Eastman CISWI Petition Supplement

EPA-HQ-OAR-2003-0119

January 21, 2013

Page 1 of 14

Eastman Chemical Company

Supplemental Submittal 

To Petition for Reconsideration, Amendment, and Administrative Stay of

Commercial and Industrial Solid Waste Incineration Units (78 Fed. Reg. 9112)

Introduction: Eastman Chemical Company (Eastman) operates three of the four coal-fired energy 

recovery units (ERUs) in the Commercial and Industrial Solid Waste Incineration Units (CISWI) final rule’s

coal-ERU subcategory. See generally Commercial and Industrial Solid Waste Incineration Units: 

Reconsideration and Final Amendments, 78 Fed. Reg. 9112 (Feb. 7, 2013). Eastman’s three boilers 

(boiler numbers 18, 19, and 20) are identical boilers, burn the same coal and waste, and are identified 

by the U.S. Environmental Protection Agency (EPA) in the CISWI final rule as the coal-ERU subcategory 

top performers. 

It is well settled that the EPA must set the maximum achievable control technology (MACT) floor for 

pollutants regulated under Clean Air Act Sections 112 and 129 at levels that the top performing unit can 

meet “every day and under all operating conditions.” Mossville Environmental Action Now v. EPA, 370 

F.3d 1232, 1242 (D.C. Cir. 2004)(Mossville); see also National Association of Clean Water Agencies v. 

EPA, 734 F.3d 1115, 1134-1135 (D.C. Cir. 2013)(NACWA). As more fully described below, EPA erred in 

setting the CISWI coal-ERU MACT floor for hydrogen chloride (HCl), sulfur dioxide (SO2) and nitrogen 

oxide (NOx) at levels Eastman’s top performing coal-ERUs cannot meet “every day and under all 

operating conditions.” Accordingly, these standards are unlawful and are highly likely to be remanded 

by the United States Court of Appeals for the District of Columbia Circuit in line with the court’s 

Mossville and NACWA decisions. 

On April 5, 2013, Eastman submitted a petition to EPA to reconsider, amend, and administratively stay 

the effective date of the offending provisions in EPA’s CISWI final rule. To date, EPA has neither 

administratively granted nor denied Eastman’s petition. Eastman much prefers to work with EPA to 

resolve these issues without further litigation. To that end, Eastman submits this document and the 

accompanying data to supplement its petition, respectfully requests that EPA grant this petition and 

correct the CISWI final rule.

Issue One - Fuel Variability Factors: As fully explained in our petition, after repeated requests to include 

fuel variability in the setting of MACT floor emission standards for the coal ERUs subcategory, EPA has 

to-date not done so. As we will further explain here, EPA’s logic for this decision is flawed and two of 

the resulting MACT floor standards are unlawful.

Five of the CISWI pollutants are fuel dependent. Those are: cadmium, lead, mercury, HCl, and SO2. For 

each of these five, one of Eastman’s boilers (18, 19, or 20) has been identified by EPA as the top 

performer in the coal ERU subcategory. Each of these three is an identical stoker boiler equipped with 

an electrostatic precipitator (ESP) and no air pollution control device to remove acid gases (HCl and 

SO2). Cadmium and lead are very effectively removed by the ESPs. Mercury has some nominal removal 

efficiency via the ESPs.
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January 21, 2013

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It is important to note that, for cadmium, lead, and HCl, MACT floor standards were based on one stack 

test. Mercury’s standard was based on two stack tests. The SO2 standard was based on seven days of 

CEMS data provided by Eastman. Thus, these standards are based on very short-term periods while coal 

is proven to have variable levels of each of these contaminants (cadmium, lead, mercury, chlorine, and 

sulfur). Data provided by Eastman during the comment period on the June 4, 2010 proposed rule and 

supplemented with additional data in this submittal, proves beyond a doubt that this is true for the top 

performers (Eastman’s boilers) in the CISWI coal-ERU subcategory.

