 10 MMBtu/hr coupled
             with an inspection and maintenance program on all
             sources in order to achieve optimum combustion
             conditions,
        (g)  Conversion to distillate  fuel  oil by all sources
             with a heat input of less than 10 MMBtu/hr coupled
             with application of a fuel washing process to re-
             move particulates from the fuel,
*
 MMBtu/hr is used throughout this report as an abbreviation for million
 Btu/hr.
                                    -2                      WALDEN RESEARCH CORPORATION

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        (h)   Sources with  a  heat  input of less  than 10 MMBtu/hr
             switching  from  oil to  natural  gas  coupled with an in-
             spection and  maintenance  program on all  sources in
             order  to achieve  optimum  combustion conditions,

        (i)   Sources with  a  heat  input of less  than 10 MMBtu/hr
             switching  from  oil to  natural  gas  coupled with a
             fuel-washing  process to remove particulates from
             the  fuel.


In addition,  we also examined  the strategy of:


        (j)   Sources with  a  heat  input of less  than 10 MMBtu/hr
             switching  from  oil to  electric heat.


        The  selected  study area is  shown in Figure 1-1 and contains the

bulk of the  stationary  fuel  burning sources in  the control region.  The

cities and towns  included in this region are:


               Arlington                        Needham
               Belmont                          Newton
               Boston                           Peabody
               Braintree                        Quincy
               Brookline                        Revere
               Cambridge                        Saugus
               Canton                           Somerville
               Chelsea                          Stoneham
               Dedham                           Wakefield
               Everett                          Waltham
               Lynn                             Watertown
               Maiden                           Weymouth
               Medford                          Winchester
               Mel rose                          Winthrop
               Milton                           Woburn


Thirteen of  these  cities  have been  designated  by  the  Bureau  of Air Quality

Control as areas of critical  concern  and constitute the  "core area."  These

municipalities are:

               Arlington                        Maiden
               Belmont                          Medford
               Boston                           Newton
               Brookline                        Somerville
               Cambridge                        Waltham
               Chelsea                          Watertown
               Everett
                                    1-3
                                                            WALDEN RESEARCH CORPORATION

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550   660   670    630    690  700    710   720   730    740     750   760   770   700
                                                                                      570
                                                                                      560
                                                                                     550
                                                                                     540
                                                                                     530
                                                                                     520
                                                                                     510
                                                                                     500
                                                                                     490
                                                                                     480
                                                                                     470
                                                                                     460
                                                                                     450
                                                                                   =- 440
                                                                                     430
                                                                                     420
                                                                                     410
                                                                                   -»400
        Figure  1-1.   Boundaries of the Survey Area  with Massachusetts
                      Plane Coordinate System Overlay.
                                     1-4
WALDEN RESEARCH CORPORATION

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The remaining seventeen cities have been designated as the "outer cities"
in this study.

    C.  METHODOLOGY

        Evaluation of the five basic strategies and the five combination
strategies included:

        (a)  Determination of the emission reduction that will
             occur by implementation of each strategy.
        (b)  Determination of the technical feasibility of each
             control strategy, including whether technical
             capabilities and fuel supplies presently exist for
             implementation.
        (c)  Determination of the capital and operating costs
             for implementation of each strategy.
        (d)  Determination of the administrative requirements of
             each  strategy, including additional resources that
             will  be necessary.

Figure  1-2 is  a flow schematic of our overall analysis procedure.  The
methodology  used to calculate emissions from stationary fuel-combustion
sources generally  conformed with  the survey techniques developed by  the
EPA  [1,2],   In its simplest form, the basic plan of  this  approach  consists
first of  inventorying  the consumption of  fuels  for generating power, for
space heating, and for industrial  process and other  needs.  The pollutant
emissions arising  from these  sources is then estimated by the application
of appropriate emission factors  in  conjunction  with  selected  fuel  composi-
tion parameters.

        The  emission  factors  used with  the fuel  use  inventory were developed
by analysis  of the most recent test results on  oil,  gas,  and  coal  combustion
in stationary sources.   The factors were  structured  to represent local
rather than  national  conditions  as  much as possible  and to  give maximum
differentiation to burners by size  and  fuel use.   The data  currently avail-
able, however, were inadequate to develop statistically reliable emission
factors for  different  burner  types  (e.g., rotary cup, pressure atomizing).

        The  basic  set  of emission factors was  supplemented  with data to
reflect the  effectiveness of  various control techniques in  the designated
                                                            WALDEN RESEARCH CORPORATION

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o
m
STRATEGY
REQUIREMENTS



	 p
w
EMISSION
FACTORS

TECHNICAL
FEASIBILITY
CRITERIA

COST
FACTORS

ADMINISTRATIVE
CRITERIA





SOURCE AND/OR
FUEL
INVENTORIES





EMISSIONS

TECHNICAL
FEASIBILITY

COSTS

MANPOWER
REQUIREMENTS
8
TO
70
Figure 1-2.  Flow Schematic of Analysis Procedures.

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strategies.   The emission factors were then applied to the relevant fuel
consumption  inventory to yield estimated emissions for stationary fuel
burning sources for each of the selected strategies.

        The  economic impact of each strategy was determined by assessing
the capital  and annual operating costs associated with implementation.  The
cost figures were obtained by determination of the most significant param-
eters associated with each strategy and by applying differential and/or
absolute costs to the corresponding source and fuel inventories.  Cost
figures are based on 1973 data, and do not reflect changes which will re-
sult from shifts in future supply and demand including those shifts which
will be a direct consequence of implementation of the strategies evaluated
in this report.

        The technical feasibility of each control strategy was assessed
through an evaluation of two general criteria:  were there any technical
or engineering  obstacles that  could delay implementation  of the control
plan,  and were  there  sufficient  fuel supplies to  cope with the increased
demands associated with the  fuel  switching  strategies.  Our procedure with
the  first criteria involved  a  detailed  analysis and  interpretation of the
engineering  requirements for each  strategy.   Evaluation of fuel supplies
was  conducted by a review of local  and  national fuel availability reflect-
ing  current  and projected import oil and  gas  quotas.

        Administrative  requirements were  established by an assessment of
the  manpower requirements associated with  the enforcement of  each of the
control strategies.  These requirements were  translated further into
needed funding resources.
                                    1_7                     WALDEN RESEARCH CORPORATION

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II.  SUMMARY


     Ten strategies for the control of participate and sulfur dioxide emis-

sions from stationary combustion sources in the 30 inner cities and towns

of the Metropolitan Boston Air Quality Control Region have been evaluated

with respect to emission reduction, technical feasibility, capital and

operating costs, and administrative requirements.  These strategies are:


     A.  Conversion to distillate fuel oil by all sources with a
         heat input of less than 10 MMBtu/hr.
     B.  Annual inspection and periodic maintenance program for
         all sources to assure optimum combustion conditions.

     C.  Application of fuel washing techniques to remove particu-
         lates from fuel.

     D.  Purchase of steam from a  local steam generating station
         for heat.

     E.  Sources with  a heat input of less than 10 MMBtu/hr
         switching from oil to natural gas.

     F.  Conversion to distillate  fuel oil by all sources with a
         heat  input of less than 10 MMBtu/hr  coupled with an  in-
         spection  and  maintenance  program on  all  sources in order
         to achieve optimum combustion conditions.

     G.  Conversion to distillate  fuel oil by all sources with a
         heat  input of less than 10 MMBtu/hr  coupled with a fuel
         washing process  to remove particulates  from the fuel.

     H.  Sources with  a heat input of less than  10 MMBtu/hr
         switching from oil to natural gas coupled with an in-
         spection  and  maintenance  program on  all  sources in order
         to achieve optimum combustion conditions.

      I.  Sources with  a heat input of less than  10 MMBtu/hr
         switching from oil to natural gas coupled with a fuel
         washing process  to remove particulates  from the fuel.

     J.  Sources with  a heat input of less than  10 MMBtu/hr
         switching from oil to electric heat.


     Strategies A, E,  F,  G, H, and I  share common requirements for  changes

 in the fuel burning patterns in the Metropolitan  Boston area  and  for  con-

 version or  replacement of existing burners or burner components.  Strate-

 gies B, F,  and H require  the practice of  higher  levels of service and

 cleaning on the existing  burner and boiler population.  Strategies  C, G,

 and I  relate to a  technique known  as  fuel washing developed by the  General
                                                            WALDEN RESEARCH CORPORATION

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Electric Company in Lynn, Massachusetts, to remove soluble corrosive salts
from residual  fuels preparatory to their use in gas turbines.  This process
has also t:en  found effective in controlling particulate emissions from the
combustion of  residual  fuels by removing the majority of the sediment ash
related constituent of the particul ate effluent.  Strategy D, purchase of
steam for space heating, also requires a change in the fuel burning pattern
in the core area.  Its successful  implementation is dependent on the con-
struction of additional generating facilities and distribution networks to
deliver the required steam.  Strategy J, conversion to electric heat, also
requires a change in the fuel burning pattern, but was not evaluated quan-
titatively since preliminary calculations indicated that a net increase in
emissions would result from its implementation.  This is a consequence of
the greater amount of fuel that would be required for utility-supplied
electric heating than for on-site fuel burning, and because residual oil,
with a higher  emission factor, would replace the use of cleaner burning
distillate oil in many cases.

     A.  EMISSION REDUCTIONS

         Determination of the emissions that would occur by implementation
of each strategy was accomplished by application of the appropriate set of
emission factors to the corresponding elements of the fuel use inventory.
Details of the development and results from the source and fuel use in-
ventory are presented  in Appendix A; the emission factors  used and their
basis  are presented in Appendix B.

         1.   Emissions from  Fuel  Burning Sources

              Table  2-1  summarizes the predicted emissions  for the 1973  pre-
strategy base case  and for each emission control  strategy.   The  1973 base
case  represents  an  adjustment of  the  1972  fuel  consumption inventory by
accounting  for programmed changes in  fuel  utilization due  to existing air
pollution  control  regulations.  This  adjustment does not  reflect  any
  Table 2-2 summarizes the fuel  consumption in the area for 1972 and for the
  1973 pre- and post-strategy cases.
                                    2-2
                                                            WALDEN RESEARCH CORPORATK

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                  TABLE  2-1

PARTICULATE AND S02  EMISSIONS  FROM STATIONARY
    FUEL BURNING SOURCES IN  THE 30 CITIES
Strategy
1972*
1972
1973 Base Case
1973 Strategy A
1973 Strategy B
1973 Strategy C
1973 Strategy D
1973 Strategy E
1973 Strategy F
1973 Strategy G
1973 Strategy H
1973 Strategy I
Parti culates (tons/yr)
13 Core 17 Outer Total
11,053
5,361
4,893
4,417
3,736
4,135
4,883
3,843
3,260
3,778
2,686
3,204
The EPA (AP-42) emission
with the emission factors
4,016
1,955
1 ,872
1,262
1,620
1,621
1,872
1,002
1,010
1,120
750
15,069
7,316
6,765
5,679
5,356
5,756
6,755
4,845
4,270
4,898
3,436
860 4,064
factors were used
from the present
so2
13 Core
52,195
51,950
47,707
44,056
47,707
47,707
47,658
31 ,839
44,056
44,056
31 ,839
31 ,839
in this case
study.
(tons/yr)
17 Outer Total
30,729
30,887
29,223
19,793
29,223
29,223
29,223
14,272
19,793
19,793
14,272
82,924
82,837
76,930
63,849
76,930
76,930
75,881
46,111
63,849
63,849
46,111
14,272 46,111
for comparison
                      2-3
                                               WALDEN RESEARCH CORPORATION

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a
m
2
o
I
o
o
                                                       TABU 2-2



                                             FUEL  CONSUMPTION IN  30 CITIES

Source
Category
Residential
0-6 MMBtu
6-10 MMBtu
10-30 MMBtu
X 30-250 MMBtu
>250 MMBtu
(non-utility)
All Utility
TOTALS

1972
Number of
Oil Fired
Boilers
465,737
5,696
2,321
146
83
15

50
474 ,050
1972
Fuel Oil
Consumption
Distillate Residual
(1000 gal) (1000 gal)
698,608
66,617
27,248
1,219
3,205



796,897

228,437
231,588
39,356
94,191
117,943

743,482
1,453,997
1973
Base Case
Distillate
Changes
(1000 gal)

+167,545






+167,545
1973
Strategy A
Distillate
Changes
(1000 gal)

+60,892
+231 ,588





+292,480
1973
Strategy D
Residual
Changes
(1000 gal)


-8,707




+ 706
-1,646
1973
Strategy E
Gas
Changes
(million ft3)
+93,124
+39,371
+34,503





+166,998
      % Change from

      1972 Fuel

      Consumption
+21%
+37%
       Total  1972 gas  consumption  was  57,920 million  ft3
+288%

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potential change in the total  amount of fuel  consumed in the area in 1973
due to growth, population shifts, and climatological  factors.  It is based
strictly on those changes which are scheduled to occur during calendar
1973, and which we have elected to apply on an annual basis.  These changes
are:

             (1)  Conversion of the three principal  coal users
                  (Boston Public School System) to distillate
                  oil.
             (2)  Conversion of the 3-6 MMBtu/hr size residual
                  oil burners in the 13 core cities to distil-
                  late oil.
             (3)  Closure of the Massachusetts Electric Power
                  Plant in Lynn.

             Table 2-1 also includes emissions predictions for 1972 using
both our revised set of emission factors and the so-called  "AP-42 Factors"
[3].  These latter factors were used by Waiden in a previous emission in-
ventory study for Metropolitan Boston  [4] and reflect a national rather
than local mixture of burner-boiler types.   It is highly significant that
the emission predictions using our revised factors indicate  that the con-
tribution of particulates  from stationary fuel burning  sources to the
local paniculate emission  inventory is less than half  of that predicted
by the AP-42 factors.  Any  effort to determine the effect on ambient air
quality  levels from control of stationary fuel burning  sources on air
quality  leads should recognize this factor and make  use of  the revised
fuel use inventory presented in  this study.

             As discussed  in Appendix  B, we  suspect  that even our revised
particulate emission factor for  natural gas  is conservatively high.  There-
fore, in order to bracket  the range, we have  included another table of
emissions  in which we assume that particulate emissions from combustion
of  natural gas are zero; this result is presented in Table  2-3.

             As previously discussed,  it is  desirable to consider the emis-
sion reductions that a strategy  will achieve  by  mid-1975 since that is the
current  deadline  for meeting secondary standards.  Emission factors were
applied  to a  projected 1975 inventory  of fuel  burning sources, described
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                                TABLE 2-3

        PARTICIPATE AND S02 EMISSIONS FROM STATIONARY FUEL BURNING
          SOURCES IN THE 30 CITIES WHEN NATURAL GAS PARTICULATE
                     EMISSIONS ARE ASSUMED TO BE ZERO
   Strategy
 Particulates (tons/yr)
13 Core  17 Outer  Total
      S02 (tons/yr)
13 Core  17 Outer  Total
1972
 5,189    1,895    7,084     51,950    30,887   82,837
1973 Base Case
 4,721    1,812    6,533     47,707    29,223   76,930
1973 Strategy E     3,211       734     3,945      31,839    14,272   46,111


1973 Strategy H     2,054       482     2,536      31,839    14,272   46,111


1973 Strategy I     2,572       592     3,164      31,839    14,272   46,111
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In Appendix A, in order to develop a 1975 emissions inventory.   These re-
sults are presented in Table 2-4.   Note again that we did not extend our
analysis to total 1975 emissions in the region since we did not have an
adequate basis for estimation of 1975 emissions from non-stationary fuel
burning sources.

