### MEMORANDUM

SUBJECT: The Impact of Emissions Averaging Time on the Stringency of an Emission Standard FROM: Stephen Boone, Ro y Neulicht, and Jeff Cole, RTI TO: Bill Maxwell, EPA, SPPD, Energy Strategies Group DATE: December 9 , 2011 **Purpose** These analyses were conducted on the Part II CEMS data to evaluate the impact of averaging time on variability and to “predict” the UPL value for different averaging times for the MACT floor facilities. This predictive tool has not been previously used and is intended to “ground truth” the variability

estimated by

the UPLcalculation methodology . The se anal ys es are not the result of additional statistical anal ys es of the stack testing data collected under Part II or any data received under Part III , directly . Note: These results have not been through an extensive QA. **General Approach** 1. Part II data from 87 units were evaluated for data completeness and hours flagged as invalid were removed prior to conducting any calculations. 2. For each unit, each hour of data was evaluated to determine the operating load (gross MW) and to determine if zero emissions were reported for the hour. Hours of zero reported emissions were excluded from the calculation of daily averages. 3. Hours were classified as startup or shutdown periods if the gross megawatts recorded for the hour were less than 5 percent of the maximum hourly generating rate recorded in the data set. These hours were not included in the calculation of daily averages. Daily

averages were calculated in accordance with Equation 19 - 19 from Method 19. 4. Contiguous six -hour periods of valid CEMS data at operating conditions equivalent to ty pical stack testing conditions (i.e., steady- state flow rate and steady load at greater than 90 percent of the maximum recorded operating load) were used to calculate all the short- term emission rate averages occurring in the data set that were analogous to short- term stack test averages; these periods are referred to as “surrogate stack tests” in this memo.DRAFT – DELIBERATIVE – NOT FOR DISTRIBUTION PRELIMINARY RESULTS, QA CHECKS NOT COMPLETED



### 2 5. All averaging periods calculated (30 - d ay, 60 - day, 90 - day, 180 - day, and 360 - day) excluded startup and shutdown periods. 6. For each averaging period anal yz e d , the variability ratio of [ the 99 th 

### percentile long - term averag e] to [ the 3 rd 

### percentile surrogate stack test value ] was calculated for each operating unit with a sufficient number of hourl y records to calculate at least one long- term period. These percentiles were used to eliminate outliers in the data sets. 7. The variability ratios for all units within a given averaging period data set were u sed to develop a general equation defining the relation ship between the 99th percentile long - term average and the near- minimum achieved surrogate stack test. The general form of the equation is presented as Equation 1: **[Equation 1]** y = Cx - z

Where y = the estimated long term emissions average x = the near - minimum short- term emissions average z = was a calculated exponent derived from all available CEMS hourly data. C = wa s a calculated coefficient derived from all available CEMS hourly data. 

### 8. For each averaging period anal yz ed, the general equation, developed in step 6, was used to transform short- term emissions data for each unit floor into an estimate of the 99 th 

### percentile long - term performance for the floor unit. The transformed estimates were calculated by inserting the minimum actual stack test data from each of the 47 units into the general equation from step 6. Appendix A of this memorandum only includes the two plots utilized to determine the equation for transforming MACT floor stack test averages to 30 - day averages. The attached spreadsheets contain the plots of all other averaging periods. 9. The upper predictive limit for each long - term average Hg emissions rate was calculated for the floor units using the equation from step 6 . Only the minimum test value (i.e., row 5 in the UPLspreadsheet) was used; all other stack test rows previously used to determine unitspecific variability

were excluded. **Conclusion** Table 1 presents the results of the anal ys is of what the Hg MACT floor for existing coal units would look like if EPA decides to promulgate a compliance period longer than 30 days. As shown in Table 1, the amount of data available for each averaging period analysis varied . For example, only

23 units had sufficient data to calculate at least one 360 - day average. Since the objective of this anal ys is was to compare achievable emissions rates based on the duration of theDRAFT – DELIBERATIVE – NOT FOR DISTRIBUTION PRELIMINARY RESULTS, QA CHECKS NOT COMPLETED



### 3 averaging period, the analysis used onl y the 23 units with sufficient data to calculate all averaging periods as a “control” to assess the impact of comparing the different data sets.

**Table 1 –**  **UP L’s Calculated with All Available Data**  **Average Period**  **Available CEMS Calculated UPL**  **(days) Data Sets**  **With All Available CEMS Data (lb Hg/MMBtu)**  30 1 87 1.11E - 06 60 83 1.01E - 06 90 77 9.13E - 07 180 66 8.04E - 07 360 23 7.60E - 07 

### To quantify the effect of the reduction in the count of available datasets with sufficient data as the averaging periods increase, the anal ys is also include s a series of UPL calculations using only the “control” data set. T able 2 presents a comparison of the calculated UPLs for each averaging period without the anal ytical artifact s caused b y the limited availability of very long - term (i.e., semi - annual and annual) CEMS data .