In its response to comments on the December 23, 2011 reconsideration proposed rule, EPA stated the 

following in response to Eastman’s request to apply fuel variability factors:

“Furthermore, our analysis indicates that the best performing sources in this subcategory, which 

are operated by the commenter, are able to meet the final emission limits, which indicates that 

we have adequately accounted for variability when establishing the emission limits for this 

subcategory.” 

EPA Summary of Public Comments and Responses for Commercial and Industrial Solid Waste Incineration 

Units: Final Rule Volume 1: CISWI, December 2012 at 185 (Document Control No. EPA-HQ-OAR-2003-

0119-2686, pages 185-186). After further evaluation, Eastman agrees the emission limits set by EPA for 

cadmium, lead, and mercury adequately account for variability of these contaminants in our coal supply. 

We believe this is because (1) there was variability among the test runs (2) cadmium is not normally 

detected in our coal supply (3) lead is very well controlled by the ESPs, and (4) mercury is partially 

controlled by the ESPs.

However, EPA’s conclusions are flawed with regard to HCl and SO2, the two pollutants for which the top 

performers have no air pollution control equipment and for which the emissions are totally dependent 

on the fuel content. The following discussion will explain why this is true and how EPA can lawfully

remedy the flaw for each of the two pollutants.

Hydrogen chloride: Figure 1 shows how EPA determined the HCl emission standard for coal 

ERUs. The standard was based on one performance test (with three runs) for Eastman’s Boiler 20. The 

chlorine in the coal during this test is calculated as an average of 80 ppm, a relatively low chlorine level 

for the coal Eastman burns – Central Appalachian coal.
Eastman CISWI Petition Supplement

EPA-HQ-OAR-2003-0119

January 21, 2013

Page 3 of 14

Figure 1

EPA MACT Floor Determination for HCl – Coal ERUs

Reference: Appendix C to memorandum from ERG to EPA dated November 16, 2012: “CISWI Emission Limit Calculations for 

Existing and New Sources for the Reconsideration Final Rule” (Docket ID EPA-HQ-OAR-2003-0119-2662)

Figure 2 below superimposes the chlorine content of the coal burned during the performance test 

conducted in November 2004 onto the graph of historical chlorine content measured in Eastman’s coal 

supply for this powerhouse since 2004. It is apparent from this graph that coal burned during the 

performance test was at the very low end of the range for chlorine content compared to the historical 

ranges. The data from which this graph was drawn is included with this submittal as attached Excel file 

“Eastman Coal Sulfur and Chlorine Data 2005-2013.xls”.

Using standard EPA conversion factors, we estimate that, for eastern bituminous coal having a heating 

value of 13,100 Btu/lb, burned in boilers such as Eastman’s with no HCl reduction device, 13 ppmvd HCl 

in the exhaust gas would be caused by coal having a chlorine content of 230 ppm. Again, looking at 

Figure 2, it is clear there are many shipments of coal that Eastman’s top performing boilers have burned 

that have chlorine contents at or above 230 ppm.

Facility Name Unit ID Pollutant Run No. Flag N D Raw Data ND < Avg Ln-transformed Data

TNEastman_NO_CBIDATA Boiler 20 Hydrogen Chloride (HCl) TNEastman_NO_CBIDATA-20-HCLT1bR1 0 4.67311004 N/A 1.541824811

TNEastman_NO_CBIDATA Boiler 20 Hydrogen Chloride (HCl) TNEastman_NO_CBIDATA-20-HCLT1bR3 0 6.23081338 N/A 1.829506883

TNEastman_NO_CBIDATA Boiler 20 Hydrogen Chloride (HCl) TNEastman_NO_CBIDATA-20-HCLT1bR2 0 4.93272726 N/A 1.595892032

Sample Size 3 3

Non-detects 0 0

Average 5.27888 1.66

Median 4.93273 1.60

Standard Deviation 0.83455 0.15

Minimum 4.67311 1.54

Maximum 6.23081 1.83

Skewness 1.55 1.49

SE Skewness 1.41 1.41

Skewness Test Normal Normal

Kurtosis #DIV/0! #DIV/0!