         2.  Emissions from Other Sources

             In order to evaluate the effectiveness of each strategy in
reducing total particulate and S02 emissions, it is necessary to consider
the contributions from mobile and/or non-fuel burning sources.  For the
purposes of this study, the information and emissions developed previously
for the 30 cities for the year 1970 [4], were used under the assumption
that these "other" emissions would not change significantly by 1972.
Three major sources are contained in this "other" category -- process
losses, transportation source emissions, and solid waste incinerator
emissions.  A tabulation of the emission contributions from these sources
in 1972 is contained  in Table 2-5.

             Regulation 2.5.3 of the Commonwealth's Air Pollution Control
regulations will require all solid waste incinerating  facilities to meet
specific particulate  emission limitations by 1975.  For the purpose of
this analysis, we have included the changes brought about by these regu-
lations in the 1973 emission estimates.  The final 1973 base case emis-
sions from all "other" sources  is shown in Table 2-6.

         3.  Total  Emissions and Percent Reduction from All Sources  (1973)

              Particulate and S02 emissions from  "other" sources  (which are
described above) were added in  each case to emissions  from the stationary
fuel burning sources  to obtain  a total emissions estimate.  These results
are given in Table 2-7 and show that the maximum reductions of the total
particulate and  S02 burden in the area occurs with Strategy H  (conversion
to gas, coupled  with  inspection and maintenance),  producing a decrease of
27% and 372, respectively.  Again, we  include a tabulation of total emis-
sions when the natural gas particulate emissions are assumed to  be zero;
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                                TABLE 2-4

            1975 PARTICIPATE AND S02 EMISSIONS FROM STATIONARY
                  FUEL BURNING SOURCES IN THE 30 CITIES
   Strategy
 Particulates (tons/yr)
13 Core  17 Outer  Total
      S02 (tons/yr}
13 Core  17 Outer Total
1975
 5,118    1,984    7,102     49,826    31,001    80,827
1975 Strategy A     4,604    1,325    5,929     45,883    20,817   66,700


1975 Strategy B     3,906    1,718    5,624     49,826    31,001   80,827


1975 Strategy C     4,319    1,716    6,035     49,826    31,001   80,827


1975 Strategy D     5,106    1,984    7,094     49,763    31,001   80,764


1975 Strategy E     4,021    1,056    5,077     33,361    15,077   48,438


1975 Strategy F     3,392    1,059    4,448     45,883    20,817   66,700


1975 Strategy G     3,933    1,175    5,108     45,883    20,817   66,700


1975 Strategy H     2,810      791    3,610     33,361    15,077   48,438


1975 Strategy I     3,351      906    4,257     33,361    15,077   48,438
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                      TABLE 2-5

1972 PARTICULATE AND SOg EMISSIONS FROM TRANSPORTATION
    AND NON-FUEL BURNING SOURCES IN THE 30 CITIES
Emission Source
Process Losses
Solid Waste Incineration
Transportation
TOTAL
Participates
(tons/yr)
302
5,294
4.357
9 ,953
S02
(tons/yr)
1,604
637
4,865
7,106
                       TABLE 2-6

   1973 BASE CASE PARTICULATE AND S02 EMISSIONS FROM
          NON-STATIONARY AND NON-FUEL BURNING
                SOURCES IN THE 30 CITIES
Emission Source
Process Losses
Solid Waste Incineration
Transportation
TOTAL
Parti culates
(tons/yr)
302
810
4.357
5,469
S02
(tons/yr)
1,604
637
4.865
7,106
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                                TABLE 2-7

           TOTAL PARTICULATE AND S02 EMISSIONS FROM ALL SOURCES
                  IN THE 30 CITIES AND PERCENT REDUCTION
                           (FROM 1973 BASE CASE)
Strategy
1972* Emissions
1972 Emissions
1973 Base Case
1973 Strategy A
1973 Strategy B
1973 Strategy C
1973 Strategy D
1973 Strategy E
1973 Strategy F
1973 Strategy G
1973 Strategy H
1973 Strategy I
Parti culates (tons/yr)
-.-i Percent
lotal Reduction**
25,022
17,269
12,234
11,148
10,825
11,225
12,224
10,314
9,739
10,367
8,905
9,533
- 105%
- 41%

9%
12%
8%
'v 0
16%
20%
15%
27%
22%
S02 (tons/yr)
T-+.I Percent
lotal Reduction**
90,030
89,943
84,036
70,955
84,036
84,036
83,987
53,217
70,955
70,955
53,217
53,217
- 7%
- 7%

16%
'x/ 0
^ 0
'u 0
37%
16%
16%
37%
37%
  The EPA  (AP-42) emission  factors were used in this case for comparison
  with the emission  factors from the present study.
**
  A negative value  indicates an  increase.
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these figures constitute Table 2-8 and indicate an additional  differential
emission reduction potential of 6% associated with the uncertainty in the
emission factor.

     B.  TECHNICAL FEASIBILITY

         Our analysis of the technical feasibility associated with imple-
mentation of each of the designated control strategies fell into two gen-
eral categories:

         (1)  Were there any technical, i.e., engineering,
              obstacles that could delay application of each
              strategy,
         (2)  Were there sufficient supplies of distillate
              oil, natural gas, or steam available to accom-
              modate the proposed strategies.

In general, it is our judgment that there are no engineering reasons why
any of the strategies could not be implemented to control particulate and
SOp emissions from stationary fuel burning sources.  However, our assess-
ment of Strategies A, F, and G  (which include conversion to distillate oil
by all sources less  than 10 MMBtu/hr) indicates a requirement for approxi-
mately 37%* more  distillate oil for their  implementation than the estimated
1972 consumption  in  the 30  cities and towns.  This is in addition to the
21%* increased demand due to  programmed changes such as the switching of
units  3-6 MMBtu/hr in the 13  core cities and towns from residual to distil-
late in July  1973.   Similarly,  our analysis of Strategies  E,  I, and J
(which include increased use  of natural gas  in sources less than 10 MMBtu/
hr) indicates a  requirement for approximately 288%* more natural gas than
the estimated consumed  in 1972  in the 30 cities and towns.  Given .the ex-
isting uncertainty in the national oil import policy, our  nationwide short-
age in petroleum refining capacity, and the widening national gap between
natural gas supply and  demand,  there  is little likelihood  that either fuel
could  be supplied to the area by  1975 in sufficient quantity  to satisfy the
*See Table 2-2.
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                     TABLE 2-8

TOTAL PARTICULATE AND S02 EMISSIONS FROM ALL SOURCES
  IN THE 30 CITIES AND PERCENT REDUCTION (PERCENT
        OF 1973 BASE CASE) WHEN NATURAL GAS
             PARTICULATE EMISSIONS ARE
                 ASSUMED TO BE ZERO
Parti dilates (tons/yr)
Strategy
1972 Emissions
1973 Base Case
1973 Strategy E
1973 Strategy H
1973 Strategy I
A negative value
Total
17,037
12,002
9,414
7,981
8,612
indicates an
Percent
Reduction*
- 42%

22%
33%
28%
increase.
so2
Total
89,943
84,036
53,217
53,217
53,217
{tons/yr )
Percent
Reducti on*
- 7%

37%
37%
37%
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requirements of the foregoing control strategies.  From this perspective,
Strategies A, F, G, E, I, and J are not feasible.*

     C.  ECONOMIC IMPACT OF CONTROL STRATEGIES

         The estimated capital and operating costs of each strategy are
summarized in Table 2-9.  In most cases, a set of high and low values are
provided to bracket uncertainties in the cost factors.  Sources of the un-
certainty in the cost factors are described below.

         Strategy A.  Conversion to distillate fuel oil by all sources
with a heat input of less than 10 MMBtu/hr.

         The low estimate of both capital and operating costs were obtained
by assuming 90% burner conversion and 10% replacement of units which cannot
be made to burn efficiently through minor adjustments — from a combustion
point of view, the units must be replaced.  The high estimates were obtained
by assuming 100% replacement of burners.

         Note that the costs given for this strategy do not reflect the in-
crease in the price of distillate oil which would certainly result from its
implementation.

         Strategy C.  Application of Fuel washing techniques to remove par-
ti culates from fuel.

         The higher of the two price estimates for this strategy in both
the capital cost and the operating cost change categories corresponds with
the use of the electrostatic precipitator method of fuel washing.  The
other method considered, and the one to which the lower cost figures apply,
is the use of centrifugation in the process.  Note that there is a signifi-
cant potential fuel saving in the operating cost which is associated with
a reduction in fuel consumption of up to 5% as a result of increased fuel
combustion efficiency.  We have not combined the operating cost change fig-
ures because of the uncertainty involved with the exact amount of the fuel
*
 The impact of the President's energy policy announcement of April 18, 1973
 has not been considered in reaching this conclusion.
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                  TABLE 2-9

SUMMARY OF CAPITAL AND ANNUAL OPERATING COSTS
           OF EACH CONTROL STRATEGY
Strategy
A
B
C
D
E
F
G
H
I
*
Due to Increased
**
A positive value
Capital Cost
(millions of dollars)
Low estimate 10.4
High estimate 23.6
0
Low estimate 6.5
High estimate 7.3
Potential saving*
Low estimate 0.01
High estimate 0.05
Low estimate 270
High estimate 450
Low estimate 10.4
High estimate 23.6
Low estimate 16.9
High estimate 30.9
Potential saving*
Low estimate 270
High estimate 450
Low estimate 277
High estimate 457
Potential saving*
combustion efficiency.
indicates an increase.
Annual Operating
Cost Change
(millions of
dollars per year)**
-3.9
+1.2
+0.6
+1.5
+1.8
-7.8
+0.36
+0.44
+9
-3.3
+1.8
-2.4
+3.0
-7.8
+9.6
+10.5
+10.8
- 7.8
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savings, but the net result is surely a net decrease or saving in annual
operating costs.

         Strategy D.  Purchase of steam from a local steam generating sta-
tion for heat.

         About 224,000 Ib/hr of steam at peak loading is available in the
13 core cities* (actually, this is a reserve capacity that would not nor-
mally be sold).  Because of the nature** of the emission factors and be-
cause of the fact that utilities primarily burn #6 oil, we have assumed
that all conversions will be sources using #6 oil in the size range 6 to
30 MMBtu/hr in the 13 core cities region.  The low estimate of the capi-
tal cost was obtained by assuming that users of approximately 30 MMBtu/hr
size would switch to steam (five users).  The high estimate of capital cost
reflects switching of 6 MMBtu/hr size (24 users).  The low estimate of the
increase in operating cost was obtained for the case of 6 MMBtu/hr size
units switching while the high operating cost increase estimate corresponds
to switching by the 30 MMBtu/hr size units.

         Strategy E.  Sources with a heat input of less than 10 MMBtu/hr
switching from oil to natural gas.

         The low estimate of capital cost was obtained by assuming 90%
conversion of oil burners and 10% replacement.  The high estimate was
calculated by assuming 100% replacement of burners.

         Strategies F. G. H, and I.  Combination strategies.

         The high and low estimates of capital and operating costs for
each of these strategies is equal to the sum of the respective high and
low cost estimates for each of the component strategies.
 *
  Currently, Cambridge and Boston are the only cities in the region with
  steam distribution networks.
**
  e.g., distillate and #4 oil factors are less than utility factors.
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     D.  ADMINISTRATIVE REQUIREMENTS

         Administratively, we conclude that there is a common requirement
for the successful  implementation of each of the strategies, i.e., completion
of the current source registration program, particularly for units in the
3 to 10 MMBtu/hr size range.   This information will  provide the Bureau of
Air Quality Control  with essential  data on source location and on their
emission characteristics, and forms the basis for surveillance and enforce-
ment of each of the  control  strategies.  The registration should be com-
pleted as soon as  possible to build the initial data base and should be
updated at least on  an annual  basis.   On an individual basis, Strategy B
(inspection and maintenance)  necessitates a substantial  inspection program
by the Bureau to assure that  the  required maintenance program is conducted
by each fuel burning source.

         We note that registration and inspection programs are currently a
part of the Bureau's operation.   Due to the strong interactions of these
strategies with current agency programs, we have therefore only re-esti-
mated total administrative requirements under the assumption of a compre-
hensive enforcement  plan.

     E.  CONCLUSIONS

         Those strategies associated with alteration of the fuel burning
pattern in the Metropolitan Boston area offer the greatest potential for
reducing the particulate and  sulfur dioxide emission burden due to sta-
tionary fuel burning sources  in the region.  However, the maximum reduc-
tion in total particulate and sulfur dioxide emissions in the 30 selected
cities and towns of the region are only 27% and 37%, respectively.  Those
strategies which are not fuel dependent, i.e., Strategy B (inspection and
maintenance) and C (fuel washing) will only reduce the region's total par-
ticulate burden by 12 and 8 percent, respectively, and are totally ineffec-
tive in controlling S02 emissions.

         Comparison of the predicted emissions for fuel  burning sources in
the 30 cities and towns using the EPA "AP-42" and our revised sets of emis-
sion factors indicates  (see Table 2-7) that the contribution of this source
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category to the total participate emissions in the area is significantly
less than originally predicted in Reference 4.*  Hence, the potential  re-
duction in air quality levels that can be achieved by further control  of
these sources is considerably less than one might infer from our earlier
inventory report (i.e., Reference 4).

         Those strategies associated with major changes in the fuel  use
patterns in the area, i.e., strategies associated with additional  use  of
distillate oil or natural gas, appear to possess major obstacles to  imple-
mentation projections of inadequate supplies of distillate oil and natural
gas in the Metropolitan Boston area through at least 1975.  Current  pro-
jections indicates an increasing inability on the part of local oil  and
gas suppliers to cope with existing demands for these fuels both at  the
present time, and in mid-1975 when secondary standards are to be achieved.
Reserve steam availability is also quite low and is projected to remain so
indefinitely unless and until a specific demand is placed on the existing
distribution systems.  A minimum of three years will be required from the
time steam customers are signed to a contract until the necessary supply
capacity could be developed.  Fuel supply  (distillate, gas, and steam) is
thus the principal obstacle associated with implementation of each of the
strategies.  There are no engineering obstacles that we could determine
to the implementation of each of the strategies.

         We also note that there is uncertainty over the potential effec-
tiveness of a burner adjustment program  (as opposed to outright burner
replacement).  Many of the burner installers in the Metropolitan Boston
area insist that an oil burner originally designed to operate on residual
fuel will operate with poorer performance  (i.e., high maintenance require-
ments, poor combustion performance) and higher emissions after conversion
to distillate oil.  This is claimed to be especially true of the older
rotary cup burners prevalent in Greater Boston.  The installers therefore
 The emission predictions included in Reference 4 were for a different
 year and a different fuel use pattern (e.g., high sulfur oils) than is
 the current practice in Metropolitan Boston.  The implication here is
 that the former predictions, though valid for the prior design year,
 cannot be applied today.
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maintain that the burners should not be adjusted, but should instead be
replaced with more efficient pressure atomizing units.  There is even a
consensus of opinion on their part that replacement of old rotary units by
new pressure atomizing burners operating on residual oil would result in
almost as great a reduction in particulate emission as would exist if the
new units were also required to operate on distillate oil.  A strategy as-
sociated with a ban on rotary burners and their replacement with residual
fired pressure atomizing burners would likely significantly relieve the
distillate oil supply problem discussed above.   Unfortunately, we were not
able to resolve these uncertainties in order to quantitatively evaluate
such a strategy.

