1 MEMORANDUM
TO: Brian Shrager & Jim Eddinger, U.S. EPA
FROM: Graham Gibson, ERG
DATE: January 2011
SUBJECT: Handling and Processing of Correc tions and New Data in the EPA ICR Databases

1.0 INTRODUCTION

This memorandum discusses the methods used to receive and proce ss data corrections
and new data into the EPA ICR databases. Correc tions received included corrected emission test data, continuous emissions monitoring (CEM) data, fuel analysis data, unit-specific information (such as design capacity), and f acility-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 identi cal. 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 pr ocessed 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 Corrections2 2.0 SOURCES OF DATA CORRE CTIONS AND NEW DATA

The majority of data corrections and ne w data were received via public comment submissions or by electronic mail (e-mail) request s sent to the ERG Comb ustion Survey address
or EPA staff. Corrections and new data receive d before the start of the public comment period came exclusively to the Combustion Survey e-ma il address. Most of the data corrections
received via e-mail came from th e respective facility. ERG conduc ted 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 repo rted in the ICR databases, the necessary corrections were made. The majority of corr ections and new data received via the public comment period came from third party organiza tions such as trade groups or technical
consultants that conducted an inde pendent 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 m onitoring 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 co mbusted or control device s) were received to units already in the inventory. Considering all correc tions and new data received, EPA adjusted its database for 722 boilers and pr ocess heaters at major sources a nd 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 wa s implemented in the database tables containing emissions test data, continuous emissions monito ring data, fuel analysis data, and the overall inventory of major source boilers and process heater s. An alphabetic code pertaining to the type
of correction made to th e data was attributed to each da tabase row where a change occurred3 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 Denoti ng 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 an d/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,” contai ned one or more of the specific codes listed in Table 1. The second database field, titled “Reaso n 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 (s eparated by a comma) and separate explanations4 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.” Th e “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 data base can be found in Appendix A.5 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)6 APPENDIX A

SUMMARY OF OUTSTAND ING DATA CORRECTIONS7Table A-1: Summary of Outstanding Data CorrectionsSourceFacilityID or ParentCompanyCombustorIDSpecified Changes and Reason for No ChangePublic Comment(DCN: EPA-HQ-OAR2002-0058-2793.3 &EPA-HQ-OAR-2002-0058-2830.1)MSDuPontDeLisle1342AF-103(BLR-1342)Facility submitted additional NOx CEMS data in pdf format. Theconversion from pdf to Excel format via electronic softwarecontained errors due to poor quality of the pdf. The errors werenot clarified due to the fact that the NOx CEMS data was notpaired with any other pollutantand thus NOx data was notanalyzed in this rulemaking process.Public Comment(DCN: EPA-HQ-OAR2002-0058-2863.1)Hovensa Refinery, St,Croix, US VirginIslandsn/aThis facility was not includedin the major source inventoryduring rule proposal. A Title V Operating Permit for the facilitywas requested from the commenter and from EPA Region 2 inorder to obtain a listof applicable combustionunits at the facility.Attainment of operating permit data for this facility did not occuruntil late November, 2010, at which point all impacts analyseswere finalized.Public Comment(DCN: EPA-HQ-OAR2002-0058-2883.1)OHMortonSaltRittman n/aCoal fuel analysis data for mercury and chlorine were submittedin graphical format. An e-mail was sent to the facility requestingthe fuel analysis data in non-graphical format so that it could beentered into the database, but no response was received.Public Comment(DCN: EPA-HQ-OAR2002-0058-2702.1)Council of IndustrialBoiler Owners (CIBO)n/aComments pointed out specific types of data corrections thatwere needed, but no specificfacilities were identified.Public Comment(DCN: EPA-HQ-OAR2002-0058-2792.1)American ChemistryCouncil (ACC)n/aComments pointed out specific types of data corrections thatwere needed, but no specificfacilities were identified.Public Comment(DCN: EPA-HQ-OAR2002-0058-2845.1)National Association ofManufacturers (NAM)n/aComments pointed out specific types of data corrections thatwere needed, but no specificfacilities were identified.8SourceFacilityID or ParentCompanyCombustorIDSpecified Changes and Reason for No ChangePublic Comment(DCN: EPA-HQ-OAR2006-0790-2137.1)The Clean AirAssociation of theNortheast States(NESCAUM)n/aFuel analysis data for metallic HAP from #2 distillate and #6residual oils were reported, but could not be attributed to anyspecific facility. Thus, the data cannot be used in any analyses.Public Comment(DCN: EPA-HQ-OAR2002-0058-2783.1)FLSmurfit-Stone n/aFacility states that data corrections were submitted to EPA, butthose corrections were never received.