**Table 2 –**  **UP L’s Calculated with C**  **ontrol Data (23 Units Only) Average**  **Period Available CEMS**  **Calculated UPL (days)**  **Data Sets With Control CEMS Data**  **(lb Hg/MMBtu)** 30 2 23 1.32E - 06 60 23 1.13E - 06 90 23 1.03E - 06 180 23 9.17E - 07 360 23 7.60E - 07 

### The data in Table 2 confirms that an appropriate ratio between a 30 - day compliance period and a 360 - day compliance period is approximately 6 0 percent. This is c onsistent with the ratio

1 Note that the data set of 87 units utilized to derive the UPL of 1.11E - 06 is presented in Appendix A, Figure A - 1. 2 Note that the data set of 23 units utilized to derive the UPL of 1. 32 E - 06 is presented in Appendix A, Figure A - 2 .DRAFT – DELIBERATIVE – NOT FOR DISTRIBUTION PRELIMINARY RESULTS, QA CHECKS NOT COMPLETED



### 4 achieved b y San Juan Unit 4 based on the maximum averages recorded b y CEMS with no statistical variability

added.y = 1E - 06x - 0. 226 R2= 0 .9 806

0. 0E +00 2. 0E - 07 4. 0E - 07 6. 0E - 07 8. 0E - 07 1. 0E - 06 1. 2E - 06 1. 4E - 06 1. 6E - 06

0 50 100 150 200 250 300 350 400 x= Day s in A ve ragn g Per io d y= Avg lb s Hg/MMBtu by CEMS San Jua n Uni t 4 - OR IS Code 2451 Ma xi mum Ave rage s fo r 1 day to 360 day ave ragin g pe riod s.

**Figure 1**  **. -**  **San Juan Unit 4**  **Actual CEMS Data Averages**

### Appendix A **Typical Data Sets Used to Derive Average Data Sets**DRAFT – DELIBERATIVE – NOT FOR DISTRIBUTION PRELIMINARY RESULTS, QA CHECKS NOT COMPLETED



### 7 

### y = 0.0032x - 0. 521 

### R2 = 0. 7323

0. 0 20. 0 40. 0 60. 0 80. 0 100. 0 120. 0 140. 0

0. 0E +00 2. 0E - 06 4. 0E - 06 6. 0E - 06 8. 0E - 06 1. 0E - 05 1. 2E - 05 1. 4E - 05 1. 6E - 05 y= (3 0 DayR ol lin g Avg) /(6 hr CEMS Sur ro gate f or S tack Te st)

x= Surrogate Stac k Te st (lbs Hg/MMBtu) Fi gure A - 1: Re lat io nshi p Be tw een M in imu m Si ngl e Poi nt Stack Te sts an d 3 0 DayRo llin g Average s Bas ed o n Hg C EM S Data f or 87 Un it s



### 6h **r Surroga**  **te: 3**  **rd P**  **ercentile (0**  **.0 3)**  **30 Day**  **Ro llin**  **g Av** **g: 99th** **P ercentile**  **(0 .9**  **9) UPL**  **= 1.**  **1 E**  **- 06**  **lb s**  **Hg/MM Btu** DRAFT – DELIBERATIVE – NOT FOR DISTRIBUTION PRELIMINARY RESULTS, QA CHECKS NOT COMPLETED



### 8 y = 0. 0034x - 0. 528 R2 = 0. 8326

0. 0 20. 0 40. 0 60. 0 80. 0 100. 0 120. 0 140. 0

0. 0E +00 2. 0E - 06 4. 0E - 06 6. 0E - 06 8. 0E - 06 1. 0E - 05 1. 2E - 05 1. 4E - 05 1. 6E - 05 y= (3 0 DayR ol lin g Avg)/(6 hr CEM S Sur rogate f or Stack Te st)

x= Sur roga te Stac k Te st (lbs Hg/MMBtu) Fi gure A - 2: R el ati onshi p Be tw een Mi ni mum Si ngl e Poi nt Stack Te sts an d 30 DayRo llin g Ave rage s Bas ed o n Hg CEM S Data f or23



### 6h **r Surrogat**  **e: 3**  **rd P**  **ercen tile** **(0 .0** **3) 30**  **Day Rollin**  **g Av** **g: 99th**  **P ercentile**  **(0.99 )**  **UPL =**  **1. 32**  **E -**  **06 lb**  **s Hg/M**  **MBtu** 

# Control D ata Set - Sa me 23 Units Us ed in 360 DayA vera geA nalys is