         With respect to economic impact, Strategies B and C are the most
attractive.  Strategy B, which involves a cleaning and maintenance program,
is attractive because there is no associated capital outlay and because its
implementation would yield an increase in burner efficiency which can be
directly translated to a lower fuel requirement for a given facility.
Strategy C, involving fuel washing, offers a potential long-range saving
since there also appears to be an increased combustion efficiency associ-
ated with washed fuel.  Strategy A, conversion to distillate, and strat-
egies coupled with it, involve very significant capital costs due to burner
conversion or replacement.  Strategy E, conversion to gas, and strategies
coupled to it, although offering significant emission reductions, have even
larger capital costs  (associated with burner conversion and replacement)
due to the large number of sources that would have to be  converted.  Strat-
egy D, conversion to  steam heat, does not appear economically attractive
because of its small  impact on emissions.  Thus, considering the only  cost
and the availability  of the required fuel supplies,  Strategies  B and C,
which are totally ineffective  in controlling SO,, emissions, and relatively
ineffective  in  controlling particulates, are the only two strategies that
could be readily  implemented  to  aid  in  the attainment of  secondary  air
quality  standards  in  the  Metropolitan  Boston region.

         Administratively, we have determined that  completion of the
Bureau's source registration  program,  particularly  for  units  in the 3  to
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10 MMBtu/hr size range, will  be required for the successful  implementation
of each of these strategies.   This requirement does not represent an addi-
tion to the Bureau's already budgeted plans for financial  and manpower
resources.

     F.  RECOMMENDATIONS

         Our assessment of the feasibility of those strategies discussed
above that are dependent on alteration of the fuel burning pattern in the
Metropolitan Boston area indicated that there was an inadequate supply of
distillate fuel oil and natural gas available to implement said strategies
by the 1975 compliance deadline.  However, these same strategies generally
are potentially the most effective of the evaluated strategies for con-
trolling particulate and sulfur dioxide emissions from stationary fuel
burning sources.  We therefore recommend that a re-examination of the im-
plementation of these strategies at a different target date be undertaken
based on an examination of local fuel interconvertability and on projected
availability of alternative fuel supplies to the Boston area.  It is our
considered opinion that, given a different time frame than that associated
with a 1975 compliance deadline, several of the strategies associated with
increased use of "cleaner fuels" might become the most feasible approaches
to controlling stationary source particulate and sulfur dioxide emissions.
Such a study was beyond the scope of our analysis but is certainly within
the scope of the problem of controlling stationary source emissions.

         Our study, and all similar analyses of emissions due to station-
ary source fuel combustion, are strongly limited by the field data avail-
able for development of a reliable set of source emission factors.   Con-
siderable emphasis in this study was given towards developing an appropri-
ate set of emission factors for use with our source and fuel  use inven-
tories.  Those factors that were developed are  based on the most current
data available on  fossil fuel  combustion in stationary sources.   In  many
cases, however, our data base  was severely limited and the factors do not
have a statistically sound basis.  Consequently, we strongly  recommend
that additional testing of burners/boilers be conducted both  to validate
the finesse of our factors and to refine said factors to reflect
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parameters such as burner age,  type, and geographic population.  Such a
finesse will, for example, be particularly useful  in performing a quanti-
tative assessment of the position adopted by burner installers in the
Metropolitan Boston area that installation of new residual oil fired
pressure atomizing burners will  be almost as effective a means of reducing
particulate emissions as if said new units were also required to operate
on distillate oil.
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III.  EMISSIONS AND EMISSIONS REDUCTION

      All  pollutant emissions can be broadly categorized as those from
stationary sources and those from non-stationary (transportation) sources.
The latter category includes all  modes of combustion-powered transporta-
tion including automobiles, buses, trucks, trains, vessels, and aircraft.
The stationary sources include fuel combustion, solid waste disposal, and
process losses; fuel combustion sources may be further classified into
different user categories and type of use as illustrated in Figure 3-1.
The major categories of source types shown in this chart include domestic
(residential), commercial, institutions, manufacturing, and steam-electric
utilities.  Most of these can be further classified as  point sources which
represent individual establishments emitting relatively large quantities
of contaminants, as distinguished from area sources which represent, col-
lectively, a large number of smaller sources distributed over the survey
district.  The basic structure for classifying fuel consumption shown in
Figure 3-1 was used in the current inventory.  Aside from its general util-
ity, this system allows for a subsequent comparison of the survey results
with those completed in a similar manner for other control regions.

      The methodology used to calculate emissions from combustion sources
generally conformed with the survey techniques developed by the  Environ-
mental Protection Agency [1, 2].   In its simplest form, the basic plan
of  this approach consists of first determining the consumption of fuels
for generating power, space heating, and other industrial process needs.
The emission of pollutants arising from these sources  is then estimated
by  the application of appropriate  emission factors in  conjunction with
selected  fuel  composition parameters.  The key elements required for
calculation of the  emissions from  combustion sources are,  therefore, a
source and fuel use inventory and  a corresponding set  of emission factors.

      A.  SOURCE AND  FUEL  INVENTORY

          For  the  purpose of this  study, we confined our inventory analysis
to  stationary  fuel  combustion sources  in  the 30  inner  cities and towns  in
the Metropolitan  Boston  Air Quality Control Region.  The basis for the  in-
ventory  is a  set  of survey forms  submitted to  the Commonwealth during 1970
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                        ANNUAL
                       STUDY AREA
                       USE Of EACH
Figure 3-1.   Subdivision of Total  Fuel Use by  User
              Categories and Type  of Use.
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and 1971 for source inventory and in 1972 for registration purposes.
These forms represent the most comprehensive survey conducted to date and
constitute a size stratified sampling of the total  number of emission
sources in the district.*  Specifically, the inventory is most complete
for sources greater than 10 MMBtu/hr and becomes  less comprehensive with
decreasing boiler size.

          Our approach to completing the inventory in order to evaluate
the control strategies made use of 1971 Bureau of Mines statewide totals
of fuel oil consumption by grade and application.  These data were then
refined using census data to yield estimates for consumption of the various
grades of oil in the 30 cities and towns.  Census data was also used to
calculate consumption in the 13 core and 17 outer municipalities.  A more
thorough description of this procedure is included in Appendix A.  Natural
gas consumption for the region was obtained directly from the gas companies
serving the area.

          The preceding treatment enabled us to compile a complete fuel
burning source inventory in the 30 cities and towns for calendar year
1971.  Clearly, changes in fuel consumption have occurred during the
intervening months due to fluctuations  in both population and climate
(e.g., 1972 was a milder year than 1971  requiring  less fuel for space
heating applications).  These two factors were found  to  have changed such
that  the  effect of one on fuel consumption  cancelled  the  effect of the
other.  Hence, we have determined that the  1971  inventory is represen-
tative of 1972 fuel consumption  in the area.  Projected  population growth
in the 13 core and 17 outer cities and towns was used to  estimate  growth
of the domestic fuel  inventory from  the end of 1972  to  the  Commonwealth's
mid-1975  target date  for achievement of the secondary air quality  standards.
An assumed growth rate of  3%  per annum was  used  to project point  source
growth in the commercial and  industrial  categories;  an average  growth
  Our source inventory  was  categorized  by fuel  type,  unit  size,  and  source
  location within either the  13  core cities  and towns (area  of critical con-
  cern) or within the 17 outer cities and towns of the region covered  by  this
  study.
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factor representative of the distribution of electric power to its customers
(i.e., domestic, commercial and industrial sources) was used with the
utility inventory.*

      B.  EMISSION FACTORS

          Computation of the pollutant emissions arising from the combus-
tion of fuel for each of the control  strategies was performed by applica-
tion of appropriate emission factors  to a corresponding source inventory.
The most widely-accepted set of factors are those assembled and published
by the Environmental Protection Agency in Reference 3.  These factors
(referred to as AP-42 factors) are the ones which were used by Walden in
developing the emission inventory study for the Metropolitan Boston Air
Quality Control District [4] and reflect a national rather than local
mixture of burner-boiler types.

          A close examination of the  above factors for fuel oil combustion
revealed several significant areas for their improvement, especially with
regard to particulate emissions.  For example:

          (1)  The factors are grouped according to application rather
               than unit size, burner type, or other more fundamental
               design characteristics.
          (2)  The factors do not take into account the various grades
               of residual fuel oil (i.e., #4, #5, #6).
          (3)  The factors were developed  for high sulfur fuels having
               significantly different particulate emission character-
               istics than the low sulfur fuels now in use.
          (4)  The relationship of the measurements used to develop the
               particulate emission factors to hypothetical measurements
               taken under identical  conditions on identical units with
               a newer EPA sampling system is unclear.
          (5)  The factors have occasionally been based on limited data
               that are now subject to questions of accuracy and/or of
               being representative.
  Economic  growth factors  used  in  this analysis were provided by the
  Harvard University School  of  Public Health and are based on an un-
  published study of the economic  growth  in the Commonwealth.
                                                          WALDEN RESEARCH CORPOB

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For these reasons, we have conducted a thorough analysis of the most cur-
rent emission data available on fuel oil  combustion and prepared a revised
set of emission factors for use with our source inventory.   Sources of
this data include but are not limited to:  The Environmental  Protection
Agency, the Commonwealth of Massachusetts Bureau of Air Quality Control,
the American Petroleum Institute, the National Oil  and Fuel Institute,
Battelle Memorial Institute, various manufacturers, vendors,;arid users
of the appropriate combustion equipment, public utilities,  fuel oil
companies and local suppliers, and appropriate state and federal agency
personnel concerned with inspection and regulation of fossil  fuel utili-
zation facilities.  These new factors were structured to assure maximum
differentiation according to unit size and type and to reflect local
rather than national operating conditions.  The new factors are pre-
sented in Appendix B together with a more comprehensive discussion of
their development.

          The base-line emissions and the emission reduction associated
with each of the designated control strategies is detailed in Section
II-A and is not repeated here.
                                   3-5                    WALDEN RESEARCH CORPORATION

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IV.  TECHNICAL FEASIBILITY

     Our assessment of the technical  feasibility of each of the control
strategies was determined from data gathered through a series of dis-
cussions with the same organizations  and individuals contacted in our
evaluation of the source emission factors (Appendix B).   Our objective
was to establish whether there were any potential  obstacles and whether
the technical capabilities existed in the Metropolitan Boston area for
the implementation of each strategy.   Analysis of the technical feasibility
of implementation of each of the  designated control strategies fell  into
two general  categories:

     (1)  Were there any technical, i.e., engineering obstacles that
          could delay application of  each strategy.
     (2)  Were there sufficient supplies of distillate oil, natural
          gas, or steam available to  accomodate the proposed strategies.

In general,  it is our judgment that there are no engineering reasons why
any of the strategies could not be implemented to control  particulate and
S02 emissions from stationary fuel  burning sources.  However, inadequate
supplies of distillate oil  and natural  gas make those strategies associated
with their availability currently unfeasible.  Furthermore, limited  steam
supplies both now, and as projected to 1975, make conversion to that form
of space heating highly unattractive.

     STRATEGY A.  CONVERSION TO DISTILLATE FUEL OIL BY ALL SOURCES WITH
                  A HEAT INPUT OF LESS THAN 10 MMBtu/HR

                  Conversion of residual oil burning units to distillate
oil is accomplished by two general procedures:

                  (1)  "Minor" adjustment of the existing  burner
                  (2)  Replacement of the existing burner

In the first case, conversion involves cleaning the fuel tank, discon-
necting the heating equipment on  the tank and suction and  return oil
lines (if in use), flushing the lines and inspecting them  for leakage,
possible addition of a line filter and replacement of the  filter basket
                                    " '                     WALDEN RESEARCH CORPORAl

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with one of a finer mesh, replacement of the fuel  pump or alteration of
its operating speed, elimination (or reduction) of the preheat supplied
to the oil for combustion, replacement of the atomizing cups in some
horizontally fired rotating cup burners, readjustment of the burners to
achieve proper C02 and smoke levels, bypassing of the cold oil inter-
lock control, and installation of required safety controls.  After
these adjustments, an existing burner can be expected to fire success-
fully on distillate fuel [5, 6].

                  There is, however, much debate over the potential  ef-
fectiveness of a burner adjustment program (as opposed to outright burner
replacement).  Many of the burner installers in the Metropolitan Boston
area insist that an oil burner originally designed to operate on residual
fuel will operate with poorer performance (i.e., high maintenance require-
ments, poor combustion performance) and higher emissions after conversion
to distillate oil.  This is claimed to be especially true of the older
rotary cup burners prevalent in Greater Boston.  The installers, therefore,
maintain that the burners should not be adjusted, but should instead be
replaced with more efficient pressure atomizing units.  There is even a
consensus of opinion on their part that replacement of old rotary units
by new pressure atomizing burners operating on residual oil would result
in almost as great a reduction in particulate emission as would exist
if the new units were also required to operate on distillate oil.  Note
that a strategy associated with a ban on rotary burners and their replace-
ment with residual fired pressure atomizing burners would likely sig-
nificantly relieve the distillate oil supply problem discussed below.
Unfortunately, we were not able to obtain quantitative data to evaluate
the effectiveness of such a strategy.  In either case (that is, if burners
are replaced or converted), the necessary technology and skills* exist in
the area to accomplish the proposed switchover to distillate oil.
 A retraining program may be necessary for residual oil burner servicemen
 so that they may apply their skills to distillate oil burners.
                                   4~2                    WALDEN RESEARCH CORPORATION

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                  A review of the oil  resources  available in  the Metro-
politan Boston area indicates that there is  an insufficient distillate
supply available to cope with the increased  demand associated with  imple-
mentation of the strategy.   This  lack  of supply  is principally associated
with the uncertainty in oil  import quota allowances during both the near
term and foreseeable future (see  Reference 7 for example). Discussions
with the major fuel oil suppliers in the Boston  area have revealed  that:

                  (1)  A significant fraction of the available distil-
                       late oil is being blended with high sulfur
                       residual oils to  satisfy  low sulfur fuel regu-
                       lations.
                  (2)  There is inadequate refining capacity  within the
                       United States to  meet currently projected needs
                       of light fuels  such as distillate  oil  and gasoline
                       on a  national level.
                  (3)  An increasing amount  of the available  distillate
                       fuel  is slated  for consumption by  public and private
                       utilities  in gas  turbine  power generators.
                  (4)  There is likely to be a distillate oil  shortage
                       in the Boston area by the 1973-74  heating season
                       even if programmed changes (e.g.,  3-6  MMBtu  units
                       in the 13  core  cities and towns switching to dis-
                       tillate) are not  implemented.

