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MEMORANDUM 

TO: Brian Shrager & Jim Eddinger, U.S. EPA 

FROM: Graham Gibson, ERG 

DATE: January 2011 

SUBJECT: Handling and Processing of Corrections and New Data in the EPA ICR Databases 

1.0 INTRODUCTION

This memorandum discusses the methods used to receive and process data corrections 

and new data into the EPA ICR databases. Corrections received included corrected emission test 

data, continuous emissions monitoring (CEM) data, fuel analysis data, unit-specific information 

(such as design capacity), and facility-specific information (such as source status). Data 

corrections were received for boilers in both the major and area source inventories, and the 

methods used to track those corrections are identical. Some data corrections were not processed 

into the database for various reasons detailed in this memorandum. No data corrections or 

additions received after November 17, 2010 were processed into the EPA database in order to 

finalize regulatory impacts analyses in the final rule. 

This memorandum is organized as follows: 

1.0 Introduction 

2.0 Sources of Data Corrections and New Data 

3.0 Processing the Corrections and New Data 

4.0 Outstanding Data Corrections 

5.0 References 

Appendix A: Summary of Outstanding Data Corrections 
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2.0 SOURCES OF DATA CORRECTIONS AND NEW DATA 

The majority of data corrections and new data were received via public comment 

submissions or by electronic mail (e-mail) requests sent to the ERG Combustion Survey address 

or EPA staff. Corrections and new data received before the start of the public comment period 

came exclusively to the Combustion Survey e-mail address. Most of the data corrections 

received via e-mail came from the respective facility. ERG conducted a review of several test 

reports prior to the end of the public comment period in June, 2010. Where discrepancies were 

found between the test report and what was reported in the ICR databases, the necessary 

corrections were made. The majority of corrections and new data received via the public 

comment period came from third party organizations such as trade groups or technical 

consultants that conducted an independent review of certain types of data. All data received 

through e-mail have been provided to the docket. Corrections to emission testing results for 

mercury (Hg) were the most prevalent among all received corrections. No data corrections or 

new data were considered after November 17, 2010 in order to finalize the databases and related 

analyses before the court-ordered deadline. 

The majority of the data corrections and new data received were for the database tables 

containing emissions testing or monitoring data, or fuel analysis data. Several new facilities 

were identified, and their respective boilers and process heaters were added to the inventory. 

Similarly, unit-specific corrections (such as fuels combusted or control devices) were received to 

units already in the inventory. Considering all corrections and new data received, EPA adjusted 

its database for 722 boilers and process heaters at major sources and 23 boilers at area sources. 

The EPA ICR database is described in detail in another memorandum.1

3.0 PROCESSING THE CORRECTIONS AND NEW DATA 

A coding system was created in order to track the data that had been added to or changed 

in the EPA ICR database. The coding system was implemented in the database tables containing 

emissions test data, continuous emissions monitoring data, fuel analysis data, and the overall 

inventory of major source boilers and process heaters. An alphabetic code pertaining to the type 

of correction made to the data was attributed to each database row where a change occurred 
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along with an explanation of the corrections in an accompanying database field. Alphabetic 

codes were used to allow for easy sorting of the corrected data and avoided the need for a 

separate file or set of files to track all received data corrections and new data. The specific codes 

used and their descriptions are shown in Table 1. 

Table 1 – Change Codes for Denoting Data Corrections and New Data 

Change Code Description 

A Added new data. 

C Change in reported control device(s). 

D Change in combustor design. 

E Change in emission values. This includes changes 

to the reported values and/or units of measure. 

F Change in reported fuel information. 

I Change in sample ID. 

M Change in test method. 

N Change in non-detect documentation. 

P Change in pollutant name. 

S Change in source status. 

U Change in unit ID. 

X Change in classification. 

Z Miscellaneous changes. 

The coding system involved adding two separate fields to each database table. The first 

field, titled “Change Code,” contained one or more of the specific codes listed in Table 1. The 

second database field, titled “Reason for Change,” contains the date and a brief description of the 

changes made. If more than one correction was made to a row in a database table, multiple 

codes are present in the “Change Code” field (separated by a comma) and separate explanations 
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are provided in the “Reason for Change” field. For example, if one row attributed to emission 

test data required changes to the reported fuel combusted and control device employed, the 

“Change Code” field contains “C, F.” The “Reason for Change” field would contain 

nomenclature describing that both the fuel and control device information was changed. If the 

two separate changes occurred on separate dates, each description would be preceded by the date 

the change was made. 

4.0 OUTSTANDING DATA CORRECTIONS 

Several data corrections did not get processed in the EPA database for one of multiple 

reasons. A list of those specific corrections and the reasons why the corrections were not 

implemented into the EPA ICR database can be found in Appendix A. 
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5.0 REFERENCES 

1. Alvis, J. and C. Burlew, ERG. Development of the Emissions Test Database for the 

Industrial/Commercial/Institutional Boilers and Process Heaters National Emission Standard 

for Hazardous Air Pollutants. October 2002. See Docket ID EPA-HQ-OAR-2002-0058-0018. 

2. Survey Database containing Results of the 2008 Questionnaire for Boilers, Process Heaters, 

& Other Combustion Units (ICR No. 2286.01) (version 2) 

3. Emissions Database for Boilers and Process Heaters Containing Stack Test, CEM, & Fuel 

Analysis Data Reported under ICR No. 2286.01 & ICR No. 2286.03 (version 6) 
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APPENDIX A 

SUMMARY OF OUTSTANDING DATA CORRECTIONS 
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Table A-1: Summary of Outstanding Data Corrections 

Source FacilityID or Parent Company CombustorID Specified Changes and Reason f

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2793.3 & 

EPA-HQ-OAR-2002-

0058-2830.1) 

MSDuPontDeLisle1342 AF-103 (BLR-1342) 

Facility submitted additional NOx CEMS conversion from pdf to Excel format via elcontained errors due to poor quality of the not clarified due to the fact that the NOx Cpaired with any other pollutant and thus Nanalyzed in this rulemaking process. 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2863.1) 

Hovensa Refinery, St, 

Croix, US Virgin 

Islands 

n/a 

This facility was not included in the major 

during rule proposal. A Title V Operating was requested from the commenter and froorder to obtain a list of applicable combustAttainment of operating permit data for thiuntil late November, 2010, at which point were finalized. 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2883.1) OHMortonSaltRittman n/a 

Coal fuel analysis data for mercury and chin graphical format. An e-mail was sent to the fuel analysis data in non-graphical formentered into the database, but no response 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2702.1) Council of Industrial Boiler Owners (CIBO) n/a Comments pointed out specific types of da

were needed, but no specific facilities were 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2792.1) American Chemistry Council (ACC) n/a Comments pointed out specific types of da

were needed, but no specific facilities were 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2845.1) National Association of Manufacturers (NAM) n/a Comments pointed out specific types of da

were needed, but no specific facilities were 
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Source FacilityID or Parent Company CombustorID Specified Changes and Reason f

Public Comment 

(DCN: EPA-HQ-OAR2006-0790-2137.1) 

The Clean Air 

Association of the 

Northeast States 

(NESCAUM) 

n/a 

Fuel analysis data for metallic HAP from #residual oils were reported, but could not b

specific facility. Thus, the data cannot be 

Public Comment 

(DCN: EPA-HQ-OAR2002-0058-2783.1) FLSmurfit-Stone n/a Facility states that data corrections were su

those corrections were never received.