It is our assessment that no certain projection  of future supply of dis-
tillate heating oil in the Boston area can be made at this time.  With
this consideration, it would appear that implementation of this strategy
in time to aid the achievement of the  1975 air quality standards in
Metropolitan Boston is unfeasible.*

     STRATEGY B.  ANNUAL INSPECTION AND  PERIODIC MAINTENANCE  PROGRAM FOR
                  ALL SOURCES TO  ASSURE  OPTIMUM  COMBUSTION CONDITIONS

                  As discussed in previous sections, this strategy  will  be
most effective for sources greater than  30 MMBtu/hr heat input. Table  4-1**
  The President's energy policy announcement of April  18, 1973,  has not
  been considered in reaching this conclusion since the impact of the
  message on the Northeast U.S. fuel supply situation is quite uncertain.
 **Table 4-1 is identical with Table B-5.
                                                          WALDEN RESEARCH CORPOR

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outlines an inspection and maintenance program under development by Boston
Edison.  Note that the Edison program calls for more frequent cleaning
and maintenance than the annual  period proposed by the strategy.  It is
our judgment that maintenance of optimum combustion conditions in units
greater than 30 MMBtu/hr heat input will require a more frequent service
interval than annual; smaller units will probably require only annual
inspection and cleaning.

                  The major technical obstacle to implementation of a
maintenance and inspection program is the establishment of a satisfactory
time interval for cleaning.  The Edison test program is designed to de-
termine the frequency necessary with their large units; a similar program
should be conducted with units outside the utility size range to estab-
lish an appropriate interval for these smaller (30-250 MMBtu) boilers.*

     STRATEGY C.  APPLICATION OF FUEL WASHING TECHNIQUES TO REMOVE
                  PARTICULATES FROM FUEL

                  This concept is based on results at the General Electric,
Lynn, Massachusetts industrial power plant.  GE has been experimenting
with fuel treatment since early 1971 to remove sodium and other water-
soluble metallic salts from #6 fuel oil scheduled for use in their gas
turbine power generator.  Their analysis indicates that much of this
matter is picked up during transit of the oil by barge or truck to their
facility; consequently, to extend the life of their turbomachinery they
must treat the fuel on site to remove all corrosive components.  Treat-
ment consists of fuel washing by either an electrostatic precipitation
or centrifugation process.
  Note  that we include emission compliance testing as an integral part of
  this  strategy.
                                    4-4                    WALDEN RESEARCH CORPORATION

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                                TABLE 4-1

             PROCEDURES FOR CONTROL OF PARTICULATE EMISSIONS
              FROM THE STACKS OF THE BOSTON EDISON COMPANY
I.    Frequent testing to maintain proper fuel/air ratio for combustion,

II.   Purge cleaning of fuel-oil burning guns at each shutdown.
      A.  Routine disassembly and cleaning of fuel oil burning guns to
          determine possible plugging of orifices.
      B.  Renew worn parts of fuel oil burning guns as soon as wear is
          noted.
III.  Complete overhaul and repair of all fuel oil burning equipment
      and all flue gas passages of the boiler, during every annual
      outage for inspection.
IV.   Continuous sequential operation of soot blowers.
V.    Fire sides of boilers, boiler duct work and ash hoppers are to
      be cleaned at periodic intervals during the year.
          The frequency of cleaning will be determined by the
          results of the test program described in Item VI.
VI.   A program of periodic testing of particulate emissions for rep-
      resentative Boston Edison boilers is under development.  The
      object of this program is to determine the frequency of cleaning
      necessary to maintain particulate emissions in compliance with
      the Bureau of Air Quality Control's regulations.
                                    4"5                    WALDEN RESEARCH CORPO*

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                  With the precipitator, fuel  is heated by steam to the
designated process temperature (250° T).  A de-emulsifier is added in a
mixing chamber followed by water.  The oil-water mixture is then passed
through a precipitator that is a slightly modified version of a com-
mercially-available refinery unit manufactured by the Petreco Division
of the Petrolite Corporation.  A second mixing unit and precipitator
state are used to complete the washing process.  Before introduction
into the power turbines, a vanadium inhibitor is added to the washed
fuel.  Waste fluids are piped to a gravity separator and then to a water
treatment facility.

                  With the centrifugation process, two centrifuges ar-
ranged in parallel form each washing stage.  The centrifuges are also
commercially-available separation units and are currently marketed by
the DeLaval Company.

                  6E  has successfully  operated with washed fuel in their
conventional power boilers and  observed qualitative improvement (i.e.,
less glowing particulate matter in  the fires)  in combustion  performance.
The boilers  have also been shown to operate at higher  loads  without
smoking with washed fuels.  The washing technique  has  been shown not  to
alter oil viscosity and gravity properties and to  reduce ash and sediment
content of typical 1% sulfur  #6 fuels  by  approximately 70%.  In short,
although  the process  was developed  for elimination of  soluble  salts
from fuels slated for use  in  turbomachinery,  it appears to be  a practical
and feasible technique for reduction of ash related  emissions  in all
residual  fuel  oil burning  installations.* The major significant obstacle
to the  implementation of  this strategy is the lack of  a sufficient data
base  (including  stack emission  tests)  on  the  effectiveness of  the  washing
technique in reducing stack  emissions.
  Process technology is available through either Petreco or DeLaval.
                                    4-6                    WALDEN RESEARCH CORPORATION

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                  One problem that must be overcome in order to imple-
ment this strategy is to make certain that washing facilities are avail-
able to all local fuel suppliers.  Most probably, power plants would
operate washing facilities on site to eliminate possible recontamination
during transit of the fuel by soluble salts that would be harmful to their
more sensitive turbomachinery.  All other residual fuel users (i.e., those
operating conventional power boilers) can have their oil treated at their
supplier's terminal.  Clearly, effective application of this strategy will
also require clean tanks and trucks for fuel storage and transit, respec-
tively.  We do not consider this to be an obstacle to implementation.

     STRATEGY D.  PURCHASE OF STEAM FROM A LOCAL STEAM GENERATING
                  STATION FOR HEAT

                  The feasibility of this strategy is principally depen-
dent on the availability of steam during  the peak demand winter heating
months.  Currently, there is a maximum of 224,000 Ib of steam/hr com-
mercially available at peak load conditions within the existing Cambridge
and Boston Edison systems.*  (Actually, this is a reserve capacity that
would not normally be sold.)  This corresponds to an average capacity
of approximately 92,700 Ib/hr of steam, far short of that required to
significantly reduce emissions by application of this strategy (see
Table 5-3).  Furthermore, we must incorporate a transmission loss in
the case of steam use (we assume 20%) in our estimate  of steam avail-
ability.  Note that we also have assumed an 88% efficiency for steam
boilers and a 60% efficiency for private boilers.  On a longer term
basis (approximately 3 years), the  projected increase in capacity in
Cambridge and Boston is already committed for  current and future con-
struction.  Historically, neither of these systems builds additional
steam capacity without having the supply already contracted to future
customers.  Generation of additional steam capacity will take a minimum
of three years from the time customers and demand requirements are
 Note  that  only  Cambridge  Gas and Electric and Boston Edison have steam
 distribution  systems.  Thus, the geographic bounds placed on the ap-
 plication  of  this  strategy are the cities of Cambridge and Boston.
                                   4-7                    WALDEN RESEARCH CORPOR

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finalized.  Note also that the 224,000 Ib steam/hr assumed to be cur-
rently available at peak load essentially represents the safety margin
with which Cambridge and Boston now operate.

                  Development of additional steam capacity must be ac-
companied by development of a distribution system to service the new
customers.  Approximately six months is required for a small customer to
be tied in with the existing distribution system; time requirements for
development of an additional distribution network have not been estab-
lished.

                  The other technical requirements necessary to implement
this strategy involve connection of the utility steam line to the customer's
heating system and disconnection and removal of his boiler equipment, etc.
These are relatively simple tasks that can be handled by the existing
burner-boiler service industry.

     STRATEGY E.  SOURCES WITH A HEAT INPUT OF LESS THAN 10 MMBtu/HR
                  SWITCHING FROM OIL TO NATURAL GAS

                  Conversion of an oil-burning unit to natural gas can
be accomplished by the same general procedures associated with conversion
of residual oil burners to distillate oil;  i.e.,  by burner  conversion or
by burner replacement.  As is  the case with switching residual oil
burners to distillate fuel, considerable  debate exists in the  burner
service industry relative to the effectiveness of gas burner conversion.
In either case  (that is, if burners are replaced  or converted), the
necessary technology and skills exist  in the Boston area to accomplish
the  proposed conversion and to install the  appropriate safety  controls
associated with operation of gas-fired combustion units.

                   Implementation of  this  strategy also requires that
satisfactory gas distribution  networks exist within each  of the cities
and  towns within the control district.   Our discussions with the  major  gas
suppliers in  the area indicate that within the  13 core cities  and towns
between  95-99% of  the potential users can be serviced with  the existing
gas  distribution network.   In  the  17 outlying cities and  towns, this
figure is closer to  90%.   It would  thus  appear  that from  the viewpoint
of  distribution, implementation of this  control  strategy  does  not present
a significant technical  problem.
                                    4-8                    WALDEN RESEARCH CORPORATION

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                  However, as in the case of distillate oil, the supply
of natural gas and of synthetic natural gas (SNG)* is inadequate to meet
current needs.  On a national level, statistics indicate an ever widening
gap between supply and demand [8]; on a local  level, many of the distri-
butors have already been forced to resort to peak shaving techniques over
the last heating season.  Thus, considering the increased demand associated
with implementation of this control technique (290% more natural gas than
was consumed in the 30 cities and towns in 1972),** it would appear that
this strategy is not feasible, in both the short and long term, as viewed
from our current perspective of the local  and  national  gas supply situation.

     COMBINATION STRATEGIES F, G, H AND I

                  Strategies F, G, H and I represent coupling of the five
principal strategies discussed above (see  page 1-3).  The technical
feasibility of each of these strategies is the combined feasibility of
each of their component parts.

     STRATEGY J.  SOURCES WITH A HEAT INPUT OF LESS THAN 10 MMBtu/HR
                  SWITCHING FROM OIL TO ELECTRIC HEAT

                  As previously discussed, no quantitative assessment of
the effectiveness of this strategy has been conducted since our preliminary
calculations revealed a greater equivalent oil consumption by the  utilities
than would be consumed by a given facility with an internal heating plant.
That is, the fuel oil necessary to generate a Btu of energy for space heat-
ing by electrical power is greater than the fuel oil necessary to  provide
  SNG is an important supply  source  in the Boston area  since Boston Gas
  is constructing an SNG plant  in  Everett to  supplement its pipeline supply
  of natural  gas.  The facility will  have a production  capacity of 40 million
  ft3/day of SNG.
**
  See Table 2-2.
                                    4-Q
                                                          WALDEN RESEARCH CORPORl

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the same usable energy with an on-site heating plant.*  Thus, given the
current fuel  oil  shortage, we judge this strategy not to be feasible at
this time.   Should the situation change, the strategy should be re-evaluated
recognizing that the dispersion characteristics of a series of large ele-
vated point sources are considerably different than those from a series
of relatively small, low level sources.  A study of the air quality impact
of electric heat, focussing on this latter consideration for sources in
the Metropolitan Boston area, is currently in preparation for the Energy
Policy Staff of the New England Regional Commission [9].
  For residual  oil  users,  the increase in oil consumption is enough to
  offset the reduction in  emission factors associated with such a switch.
  Also, residual  oil, with a higher emission factor, would replace the
  use of cleaner-burning distillate oil in many cases.  This too would
  lead to higher emissions.
                                   4-10                    WALDEN RESEARCH CORPORATION

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V.  CAPITAL AND OPERATING COSTS

    An assessment was made of the capital and operating costs associated
with the implementation of each of the strategies based on a review of
data gathered during the course of the study.  Costs that were considered
in assessing the economic consequences of the five basic strategies are:

    STRATEGY A.  CONVERSION TO DISTILLATE OIL BY ALL SOURCES OF LESS THAN
                 10 MMBtu/HR HEAT INPUT

                  I.  Capital Costs

                      Burner replacement or burner conversion

                 II.  Operating Costs

                      Differential fuel cost
                      Differential heating value of oils
                      Differential burner efficiency of distillate versus
                      residual oil
                      Line and tank heating costs eliminated with distil-
                      late oil
                      Differential maintenance costs for replaced and
                      converted units

    STRATEGY B.  ANNUAL INSPECTION AND PERIODIC MAINTENANCE PROGRAM FOR
                 ALL SOURCES TO ASSURE OPTIMUM COMBUSTION CONDITIONS

                   I.  Capital Costs

                      None

                  II.  Operating  Costs

                      Periodic emission  tests
                      Annual  overhaul  and cleaning of  boilers  (differential
                       beyond current level)
                       Replacement power  (utilities only)
                       Gun maintenance
                       Periodic cleaning  and inspection
                       Periodic testing to maintain  proper fuel/air ratio
                       for combustion
                       Fuel  saving due to increased  efficiency
                                    5-1
WALDEN RESEARCH CORPO!

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STRATEGY C.  APPLICATION OF FUEL WASHING TECHNIQUES TO REMOVE PARTICU-
             LATES FROM FUEL

              I.  Capital Costs

                  Electrostatic precipitator system or configuration
                  system (including waste treatment units)

             II.  Operating Costs

                  Electrical energy consumption
                  Water supply
                  Inhibitor
                  Ftiel saving due  to  improved  combustion  efficiency

STRATEGY D.  PURCHASE OF STEAM  FROM LOCAL STEAM  GENERATION STATION
             FOR HEAT

              I.  Capital  Costs

                  Installation  cost to consumer

             II.  Operating  Costs

                  Differential  cost of current  heating  fuel  versus
                  steam
                  Differential  cost of decreased maintenance with
                  steam
                  Differential  cost  in annual  overhaul  requirements

 STRATEGY  E.  SOURCES WITH  A HEAT INPUT OF LESS THAN 10 MMBtu/HR
             SWITCHING FROM OIL TO NATURAL GAS

               I.   Capital  Costs

                   Burner replacement or burner conversion

              II.   Operating Costs

                   Differential fuel  costs
                   Differential burner efficiency on gas  versus oil
                   Differential maintenance costs for replaced and
                   converted units
                   Line and tank heating costs eliminated for residual
                   oil burners

                                5-2                    WALDEN RESEARCH CORPORATION

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Evaluation of the capital and operating costs for combination strategies
(i.e., F through I) were calculated by summing the costs for the appropriate
basic strategies (e.g., F = A + B).

                 The estimated capital and operating costs of each stra-
tegy are summarized in Table 5-1.*  In most cases, a set of high and low
values are provided to bracket uncertainties in the cost factors.  These
cost factors and the estimated cost of implementation of each strategy
were obtained by the procedures described below.

    STRATEGY A.  CONVERSION TO DISTILLATE FUEL OIL BY ALL SOURCES WITH A
                 HEAT INPUT OF LESS THAN 10 MMBtu/HR

                 The low estimates of both capital and operating costs
were obtained by assuming 90% burner conversion and 10% replacement of
units which  cannot be made to burn efficiently through minor adjustments
(from a combustion point of view the units must be replaced) [10 - 12].
The high estimates were obtained by assuming 100% replacement of burners.

                 A capital cost of $1550/burner (data ranged from $1250
to $1610)  was used as the average conversion cost for all commercial and
industrial  oil  burning units less than 10 MMBtu/hr.  The average cost of
replacement used was $3600/burner (data ranged from $4500 to $7500) for
the 6-10 MMBtu/hr  size range.

                  In  determining the increase in operating cost due to
the switch to  use  of a more expensive fuel, the differential fuel costs
given  in Table  5-2 were  used.  These costs were developed from data ob-
tained  from local  fuel-oil suppliers.   In estimating cost changes due  to
the difference  in  heating  value between distillate and residual  oils,  we
estimated  a 3.5% lower heating  value  per gallon for #2 oil  than  for the
residual  oils  (estimate  based on  fuel oil inspection data supplied by
local  and  national  fuel-oil  suppliers).   Improved combustion efficiency
with  distillate fuel  is  expected  to increase  burner fuel efficiency by
 *Table 5-1 is identical with Table 2-9.
                                    5-3                   WALDEN RESEARCH CORPOJ

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                   TABLE 5-1

SUMMARY OF CAPITAL AND ANNUAL OPERATING COSTS
           OF  EACH CONTROL STRATEGY
Strategy
A

B
C

D

E
F

G

H
I
Capital Cost
(millions of dollars)
Low estimate
High estimate

Low estimate
High estimate
Potential saving*
Low estimate
High estimate
Low estimate
High estimate
Low estimate
High estimate
Low estimate
High estimate
Potential saving*
Low estimate
High estimate
Low estimate
High estimate
Potential saving*
10.4
23.6
0
6.5
7.3
0.01
0.05
270
450
10.4
23.6
16.9
30.9
270
450
277
457
457
Annual Operating
Cost Change
(millions of
dollars per year)**
-3.9
+1.2
+0.6
+1.5
+1.8
-7.8
+0.36
+0.44
+9
-3.3
+1.8
-2.4
+3.0
-7.8
+9.6
+10.5
+10.8
- 7.8
Due to increased combustion efficiency.
**
A positive
value indicates an increase.
                      5-4
WALDEN RESEARCH CORPORATION

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about 5% (data ranged from 0-10%) in conversion units, and by 15% (data
ranged from 10-20%)  in replacement  units.  We estimated a 3% (data ranged
from 1-5%) fuel consumption reduction  in  the case of  the switch from #5
to #6 oils, because  heating of  lines and  storage tanks is not required
with distillate oil.  We  further estimated that maintenance costs  would
not change for converted  burners, but  an  annual reduction of about $300/
burner (data  ranged  from  $200-$350) would result from replacement of a
burner.

                  Note  that the  costs given for this strategy do not reflect
the increase  in  the  price  of distillate  oil which would certainly result
from  the  increased demand associated with the strategy.  We have also
assumed that  the  total  fuel  required for  application  of the strategy could
be obtained.

     STRATEGY  B.   ANNUAL INSPECTION  AND PERIODIC MAINTENANCE PROGRAM FOR
                  ALL SOURCES  TO ASSURE OPTIMUM COMBUSTION CONDITIONS,

                  This strategy  impacts upon all residual oil consumers
 greater than 30 MMBtu/hr.  There is no significant capital cost associated
 with this strategy.  The operating-cost-changes include the cost of
 four emission tests per year per boiler,  cleaning of  all boilers four
 times per year, and a 5% decrease in  boiler efficiency.  Evaluation of
 the associated costs to local utilities were  based on cost quotes
 supplied by these facilities.  For non-utility sources, a combination
 of the utility data figures and information assembled from other sources
 were used to generate average cost figures.

                  One of the utilities  reported a  cost of  $3000/boiler/
 emission test; we estimate a cost of $7500/boiler for cleaning.  A
 second utility spends $3500/boiler for an emission  test; we  estimate
 a cost of $5500/boiler for cleaning.*  For non-utility  sources  of  size
  No  incremental  cost  for  this strategy has been projected for Boston
  Edison  since  their existing abatement plan (Table 4-1) has been taken as
  the basis of  the  strategy for the utilities.
                                                           WALDEN RESEARCH CORPO«

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greater than 250 MMBtu/hr, an emission test cost of $2850/boiler was
used, along with a cleaning cost of $7500/boiler.  For units of size
30-250 MMBtu/hr, we used an emission test cost of $2850/boiler and a
cleaning cost of $1500/boiler.  These are all costs in excess of that
which is presently being expended by these sources.*  The cost of fuel
oils which were used to estimate the savings in fuel expenditures are
contained in Table 5-2 and are based on data obtained from local fuel
oil suppliers.  These are wholesale costs which would apply to the large
sources affected by this strategy.
                                TABLE 5-2
       WHOLESALE FUEL OIL PRICES IN THE 30 CITIES (cents/gallon)

Maximum % Sulfur          #2          #4            #5           #6
1/2
1
13.4
13.4
13.4
13.2
13.2
12.7
12.6
11.3
    STRATEGY C.  APPLICATION OF FUEL WASHING TO REMOVE PARTICULATES FROM
                 FUEL
                 The higher of the  two price estimates for this strategy
in both the capital cost and the operating cost change categories corres-
ponds to the use of the electrostatic precipitator method of fuel washing.
The other method considered, and the one  to which the  lower cost figures
apply, is the use of centrifugation in the process.  Note that there  is
a significant potential fuel saving in the operating cost which corresponds
 The principal basis for our  estimates was  cost  data  and  current  practice
 information made  available to  us  by  Boston Edison, Cambridge  Electric*
 and Braintree Power and Light.
                               5-6
                                                          WALDEN RESEARCH CORPORATION

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to a reduction in fuel  consumption of up to 5% as a result of increased
fuel combustion efficiency.   We have not combined the operating cost
change figures because of the uncertainty involved with the exact
amount of the fuel savings,  but the result is surely a net decrease or
saving in annual  operating costs.

                 In calculating the capital cost, we assumed that each
large utility would buy and  operate its own fuel-washing process and
waste treatment plant so that they could eliminate possible recontamina-
tion by soluble salts during transit.   Furthermore, oil companies and/
or distributors would wash the oil  for all  other consumers; we assumed
that, in this case, six facilities would wash #4 and #5 oils, and that
12 facilities would wash #6  oil, making a total  of 24 facilities.  We
assume that all costs to the oil companies  and utilities will be passed
on to consumers in the form  of increased fuel  and electricity (or steam)
prices.

                 The capital cost  to a facility of fuel washing using
the electrostatic precipitation technique was determined using the in-
formation given in Table 5-3 and supplied by the Petreco Division of the
Petrolite Corporation and by the General Electric Company (Lynn, Massa-
chusetts).  Added to this capital  cost is the cost of a waste treatment
facility, which is given in  Table  5-4, which was supplied by Petreco.
The cost of operating the electrostatic precipitation facility, which
is equivalent to the cost of the electricity needed to operate it, was
derived from the information given in Table 5-5, also supplied by
Petreco.

                 The capital cost   of the centrifugation unit needed to
perform fuel washing was derived from the information given in Table
5-6 which was  supplied by the DeLaval Company and the General Electric
Company.  Added to  this is  the cost of  the waste treatment facility
(Table 5-4).   The operating cost change consists  of cost of electricity
consumed, cost of water used, cost of  inhibitor used, and the decrease
in  fuel expenditures due  to increased  burner efficiency and decreased
                                     5-7                 WALDEN RESEARCH CORPOl

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                      TABLE 5-3

CAPITAL COST OF  ELECTROSTATIC PRECIPITATION  FACILITY
          WHICH WILL PERFORM FUEL-WASHING
Facility Size
(gallons of oil processed
per hour)
1 ,000
3,000
6,000
12,000
24,000
50,000
Cost
(dollars)
156,000
169,500
200,000
253,000
343,500
477,500
                      TABLE 5-4

   CAPITAL COST OF A WASTE TREATMENT FACILITY
Facility Size
(gallons of oil processed
per hour)
1,000
3,000
6,000
12,000
50,000
Cost
(dollars)
25,000
33,000
33,000
57,000
57,000
                           5-8                  WALDEN RESEARCH CORPORATION

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                               TABLE  5-5

    OPERATING (ELECTRICITY)  COST  FOR AN  ELECTROSTATIC PRECIPITATION
                 FACILITY WHICH PERFORMS FUEL-WASHING
      Facility Size                                  Cost
(gallons of oil  processed                       (Cents/1000 gal
         per hour)                              of oil  processed)
           1,000                                      45
           3,000                                      89
           6,000                                      85
          12,000                                      87
          36,000                                     261
                                TABLE 5-6

             CAPITAL COST OF CENTRIFUGATION FACILITY WHICH
                       WILL PERFORM FUEL-WASHING
      Facility Size                                  Cost
(gallons of oil processed                          (Dollars)
         per hour)
           1,000                                    33,333
           3,000                                   100,000
           6,000                                   200,000
                                   5-9
                                                          WALDEN RESEARCH CORPORATION

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fuel  consumption.

                 The cost of electricity used is 11.2 KWH* per 900
gallons per hour (gph)  for a 900 gph or smaller size facility, and 26.1
KWH* per 3000 gph for facilities equal  to or greater than 3000 gph in
size; interpolation was used between these size classes.   A water cost
of $120 per million gallons was used.  Inhibitor is consumed in the
amount of 300 parts per million parts oil, and it costs about $3 per
gallon.  These data were supplied by DeLaval and General  Electric.

    STRATEGY D.  PURCHASE OF STEAM FROM A LOCAL STEAM GENERATING STATION
                 FOR HEAT

                 The low estimate of the capital cost was obtained by
assuming that users of approximately 30 MMBtu/hr size would switch to
use ot steam (5 users).  The high estimate of capital cost reflects
switching by users of 6 MMBtu/hr (24 users)  size.  All "new" users
were assumed to be  located adjacent to existing steam lines such that
additional distribution lines would  not have to be installed.  The low
estimate of the increase in operating cost was obtained  for the case of
6 MMBtu/hr size units switching, while  the  high operating cost increase
estimate corresponds to switching by the  30  MMBtu/hr  size units.

                 We used $2000** as  the average cost  to  a new customer
of installation of  the equipment needed to  use  purchased steam.   An
on-site boiler efficiency  of 60$, an 88%  efficiency  for  utility steam
boilers, and a 20%  transmission loss, were  assumed  in estimating  operating
cost expenditures.  The steam  availability  at  peak  loading  is  224,000
Ibs/hr, as discussed in Section IV  of  this  report.**

                 The operating cost change contains the difference
between steam  service  and   oil  prices,  the  savings  in oil  burner  main-
 *
 **
A KWH is assumed to cost 2.32£ [13].
Data supplied by the Cambridge Gas and Electric Co. and by the Boston
Edison Co.
                                   5_1 o                   WALDEN RESEARCH CORPORATION

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tenance visits, the savings in cost  associated with a decrease in time
requirements of on-site personnel,  and the savings in annual  cleaning of
oil burners.

                 The steam costs* given in Table 5-7 (Block Rate A) apply
to the less than 5,000-10,000 Ib steam/hr customers, and hence apply to
users of size 6 MMBtu/hr.   Added to this is a charge of about $1/1O6 Btu/
month, which is dependent  upon current labor and tax rates and current
fuel costs.  The wholesale cost of oil (Table 5-2) applies to this size
category.

                 The steam costs* given in Table 5-8 (Demand Rate) apply
to steam customers of greater than 5,000-10,000 Ib steam/hr size, and
were applied to the 30 MMBtu/hr size steam users in this strategy.  Added
to this is a $1/106 Btu/month charge (as in the case of 6 MMBtu/hr sources)
and a charge of about $150/1000 Ibs steam/hr which is computed using
the maximum load during the month under consideration.  The wholesale
price of oil (Table 5-2) applies to this size grouping.

                 We assumed that 12 oil burner service visits were
required each year at an average cost of $40/visit (data ranged from
$30-$50).  We also estimated that an on-site engineer who is being paid
$12,000/year spends 1/4 of his time adjusting and servicing the oil
burner, but that his time expenditure on the purchased steam equipment
is reduced to 1/4 of that spend on the oil burner.  An annual cleaning
cost of $350 (data ranged from $150-$500) was assumed.

    STRATEGY E.  SOURCES WITH A HEAT INPUT OF LESS THAN 10 MMBtu/HR
                 SWITCHING FROM OIL TO NATURAL GAS

                 The low estimate of capital cost was obtained by assuming
90% conversion of oil burners and 10% replacement (See References 10-12).
  Data  supplied  by  the Cambridge Gas and Electric Co. and by the Boston
  Edison  Co.
                                 5-11                    WALDEN RESEARCH CORPORATI

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                               TABLE 5-7*
                       STEAM COSTS:   BLOCK RATE A
       [Applicable  to Users of <(5000 to 10,000) Ib Steam/hr Size]

        Rate                                                Consumption
(Dollars/MMBtu/Month)                                      (MMBtu/Month)

         1.7                                                first  50
         1.6                                                 next  50
         1.5                                                 next 100
         1.4                                                 next 300
         1.3                                                 over 500
*
 Cambridge Electric rates.
                               TABLE 5-8*
                        DEMAND RATE COST OF STEAM
         [Applicable to Users of >(5000 to 10,000) Ib Steam/hr]

        Rate                                                Consumption
(Dollars/MMBtu/Month)                                       (MMBtu/Month)

         0.95                                               first 2000
         0.90                                                next 3000
         0.85                                                over 5000
 Cambridge Electric rates.
                                   5-12                    WALDEN RESEARCH CORPORATION

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The high estimate was obtained by assuming 100% replacement of burners.
We used $500/burner (data ranged from $400 to $600) as the average cost
of replacement of such a burner.  We used $1500/burner (no range - single
source) as the average cost of conversion of a 0-10 MMBtu/hr size com-
mercial and industrial unit.  An average replacement cost of $3600/burner
(data range from $2250 to $4550) was used for 0-6 MMBtu/hr size non-
domestic units, and $6050/burner (data ranged from $5850 to $6250) for
6-10 MMBtu/hr size units.

                 The operating cost increase results from an effectively
higher cost of gas compared with oil.  Gas burners have lower efficiencies
than oil burners, but heating of lines and storage tanks is no longer
required as in the case of #5 and #6 fuel oils; we have assumed that
these two factors cancel each other out.  We have also assumed that there
are no differences in maintenance costs.

                 Average cost figures were obtained from regulated gas
company rate schedules; the average cost  figures correspond to what we
found to be an average-size user in the domestic,  commercial and  indus-
trial sectors.  This rate was then applied to  the  total consumption in
each sector by sources impacted upon by this strategy.  The average prices
of gas are as follows:  $1.45/103 ft3 for domestic users;  $1.51/103 ft3
for commercial users; $1.24/103 ft3 for industrial users.   Retail oil
prices  (Table 5-9) were applied to domestic  users  and wholesale oil
prices  (Table 5-2) were applied to the other sources  less  than  10 MMBtu/hr.

                                TABLE 5-9*
                  RETAIL  FUEL  OIL PRICES  IN THE 30  CITIES
                              (cents/gallon)
Maximum % Sulfur
1/2
1
n
22.9
22.9
#4
14.0
14.0
15
13.8
13.5
#6
13.2
12.1
  Data obtained from local fuel  oil  suppliers.
                                    ~1 3                    WALDEN RESEARCH CORPORA^1

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                 Note that costs given for this strategy do not reflect
the large increase in the price of natural gas which would certainly re-
sult from implementation of this strategy.  We have also assumed that the
supply required could be obtained.

   STRATEGIES F, 6, H AND I.   COMBINATION STRATEGIES

                 The capital  and operating costs for these strategies
are the sum of the costs associated with their component parts.

    STRATEGY J.  SOURCES WITH A HEAT INPUT OF LESS THAN 10 MMBtu/HR
                 SWITCHING FROM OIL TO ELECTRIC HEAT

                 As indicated earlier, we did not quantitatively evaluate
the costs associated with this strategy because a preliminary analysis
showed that a net increase in emissions would result from implementation
of this strategy.
                                   5-14                    WALDEN RESEARCH CORPORATION

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VI.   ADMINISTRATIVE REQUIREMENTS

     Administration of the present control  program by the Bureau of Air
Quality Control can be classified into engineering services, technical
services, field enforcement services, and management services.  These
functions are currently performed within the different operating units
of the Bureau's organizational  structure.  Implementation of the new
strategies considered in this study will require a similar commitment
of resources in the form of manpower, facilities, and funds.  These
needs can be satisfied through  a combination of reassignment of re-
sources from current programs and/or the addition of new manpower and
funds.  Because of this strong  interaction with current agency programs,
identification of the differential resource requirements associated
with implementation of the new  strategies cannot be readily assessed.
Instead, our approach has been  based on estimating the total adminis-
trative requirements under the  assumption of a comprehensive enforcement
plan.

     The projected annual manpower requirements for implementation of
Strategy A, conversion of all sources with heat input less than 10 MMBtu/hr
to distillate oil, are given in Table 6-1.   The principal activities asso-
ciated with this strategy are source registration and inspection to assure
compliance with air pollution control regulations.  We have considered
that all sources require annual registration to update information and
maintain a current source reference file.  The manpower estimates reflect
that a portion of this function is provided by the inspection visit.

     Two time intervals for periodic inspection have been assumed.  Sources
up to 10 MMBtu/hr are considered to be inspected once every five years,
hence, 20% of the total number are inspected during a single year.  All
sources greater than 10 MMBtu/hr, including all utility facilities, are
inspected annually.

     The estimated annual budget requirements for this control program
are  shown in Table 6-2.  These data include the administration and clerical
support required for the professional staff.
                                  6-1                     WALDEN RESEARCH CORPORATH

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CTl
I
O
m
33
m
                                                        TABLE 6-1


                   ANNUAL MANPOWER  REQUIREMENTS  FOR STRATEGY A (CONVERSION TO DISTILLATE  FUEL OIL  BY
                                  ALL  SOURCES WITH A HEAT INPUT LESS THAN 10 MMBtu/hr)
Activity
Source Registration
All Sources
Spot Inspection
3-10 MMBtu/hr
Scheduled Inspection
10-250 MMBtu/hr
>250 MMBtu/hr
Utilities
Administration
Clerical
Output Unit

Registration
Update
Inspection

Inspection
Inspection
Inspection
Per Employee
Per Employee
Number
Units

6570
1450

230
15
11
5.91
7.09
Units/Day

8
4

3
2
2
0.2 MY
0.2 MY
Man-Years

3.65
1.81

0.38
0.04
0.03
1.18
1.42
o
I
8
•ya
s
TO

-------
I
o
m
TO
m
to
8
TO
s
ZJ
                                                        TABLE 6-2


                    ANNUAL BUDGET REQUIREMENTS  FOR  STRATEGY A (CONVERSION TO DISTILLATE FUEL OIL BY
                                 ALL SOURCES WITH A HEAT  INPUT LESS THAN 10 MMBtu/hr)
CO
Activity
Source Registration
Inspection
Administration
Clerical
Total
Manpower
Need
3.65
2.26
1.18
1.42
Employee Grade
Junior Engineer
Inspector
Senior Engineer
Clerk-Steno
Number
3.5
2.5
1.0
1.5
Salary
$11,800
8,400
13,000
6,500
Total
$41 ,300
21 ,000
13,000
9,750
$85,050

-------
     The estimated manpower staff required to inspect all sources annually
associated with the maintenance program in Strategy B, is detailed in
Table 6-3, with the associated costs given in Table 6-4.  The scheduled
inspection is considered to serve the joint function of update of source
registration information, and verification of compliance with applicable
control registrations.

     An alternate administrative approach to implementing Strategy B,
which avoids the requirement for comprehensive inspection could be based
on a program of certified servicing reports.  These reports would be used
to verify that an approved maintenance program was being conducted by the
facility.  The manpower and funding requirements for such a plan would be
substantially reduced from those associated with a full inspection plan.

     The estimated manpower requirements connected with the fuel washing
plan (Strategy C) are summarized in Table 6-5.  We have considered that
implementation of this plan necessitates annual registration of all
sources, and a source inspection program similar to that in Strategy A
(i.e., annual inspection of all sources greater than 10 MMBtu/hr; 20%
inspection of all other sources).  This plan is supplemented with a pro-
gram of quarterly inspection of fuel washing facilities  (11 on-site facil-
ities and 24 at bulk  storage terminals).  Fuel samples  obtained during
these inspections are subjected to proximate and ultimate analysis at
the state laboratories.  The estimated cost for this control program is
given in Table 6-6.

     The number of fuel burning sources which may be switched to steam
heat (Strategy D) was found to be extremely limited.  We have estimated
that 24 locations with boilers rated  at 6 MMBtu/hr (or  5 locations with
boilers rated at 30 MMBtu/hr) can be  switched, based  on the availability
of excess steam generating capacity.  Consequently, the impact on admin-
istrative requirements from an assumed enforcement program consisting  of
source registration and field inspection such  as that associated with
Strategy A,  conversion to distillate  oil, would be negligible.
                                   6_4                    WALDEN RESEARCH CORPORATION

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                           TABLE 6-3

ANNUAL MANPOWER REQUIREMENTS FOR STRATEGY B (ANNUAL INSPECTION
                   AND PERIODIC MAINTENANCE)




o*>
1
Ul




0
§
Z
m

2
S
X
o
o
33
3
3)
H
a

Activity
Scheduled Inspection
3-6 MMBtu/hr
6-10 MMBtu/hr

10-30 MMBtu/hr
30-250 MMBtu/hr
>250 MMBtu/hr
Utilities
Administration
Clerical















Output Unit

Inspection
Inspection

Inspection
Inspection
Inspection
Inspection
Per Employee
Per Employee














Number
Units

5700
2320

145
85
15
11
1380
16.50















Units/Day

3
3

3
3
2
2
0.2 MY
0.2 MY















Man-Years

9.48
3.87

0.24
0.14
0.04
0.03
2.76
3.30















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                                                       TABLE 6-4




                             ANNUAL BUDGET REQUIREMENTS FOR STRATEGY B (ANNUAL INSPECTION

                                              AND PERIODIC MAINTENANCE)
o>
1
o
Manpower
Activity Need Employee Grade
Scheduled Inspection 13.80 Inspector
Administration 2.76 Head Inspector
Clerical 3.30 Clerk-Steno
Total

Number Salary Total
14 $ 8,400 $117,600
2.5 11,500 28,750
3.5 6,500 22,750
$169,100

o



8
3)



I


O

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                                                        TABLE 6-5
                               ANNUAL MANPOWER REQUIREMENTS FOR STRATEGY  C  (FUEL WASHING)
I
o
m
z

TO
m
07

2
TO
O



8
TO

8
TO
Activity
Source Registration
All Sources
Source Inspection
Same as Strategy A
Fuel Facility Inspection
Fuel Washing Facilities
Laboratory
Fuel Analysis
Administration
Clerical
Output Unit

Registration Update

Inspection

Inspection

Fuel Analysis
Per Employee
Per Employee
Number
Units

6570

1706

129

140
6.75
8.10
Units/ Day

8

Same as Strategy A

3

1
0.2 MY
0.2 MY
Man-Years

3.65

2.26

0.22

0.62
1.35
1.62

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                                                      TABLE 6-6
                              ANNUAL BUDGET  REQUIREMENTS FOR STRATEGY C  (FUEL WASHING)

CTl
oo


1
o
m
f't
z
TO
§
TO
a
8
70
Activity
Source Registration
Source Inspection
Fuel Inspection
Laboratory
Administration
Clerical
Total






Manpower
Need
3.65
2.26
0.22
0.62
1.35
1.62






Employee Grade Number
Junior Engineer 3.5
Inspector 2.5
Inspector 0.5
Lab Technician 0.5
Senior Engineer 1.5
Clerk-Steno 1.5






Salary Total
$11,800 $ 41,300
8,400 21,000
8,400 4,200
9,000 4,500
13,000 19,500
6,500 9,750
$100,250






s
O

-------
     Implementation of the control plan associated with conversion of
sources less than 10 MMBtu/hr from oil to natural gas use  (Strategy E)
is based on annual source registration and annual inspection of all re-
maining oil burning sources greater than 10 MMBtu/hr.  No  inspection
has been budgeted for the sources less than 10 MMBtu/hr which  have
switched from oil to natural gas use.  The associated manpower require-
ments to implement this plan are shown in Table 6-7, while the annual
budget is given in Table 6-8.
                                   6-9                     WALDEN RESEARCH CORPORATION

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                                                       TABLE  6-7



                   ANNUAL  MANPOWER  REQUIREMENTS  FOR STRATEGY E  (SOURCES  WITH  A HEAT INPUT OF LESS

                                  THAN  10  MMBtu/hr SWITCHING  FROM OIL  TO  NATURAL GAS)
                    Activity
Output Unit
Number

Units
                                                                   Units/Day
Man-Years
CTl

I
5
•30
O
X


8
70

s
Source Registration



   All Sources



Scheduled Inspection
                                              Registration  Update
                    8020
                           4.46
All Sources >10 MMBtu/hr
Administration
Clerical
Inspection
Per Employee
Per Employee
256
4.91
5.89
2-3
0.2 MY
0.2 MY
0.45
0.98
1.18
o

-------

m
                                                       TABLE 6-8




                     ANNUAL BUDGET REQUIREMENTS FOR STRATEGY E (SOURCES WITH A HEAT INPUT OF LESS

                                  THAN 10 MMBtu/hr SWITCHING FROM OIL TO NATURAL GAS)
Activity
Source Registration
Inspection
Administration
Clerical
Total
Manpower
Need
4.46
0.45
0.98
1.18
Employee Grade
Junior Engineer
Inspector
Senior Engineer
Clerk-Steno
Number
4.5
0.5
1.0
1.0
Salary
$11,800
400
13,000
6,500
Total
$53,100
4,200
13,000
6,500
$76,800
8
TO

3
30

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VII.  REFERENCES
 1.  Ozolins, G. and  R. Smith,  A Rapid  Survey Technique for Estimating
    Community Air Pollution  Emissions,  U.S. Dept.  of HEW, PHS, Pub. No.
    999-AP-29, Cincinnati, Ohio (October  1966).

 2.  Guide for Compiling  a  Comprehensive Emission  Inventory, U.S. Environ-
    mental Protection Agency,  Publication APTD-1135, Research Triangle
    Park, North Carolina (March 1973).

 3.  Compilation of Air Pollutant Emission Factors, EPA Office of Air
    Programs, Publication  No.  AP-42, Research  Triangle Park, N.C.
    (February 1972).

 4.  Morgenstern, P., Parks,  T.R., and  Calcagni, J., Air  Pollutant  Emis-
    sion  Inventory for the Metropolitan Boston Air Pollution Control
    District, Prepared by  Walden Research Corporation, Cambridge,  Mass.
    (June 1972).

 5.  Personal Communication,  Mr. R.A. Beals, Natural Oil  and  Fuel Insti-
    tute, Inc., New  York,  New York,  to Dr. Richard D. Siegel  (February
    1973).

 6.  Changing Burner  Installations to Lighter  Grade of  Fuel Oil, Part  I
    Of NOFI Technical  Publication Bulletin 68-103-50A, National Oil and
    Fuel  Institute,  New  York, New York.

 7.  Cummings, G.H. and  Franklin, W.B., Declining  Domestic Reserves -
    Effect  on Petroleum  and  Petrochemical Industry, AIChE Symposium
    Series, 69  (127),  New York, New York  (1973).

 8.   lammartino, N.R.,  "Gas Pinch Plagues  CPI," Chemical  Engineering,
    pp 34-36  (March  5,  1973).

 9.  Unpublished  report by the Research Corporation of  New England  to
    the Energy  Policy  Staff of the New England Regional  Commission.

10.  Levy, A., et  al, A Field Investigation of Emissions  from Fuel  Oil
    Combustion  for Space Heating, Prepared by Battelle  Columbus Lab-
    oratories,  Columbus, Ohio, American Petroleum Institute  Publica-
    tion 4099  (November 1971).

11.  Cauley,  S.P.  and Siegmund, C.W., Updating Emission  Factors  for
    Space Heating with Fuel  Oil, Publication No.  29-72,  Presented  at
     the 37th  Midyear Meeting of the American Petroleum Institute's
    Division  of Refining, New York, New York (May 1972).

12.   Unpublished report by Battelle Memorial Institute,  Columbus,  Ohio,
     to the  American  Petroleum  Institute and the EPA,  A Field Investi-
     gation  of Emissions from Fuel Oil  Combustion for Space Heating
     (Year 2).
                                                          WALDEN RESEARCH CORPORATION

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13.   Electric Utility Industry in New England Statistical Bulletin 1971,
     Electric Council of New England, Burlington, Mass. (July 1972).

14.   Diehl, J.M., "Sales of Fuel  Oil  and Kerosene in 1971", Mineral
     Industry Surveys, Bureau of Mines, Arlington, Virginia (October
     1972).

15.   Ehrenfeld,  J.R., et al, Systematic Study of Air Pollution From
     Intermediate-Size Fossil-Fuel  Combustion Equipment. Wai den Research
     Corporation for Air Pollution Control  Office, EPA, Contract No.  CPA
     22-69-85 (March 1971).

16.   Shelton, E.M., Burner Fuel  Oils, 1972, Bureau of Mines, Petroleum
     Products Survey No. 76, Bartlesville,  Oklahoma (July 1972).
                                  7-2                     WALDEN RESEARCH CORPORATION

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                              APPENDIX A

                    SOURCE AND FUEL USE INVENTORIES

      An inventory of stationary fuel-burning sources was developed to
serve as a data base for evaluation of the various control strategies.
This inventory consists of an accounting of the amount of fuel used and
the number of fuel burning sources in the area classified by location,
size and type.  An inventory was prepared for the years 1972, 1973, and
1975.  This appendix contains a description of these inventories and
describes the procedures used in their development.

A-l.  1972 SOURCE AND FUEL USE INVENTORY

      Consumption of natural gas and coal during  1972 in  the 30 cities
and towns covered in this study is given in Table A-l.  Gas consumption
data was obtained from reports of gas company sales, while consumption
of coal was compiled from data on file with the Bureau of Air Quality
Control.  These data are categorized by region, viz., 13  core cities
and 17 outer  cities.

      Consumption of #2 distillate and #4, #5, and #6 residual fuel oils
during 1972 in the 30 cities is given  in Table A-2.   In this case, con-
sumption is categorized by region, user size, and oil type.  These basic
data were derived from Bureau of Mines published  information.

      The estimated number of oil-fired boilers operating in the 30 cities
in  1972  is given  in Table A-3.  This  information  is  categorized by region,
user size, and oil type.  These estimates were derived from  representative
population samples on file at the Bureau  of Quality  Control  using proce-
dures described  later  in  this Appendix.

      A.  NATURAL GAS  CONSUMPTION

          Consumption  of  natural  gas  in  1972  was  obtained by a  direct
survey of all  of the gas  companies  serving  the 30 cities  and towns covered
                                                          WALDEN RESEARCH CORPORATION

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                     TABLE A-l
  ESTIMATED 1972 CONSUMPTION OF NATURAL GAS AND
              COAL IN THE 30 CITIES
Natural Gas (MMcf/year)
   13 Core Cities                           42,949
   17 Outer Cities                          14,971
      Total 30 Cities                       57,920
Coal (tons/year)
   13 Core Cities                             1,671
   17 Outer Cities                                0
      Total 30 Cities                         1,671
                         A-2                     WALDEN RESEARCH CORPORATION

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                                                      TABLE A-2
                           ESTIMATED 1972 FUEL OIL CONSUMPTION INVENTORY  IN THE 30  CITIES
                                                   (thou gal/year)


                                              Industrial and Commercial
              Fuel                0-6        6-10      10-30       30-250      >250
              Type    Domestic   MMBtu/hr   MMBtu/hr   MMBtu/hr   MMBtu/hr   MMBtu/hr  Utility    Total

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#2 473,656
#4

#5
#6
#2 224,952
#4
#5
#6



51,141
24,969

69,155
73,421
15,476
6,431
18,535
35,926



18,915
8,636

13,765
128,840
8,333
4,951
9,549
65 ,847



13 Core Cities
845 2
2,155 1

2,484 2
23,115 83
17 Outer Cities
374
1,254
853
9,495 6



,932
,000

,378
,476
273
—
793
,544



547,489
36,760

1,933 — 89,715
56,438 621,939 987,229
249,408
12,636
29,730
59,572 121,543 298,927



s

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                          TABLE A-3



ESTIMATED NUMBER OF OIL-FIRED BOILERS IN  THE  30  CITIES  IN  1972
Industrial and Commercial



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#2
#4
15
#6
Sub-Total
#2
#4
#5
#6
Sub-Total
Grand Total

0-6
Domestic MMBtu/hr
315,771 1,657
473
1 ,439
1,126
315,771 4,695
149,968 258
93
339
311
149,968 1,001
465,739 5,696

6-10
MMBtu/hr
13 Core
188
106
156
918
1,368
17 Outer
139
71
174
569
953
2,321

10-30
MMBtu/hr
Cities
7
8
15
75
105
Cities
1
5
4
31
41
146

30-250 >250
MMBtu/hr MMBtu/hr Utility
4
1
7 1
56 8 32
68 9 32
1
— — • —
4
10 6 18
15 6 18
83 15 50


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in this study.   This data was not categorized by user size since only a
single emission factor for gas (applicable to all source sizes) was avail-
able.   However, gas consumption was classified by region - either 13 core
cities or 17 outer cities.

      B.  COAL CONSUMPTION

          Only three significant sources, all Boston schools in the
0-6 MMBtu/hr size range, burned coal in 1972.  This information was ob-
tained from the Bureau of Air Quality Control.

      C.  OIL CONSUMPTION AND NUMBER OF OIL-FIRED UNITS

          Fuel oil consumption and number of  oil-fired  burners was deter-
mined by a combination of direct count and  estimation methods.

          1.  Oil Consumption and Number  of Boilers  at  Utilities

               Fuel  oil consumption  by  utilities  was  provided  to  us  by  the
Bureau  of Air  Quality  Control.  Wai den,  however, conducted its  own  direct
survey  to determine  the  number  of  boilers operated  at each utility  site  in
1972.

          2.   Oil  Consumption  and  Number of Units in the Commercial  and
               Industrial >10 MMBtu/Hr  Size Range

               Consumption of #2 distillate and #4,  #5,  #6 residual  oils  by
 large industrial  and commercial  facilities of greater than 10 MMBtu/hr size,
 and the number of such sources, was obtained from the source registration
 and survey  forms  on file with the Bureau of Air Quality Control.  Although
 almost all  of these forms contain 1970 or 1971 operating data, we have
 assumed that 1972 consumption by these sources did differ significantly
 from either of these earlier years.*  We further assumed that the files
 were essentially complete for sources in this size category.
  Although population and other growth factors may have increased during the
  period 1970-1972, the winter months of 1972 were mild, and thus required
  less heating than those of 1970 or 1971.  These two factors have been
  determined to have approximately offset one another.
                                                           WALDEN RESEARCH CORPORATION
                                   A-5

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          3.  Oil  Consumption and Number of Sources in the Commercial and
              Industrial 0-10 MMBtu/Hr Size Range

              Consumption of fuel oils by industrial and commercial sources
in the size range 0-10 MMBtu/hr includes use by commercial, industrial, in-
stitutional, and governmental sources.  The source registration and survey
forms on file with the Bureau of Air Quality Control constitute a repre-
sentative size-stratified sampling of the sources in the 3-10 MMBtu/hr
size range.  Estimation of total consumption in this size range were made
using census figures and 1971 Bureau of Mines (BOM) data on fuel oil con-
sumption [14] to adjust the registration data sample.  A more detailed
description of the procedures used follows.

              a.  Estimation of #2 Fuel Oil Consumption by 0-10 MMBtu/Hr
                  Size Industrial and Commercial

                  We have estimated that 10% of total Massachusetts #2
distillate heating oil, 100% of industrial distillate oil and 100% of oil
company distillate oil is consumed in the state by all industrial and com-
mercial sources (these figures are based on data gathered by Maiden in
previous studies).  Consumption of #2 fuel oil in the 30 cities and towns
was then estimated from statewide totals by applying a proportioning factor
(based on commercial and industrial employment figures and adjusted to ac-
count for steam use in Boston and Cambridge).  The amount consumed by the
greater than 10 MMBtu/hr sources (obtained from the state.s source regis-
tration and survey files) was subtracted from this regional total yielding
an estimate of fuel use by sources less than 10 MMBtu.  The split between
consumption in the 13 core cities and that in the outer 17 was made by
again applying a proportioning factor based on commercial and industrial
employment  (and adjusting it to account for steam use in the 13 core cities)
to the 30 cities total.  The consumption by military sources in the 13 and
17 cities was added to this fuel inventory.

                  The final division  between 0-6 MMBtu/hr and 6-10 MMBtu/hr
size sources, and the number of sources in each category, was made on the
basis of proportions developed from the source registration and survey data
available  for less than 10 MMBtu sources.
                                                          WALDEN RESEARCH CORPORATION

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              b.   Estimation of #4 Fuel Oil Consumption by 0-10 MMBtu/Hr
                  Size Industrial and Commercial Sources

                  The procedure used in this case was the same as for #2
oil, except that the calculations were applied to 100% of the statewide
#4 heating oil use given in the BOM data.

              c.   Estimation of #5 Fuel Oil Consumption by 0-10 MMBtu/Hr
                  Size Industrial and Commercial Sources

                  The procedure used was  the same as for #4 oil and applied
to 100% of the statewide #5 heating oil use given in the BOM data.

              d.  Estimation of #6 Fuel Oil Consumption by 0-10 MMBtu/Hr
                  Size Industrial and Commercial Sources

                  The procedure was the same as  in  the  case of #4 and #5
fuel oil, and applied to 100%  of  statewide #6  heating  oil use, 100% of
industrial residual  oil use, and  100%  of  oil company  residual  oil use.

          4.  Oil Consumption  by  Domestic Sources

              Previous Walden  studies  [15] have estimated that  100% of
total  #1  heating  oil  and 90% of total  #2  heating oil  is consumed  in Mas-
sachusetts by domestic  sources.   These were combined  on an  equal  volume
basis  because, although the #1 oil  has a  lower emission factor than  the
#2,  it also  has  a somewhat lower heating  value and these two  factors  have
been determined  to  approximately counterbalance one another.   We  estimated
consumption  of  these fuels in  the 30 communities by applying  a proportion-
ing  factor  (based on 1970  population figures)  to the state  total.   Similarly,
the  split between the amount consumed in  the 13 cities and that consumed
in the 17 cities was also  obtained by application of a population-based
proportioning factor.  The number of residential sources was estimated by
assuming 1500 gallons per  year as an average consumption by a residential
unit for purposes of space heating, hot water heating, cooking, and other
domestic applications [4].
                                    „ _                     WALDEN RESEARCH CORPORATION
                                    A-7

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A-2.  PROJECTED 1973 CHANGES IN FUEL CONSUMPTION AND SOURCE INVENTORY

      The 1972 fuel consumption and source inventory was adjusted to a
1973 basis by accounting for programmed changes in fuel utilization due
to existing regulations without adjusting the total amount of fuel con-
sumption.  These changes are:

      (1)  Conversion of principal coal users in area to distillate oil
      (2)  3-6 MMBtu/hr residual oil users in 13 core cities convert to
           distillate oil
      (3)  Shutdown of Lynn power plant,

and are further described below.  Thus, 1973 is a pre-strategy  base case
and formed the basis for comparison of the effectiveness of each  applied
control strategy.  Although not all of the programmed changes will occur
at the beginning of 1973 and be in effect throughout that entire  year, we
have elected to apply them on an annual basis.

      Table A-4 shows consumption of natural gas and coal in the  1973
base case while Table A-5 presents the 1973 base case oil consumption
inventory.  The number of oil consumers in the  1973 base case  is  given
in Table A-6.

                               TABLE A-4

         ESTIMATED 1973 BASE CASE CONSUMPTION OF NATURAL GAS
                       AND COAL IN THE 30 CITIES
          Natural Gas  (MMcf/vert)
             13  Core Cities                             42,949
             17  Outer  Cities                            14,971
                Total  30 Cities                         57,920
          Coal  (tons/year)
                Total  30 Cities                           0
                                   A-8                     WALDEN RESEARCH CORPORATION

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I
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                                                       TABLE A-5

                       ESTIMATED 1973 BASE CASE FUEL OIL CONSUMPTION INVENTORY IN THE 30 CITIES
                                                    (thou gal/year)
                                               Commercial and Industrial
              Fuel                0-6        6-10       10-30     30-250      >250
              Type   Domestic   MMBtu/hr   MMBtu/hr   MMBtu/hr   MMBtu/hr   MMBtu/hr   Utility    Total

#2 473,656 218,985
#4
#5
#6
1
18,915
8,636
13,765
128,840
13 Core Cities
845
2,155
2,484
23,115
2,932
1,000
2,378
83,476
715,333
11,791
1,933 — 20,560
56,438 626,398 918,261
                                                    17 Outer Cities
#2 224,952
#4
#5
#6
15,476
6,431
18,535
35,926
8,333
4,951
9,549
65,847
374
1,254
853
9,495
273
—
793
6,544
249,408
12,636
29,730
59,572 100,622 278,006

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                                  TABLE  A-6
ESTIMATED NUMBER OF OIL-FIRED BOILERS  IN THE  30  CITIES  IN THE  1973 BASE CASE
Commercial and Industrial



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Fuel
Type
#2
#4
#5
#6
Sub-Total
#2
#4
#5
#6
Sub-Total
Grand Total



0-6
Domestic MMBtu/hr
315,771 4,698
— —
— —
— —
315,771 4,698
149,968 258
93
339
311
149,968 1,001
465,739 5,696



6-10
MMBtu/hr
13 Core
188
106
156
918
1,368
17 Outer
139
71
174
569
953
2,321



10-30
MMBtu/hr
Cities
7
8
15
75
105
Cities
1
5
4
31
41
146



30-250 >250
MMBtu/hr MMBtu/hr Utility
4 	 	
1 	 	
7 1
56 8 32
68 9 32
!
— — —
4
10 6 14
15 6 14
83 15 46




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      A.   COAL CONSUMPTION

          The three principal remaining coal users (Boston schools) will
switch to #2 oil in 1973.

      B.   CONVERSION OF 3-6 MMBtu/hr SIZE RESIDUAL OIL USERS IN THE 13
          CORE CITIES

          The regulation requiring the 3-6 MMBtu/hr size residual oil
users in  the 13 cities to switch to distillate oil is scheduled to go
into effect on July 1, 1973.  Although hearings will soon be held to
determine whether the regulation will go into effect as previously planned,
the longest extension under consideration is about 1 year.  This does not
change our rationale for including the implementation of this regulation
in with the other programmed changes.  We have assumed 100% compliance
with this regulation when it becomes effective.

      C.   LYNN UTILITY

          Massachusetts Electric Company in Lynn  shut down operations in
December of 1972.  The electricity which this company had previously sup-
plied is now being supplied by  a power pool consisting of all New England
utilities, including those  situated in the  30 cities covered in this
study.  Therefore, adjustments  have been made to  take account of this
change in the 1973 inventory.   It was assumed that the New England util-
ities would proportionately absorb the Lynn plant.s oil consumption based
on their respective  shares  of the total New England utility oil
consumption.

A-3.  PROJECTED  1975 FUEL CONSUMPTION

      Since secondary standards must be met by mid-1975,  it is necessary
to determine the effectiveness  of each of the strategies  in reducing 1975
 Data on utility oil  consumption,  name-plate  capacity,  etc., was  taken
 from Reference 13.
                                    _] ]                    WALDEN RESEARCH CORPORATION

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emissions.  For this reason, projected population and economic growth
figures were applied to the 1973 base case fuel inventory (Table A-5)
to obtain a 1975 fuel consumption inventory.  A population growth factor
was applied to domestic fuel consumption, and to the amount of utility
fuel consumption which is used by the domestic sector on the assumption
that total fuel consumption will grow at the same rate as population.
An economic growth factor (which is an average GNP growth figure) was
applied to all other fuel consumption; here we have assumed that pro-
portional changes in fuel consumption in the predominantly commercial
and industrial sector are equal to the economic growth in that sector.

      The projected population and economic growth figures that were
used to derive the 1975 fuel consumption inventory are given in Table A-7.*
The 1975 inventory for gas and coal consumption is contained in Table A-8,
while that for fuel oils is presented in Table A-9.

      An estimate of the number of fuel burning sources was not prepared
for the year 1975.
  Economic growth factors  used  in  this  analysis  were provided by the Harvard
  University School of  Public Health  and  are  based  on an  unpublished study
  of the economic growth in  the Commonwealth.
                                   A-12                    WALDEN RESEARCH CORPORATION

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                         TABLE A-7
          POPULATION AND ECONOMIC GROWTH  FIGURES
  Population                  1970                  1975

13 Core Cities             1,356,495             1,309,388
17 Outer Cities              644,562               657,892
Population Growth Factor for Period 1973 to Mid-1975
   (applied to domestic sources)
13 Core Cities                 0.98
17 Outer Cities                1.01
Economic Growth Factor for Period 1973 to Mid-1975
   (applied to all nondomestic sources)
30 Cities                      1.08
                         TABLE A-8
    ESTIMATED  1975 CONSUMPTION OF NATURAL GAS AND COAL
                      IN THE  30 CITIES
    Natural Gas  (MMcf/year)
        13  Core Cities                           44,555
        17  Outer  Cities                          15,685
           Total  30 Cities                      60,240
    Coal  (tons/year)
           Total  30 Cities                         0
                            /\_13                    WALDEN RESEARCH CORPORATION

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                                                       TABLE  A-9
                                   1975 FUEL OIL CONSUMPTION  INVENTORY  IN  30  CITIES
                                                    (thou gal/year)
                                 Commercial  and  Industrial
Fuel                0-6        6-10       10-30      30-250      >250
Type   Domestic   MMBtu/hr   MMBtu/hr   MMBtu/hr   MMBtu/hr   WBtu/hr   Utility    Total

                                      13 Core  Cities
 #2    464,183     236,504    20,428        913      3,167        —       —     725,195
 #4      ---         ---       9,327      2,327      1,080        —       —      12,734
 #5      —         —      14,866      2,683      2,568       2,088      —      22,205
 #6      —         —     139,147     24,964     90,154      60,953    652,901   968,119
                                      17 Outer Cities
 #2    227,202      16,714     9,000        404        299        —       —     253,619
 #4      —         6,945     5,347      1,354      —         —       —      13,646
 #5      —        20,018    10,313        921        856        —       —      32,108
 #6      —        38,800    71,115     10,255      7,068      64,338    106,017   297,593

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                               APPENDIX B
                            EMISSION FACTORS

     As discussed in Section II of this report, the set of emission fac-
tors most widely applied to source inventories are those assembled and
published by the EPA [3].  The factors for oil burning sources are shown
in Table B-l;* those for natural gas and coal consumption are shown in
Table B-2.  A review of these factors concluded that the factors for fuel
oil consumption:
            1.  are grouped too broadly for application to
                our inventory;
            2.  do not recognize the difference in partic-
                ulate emissions for various grades of fuel
                oil;
            3.  were developed for high rather than low
                sulfur fuel that is currently in  use in the
                Metropolitan Boston area;
            4.  were developed using sampling and measure-
                ment techniques different  from those cur-
                rently accepted by EPA; and
            5.  are, occasionally, based on  limited and/or
                nonrepresentative data.
Consequently, a revised  set of factors were  developed based  on  examination
of  recent data and on discussions with various government, commercial,
industrial, and professional groups.   These  factors are shown  in Table  B-3*
and reflect our evaluation of  the best available  data on  fuel  oil  combus-
tion by  stationary sources.

     The major differences in  the revised  factors are for particulate
emissions.  For residential units, and small  commercial and  industrial
units  (0 to 10  MMBtu/hr),  the  factors  are  based on  the results  of  a
series of tests performed  for  the API  [10,11]  and for the EPA  [12] by
 *Note  that in  our calculations S02 and S03 emission factors were coupled
  to represent  a total  S0x emission factor (expressed as equivalent S02).
                                    B-l                   WALDEN RESEARCH CORPORATION

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                             TABLE B-l
           EPA EMISSION FACTORS FOR FUEL OIL  COMBUSTION
Pollutant
Parti oil ate
Sulfur Dioxide
Sulfur Trioxide
Type of Unit
Power Plant
(lb/103 gal)
8
157S*
2S
Industrial and Commercial
Residual
(lb/103 gal)
23
157S
2S
Distillate
(lb/103 gal)
15
142S
2S
Domestic
(lb/103 gal)
10
142S
2S
S equals percent by weight of  sulfur in the oil.
                                 B-2
WALDEN RESEARCH CORPORATION

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                                                          TABLE B-2
                                              EMISSION FACTORS FOR NATURAL GAS

                                                     AND COAL COMBUSTION
Pollutant
Parti culates
S0x
Gas Fired (lb/106 ft3)
Coal Fired (Ib/Ton fuel)
Type of Unit
EPA Factors
Power Plant**
15
0.6
Industrial Process
Boiler**
18
0.6
Domestic/**
Commercial
Heating Units
19
0.6
Revised Factor
All Sources***
8
0.6
EPA Factor
Hand-Fired Units
Bituminous
20
38S*
 00
 I
 co
             **
ir

 S equals percent by weight of sulfur in coal

Ir

 EPA Factors from Reference 3
            ***
               Wai den estimate
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                                                        TABLE B-3

                                    REVISED EMISSION FACTORS FOR FUEL OIL COMBUSTION
                                                     (lb/lQ3 gallon)
CO
o
2
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m
250 MMBtu/hr

8







157S*





2S
Domestic

2.4







140S





2S
Industrial and Commercial
(0-30 MMBtu/hr)
Type Oil
n 2.4
I4-1/2XS 5
#4-US 5
#5-l/2%S 8
#5-1 %S 10
#6-1 /22S 9
16-1 XS 12
#6-high S 42
#2 140S
#4 149S
#5 157S
#6-1/2X5 149S
#6-1 XS 157S
#6-h1ghS 157S
All oils 2S
(30-250 MMBtu/hr)

8







157S





2S
.S  equals  percent by weight of sulfur in  oil.
 Q

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Battelle Memorial Institute on a total of 30 boilers in the 0 to 10 MMBtu
size range for a variety of fuel oils.  Note that the Battelle tests with
#4 and #5 residual oils were with high sulfur fuels.  The factors shown
in Table B-3 for 1/2 and 1 percent sulfur #4 and #5 oils were developed
using the Battelle results with distillate and low sulfur #6 oils as guide-
lines.*  Factors for industrial units (10 to 30 MMBtu/hr) have been assumed
equivalent to those for commercial units since there are no suitable data
currently available on sources in this size range.  (Note that a test pro-
gram on sources in this range has just been initiated by EPA.)  An upper-
bound of 30 MMBtu/hr has been placed on this extrapolation since lower ex-
cess air levels, different residence times, and, therefore, different
emission characteristics are associated with units larger than about
30 MMBtu/hr.  The  emission  factors for utilities and for industrial sources
larger than 30 MMBtu/hr have been assumed equal to the power plant factors
given by EPA  [3] even though our analysis of Boston Edison test data in-
dicates that  their power plants should currently be assigned higher fac-
tors. This decision reflects our judgment that the EPA factors are more
representative of the emissions associated with the entire spectrum of
sources greater than 30 MMBtu/hr than new factors  based strictly on the
Edison tests  would be.  Furthermore, we were unable to obtain any other
data for sources  in this size  range than that contained in the original
references used to generate the EPA factors.

     The EPA emission factors for natural gas combustion were also re-
viewed and the particulate emission factors modified as shown in Table B-2.
The basis for this adjustment was our conclusion that the basic data
used for the  development of the EPA factors were taken with sampling and
measurement apparatus that does not correspond with current EPA standard
procedures.   In fact, when compared with the new factor for distillate
*The emission  factor was  correlated with  API  gravity.   Typical  fuel  oil
  inspection  data  was provided by local  and national  fuel  oil  distributors.
                                    B-5                  WALDEN RESEARCH CORPORATION

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fuel oil consumption (on a Ib/MMBtu basis), the EPA gas factor exceeds
that for oil.  We do not believe this is to be justified.  Our revised
factor is therefore based on limited new data from Battelle, Bethlehem
Steel, and Cleaver Brooks that were obtained using accepted sampling
and measurement procedures.*  We feel that this data base  is too narrow
to categorize gas emission factors by unit size or type; for this rea-
son we have developed one value for all gas combustion sources.**

     The EPA emission factors for coal-burning sources were found suit-
able for use with our inventory.  These factors are also presented  in
Table B-2 for small hand-fired units operating with bituminous coal;
these are the only coal-burning sources included  in our  inventory of
fuel consumption in the Metropolitan Boston area.

     The basic factors  in Table B-2 were modified in our evaluation of
those strategies which  involve technological changes that  would  affect
emissions to reflect the degree of emission control associated with each
procedure.  These modifications are  discussed below.

     Strategy B.  Annual inspection and periodic  maintenance program
                  for all sources to assure optimum combustion con-
                  ditions

                  The factors developed to reflect the effect of periodic
oil burner maintenance  on emissions  are shown in  Table B-4.  Gas and  coal
factors are assumed unchanged by the strategy and are contained  in  Table
B-2.

                   For sources smaller  than 3 MMBtu/hr, the Battelle
studies  indicate  [10-12]  that an  increased inspection and  maintenance
 *Data range from 3-10 lb/106ft3
**
  Emission calculations were also undertaken assuming the gas emission
  factor to be zero.  The rationale behind this decision is that the
  factor shown in Table B-2 may still  be too large; a zero value allows
  us to calculate the maximum impact potentially achievable by con-
  version to gas.
                                    B-6                   WALDEN RESEARCH CORPOHATlO

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                                                        TABLE B-4


                                        EMISSION  FACTORS  FOR FUEL OIL  COMBUSTION

                                         Stategy  B:   Inspection  and  Maintenance

                                             (All  Factors  in lb/103 gallon)
 CO
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m
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o

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33

3
Pollutant
Parti culates
so2
so3
Type of Unit
Power Plant and
Utility Sources
>250 MMBtu/hr
5
157S*
2S
Domestic
2.4
140S
2S
Industrial and Commercial
(0-30 MMBtu/hr)
Type Oil
#2 2.4
#4-l/2%S 5
#4 -US 5
#5-1/2X5 8
#5 -US 10
#6-1/2X5 9
#6 -US 12
#6-high S 42
#2 140S
#4 149S
#5 157S
#6-l/2%5 149S
#6-US 157S
#6-high S 157S
All oils 2S
(30-250 MMBtu/hr)
5
157S
2S
S equals percent by weight of sulfur in oil.
o

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program, one beyond that which already is in practice in the Boston area
with units in this size range, will  do little to improve emission per-
formance.  In those studies, the extent of existing annual inspection,
periodic maintenance, and service programs in a geographic area are param-
eters used to adjust emission factors for sources less than 3 MMBtu/hr.
Based on our discussions with burner/boiler service personnel in the
Boston area, it is our judgment that the current maintenance practices in
the area are such that these sources are already serviced at a frequency such
that their emission factor is at the low end of the range suggested by
Battelle and the National Oil & Fuel Institute.  Sources between 3 and
30 MMBtu/hr are judged to also receive a high level of service; for this
reason no adjustment was made to the latter sources' set of emission
factors.  For larger sources, i.e., sources >30 MMBtu/hr, a revised fac-
tor has been developed based on stack test data made available by the
Boston Edison Co.  This factor reflects the effectiveness of their test-
ing and maintenance program outlined in Table B-5.*  We consider this
program to also be representative of the requirements for nonutility
sources in this size range.  Note that on the basis of our discussions
with boiler manufacturers and service personnel, it is our conclusion that
sources larger than 30 MMBtu/hr will require maintenance more frequently
than once a year; our factors  (and  the Edison program) are based on an
assumption of a quarterly frequency of cleaning of these  units.

     Strategy C.  Application of fuel washing techniques  to  remove
                  particulates  from fuel

                  The emission  factors developed for  this strategy  for  fuel
oil  combustion are shown in Table B-6,**  and are based on a  series  of tests
conducted at General Electric  in Lynn, Massachusetts, on  #6  oil  samples  be-
fore and after fuel washing by  centrifugation and  by  electrostatic  precipi-
tation.  These tests show approximately  a 70 percent  reduction  in  ash and
 **
*Table B-5 is identical with Table 4-1.
 Gas and coal factors are unchanged from the baseline case; see Table B-2.
                                                         WALDEN RESEARCH CORPORATION

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                     TABLE  B-5

  PROCEDURES  FOR CONTROL OF PARTICULATE EMISSIONS
   FROM THE STACKS OF THE BOSTON  EDISON COMPANY
  I.   Frequent testing to maintain proper fuel/air
      ratio for combustion.
 II.   Purge cleaning of fuel-oil  burning guns  at
      each shutdown.
      A.   Routine disassembly and cleaning of
          fuel oil burning guns to determine
          possible plugging of orifices.

      B.   Renew worn parts of fuel oil  burning
          guns as soon as wear is noted.
III.   Complete overhaul and repair of all fuel  oil
      burning equipment and all flue gas passages of
      the boiler, during every annual outage for
      inspection.
 IV.   Continuous sequential operation of soot
      blowers.
  V.   Fire sides of boilers, boiler duct work and
      ash hoppers are to be cleaned at periodic
      intervals during the year.
          The frequency of cleaning will be de-
          termined  by the results of the test
          program described in Item VI.
 VI.   A program of  periodic testing of  particulate
      emissions for representative Boston Edison
      boilers is  under development.  The object of
      this program  is to  determine the  frequency
      of  cleaning necessary to maintain  particu-
      late emissions  in  compliance with  the Bureau
      of  Air  Quality  Control's regulations.
                           B-9                 WALDEN RESEARCH CORPORATION

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                                                         TABLE B-6


                                         EMISSION  FACTORS FOR FUEL OIL COMBUSTION

                                                Strategy C:   Fuel Washing

                                              (All  Factors in lb/103 gallon)
 ro
 i

•a
m
o


o
o
TO

3


Pollutant

Particulates






S09
£





S03
Type of Unit
Power Plant and
Utility Sources
>250 MMBtu/hr

6.4






157S*





2S

Domestic

2.4






140S





2S
Industrial and Commercial

(0-30 MMBtu/hr)
Type Oil
n 2.4
#4-1/2X5 3.6
#4-1X5 3.6
#5-1/2X5 6.6
#5-1X5 8.6
#6-1 /2XS 7.4
#6-1X5. 10.4
#2 140S
#4 149S
#5 1 57S
#6-l/2%S 149S
#6-1X5 157S
#6-high S 157S
All oils 2S

(30-250 MMBtu/hr)

6 it
.4





157S





2S
*r

 S equals percent by weight of sulfur in oil.

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sediment content by washing.  The procedure was developed by General
Electric for reduction of the soluble salt content (e.g., sodium) of re-
sidual fuels used in a gas turbine heat recovery system at their Lynn
power plant.  The emission factors in Table B-6 were developed from the
baseline data in Table B-3 by assuming a 70 percent reduction in the ash-
related* emissions of residual  fuel oils currently in use in the 30
cities and towns.  Typical ash  and sediment inspections for fuels con-
sumed during the 1972-73 heating  season were obtained from the major fuel
oil distributors in  Greater  Boston.  Additional data was obtained from
the Bureau of Mines  survey of 1972 burner  fuel oils [16].

     Strategy F.   Conversion to distillate fuel oil by all sources
                   with  a heat input  of  less than 10 MMBtu/hr coupled
                   with  an  inspection and maintenance program to
                   achieve  optimum combustion  conditions

                   The emission  factors  used to evaluate this strategy
are contained in Table  B-4 for  oil  burning sources.  Gas and coal emission
factors  are  included in Table  B-2.

      Strategy G.   Conversion to distillate fuel  oil  by  all  sources
                   with  a heat input of less  than  10  MMBtu/hr coupled
                   with  a fuel  washing  process to remove  particulatesT
                   from the fuel                             ~~

                   The emission  factors used to evaluate  this strategy are
given in Table  B-6 for oil burning sources and in Table  B-2 for gas and
coal  combustion sources.

      Strategy  H.   Sources with a heat input of less  than  10 MMBtu/hr
                   switching from oil to natural  gas  coupled with an
                   inspection and maintenance program to achieve op-
                   timum combustion conditions

                   The emission factor for sources consuming natural gas
 is given in Table B-2.   The emission factors for fuel  oil  combustion
 *About 20 percent for #5 and #6 and 40 percent for #4 oils.
                                        B-ll              WALDEN RESEARCH CORPORATION

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(units greater than 10 MMBtu/hr heat input) are given in Table B-4;
these for coal combustion are also contained in Table B-2.

     Strategy I.   Sources with a heat input of less than 10 MMBtu/hr
                  switching from oil to natural gas coupled with a
                  fuel washing process to remove participates from
                  the fuel

                  The emission factor for sources consuming natural gas
is given in Table B-2.  The emission factors for coal combustion are also
given in Table B-2.  The factors for fuel oil combustion  (units greater
than 10 MMBtu/hr heat input) are given in Table B-4.
                                    B-12                  WALDEN RESEARCH CORPORATION

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