SE Kurtosis 2.83 2.83

Kurtosis Test #DIV/0! #DIV/0!

99.0% t-statistic for UL 4.54 4.54

99.0% UL 9.0683 10.49

99.0% t-statistic for UPL 6.96 6.96

99.0% UPL 10.0246 12.4932
Eastman CISWI Petition Supplement

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January 21, 2013

Page 4 of 14

Figure 2

Chlorine Content Variability

Coal Supply to Boilers 18, 19, 20

2004 - 2013

For exactly the same reasons the agency included fuel variability factors (FVFs) in the MACT floors for 

mercury and HCl for solid fuel boilers in the Boiler MACT final rule, EPA must develop and apply similar 

FVFs for the CISWI coal ERU subcategory. In the Boiler MACT, EPA decided to use the average fuel 

variability ratio, rather than the maximum ratio, as explained in the following excerpt from the Revised 

MACT Floor Analysis (August 2012) memorandum from ERG for the Boiler MACT:

“Fuel analysis variability was calculated using the same methods and assumptions used in the 

previous analysis with one exception. For the solid fuel subcategory the March 2011 final rule 

and reconsideration proposal did not adopt a fuel variability factor in the MACT floor emission 

limit. However, in response to petitions for reconsideration on this issue and the public 

comments received on the solid fuel subcategory a fuel variability factor was adopted in this 

analysis for the amended final rule, where data was available. Given that the solid fuel category 

does exhibit some heterogeneous fuel make-up amongst the top performing units, the EPA 

adopted the average fuel variability ratio for each pollutant instead of the maximum fuel 

variability ratio. This average value, calculated from only those fuel samples where the FVF ratio 

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ppm

Chlorine content during

top performer stack test

230 ppm chlorine coal ~ 13 ppmvd CISWI Coal ERU HCl Limit

1520 ppm chlorine coal ~ 86 ppmvd CISWI ERU HCl Limit

FVF = 6.6
Eastman CISWI Petition Supplement

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January 21, 2013

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was greater than one, was selected to not overestimate fuel variability for a subcategory that 

has a mix of biomass, coal, and other solid fossil stack test data factored into the 99% UPL 

calculations, but it recognizes that some additional fuel variability is present in the best 

performing units that may not be represented by the stack test data alone. While the 99% UPL 

calculation incorporates variability between test runs resulting from variability in measurements, 

unit operations, and control device operations and performance, the FVF ratio incorporates 

variability in fuel feedstocks that occur at best performing units during periods not covered by 

the stack tests. The FVF ratio, as described in previous memoranda, compares the fuel 

constituents during the test with the fuel constituents during other periods of operation in order 

to evaluate the full range of fuels consumed by these best performing units.”

In the CISWI context, since there is only one top performer and no mix of top performers as in Boiler 

MACT, the maximum FVF should be used so that any stack test at any operating condition (fuel 

variations) at the top performing unit will be in compliance. 

Eastman notes that since there is no control device to monitor that assures compliance with an HCl limit 

on our coal ERUs, that the compliance method would most likely be material balance. Even considering 

that the CISWI rule specifies a 30 day rolling average for compliance demonstration, the 230 ppm 

equivalent allowable chlorine content is not adequate for the top performer to meet every day under all 

operating conditions. This is evident from Figure 3 below where we have graphed both the monthly 

average coal chlorine content and superimposed the 230 ppm chlorine line. 

Using EPA’s Boiler MACT methodology, we have calculated FVFs for chlorine using two different 

datasets. EPA’s Boiler MACT methodology is summarized by the following steps: (1) determine chlorine 

concentration in coal during the top performer’s stack test; (2) determine the ratio of the concentration 

of chlorine in each coal sample from the top performer’s historical dataset divided by the result from 

step (1); (3) remove from the dataset as an outlier any ratio above the mean plus three standard 

deviations; (4) set the FVF as the highest remaining ratio. In the first analysis, we determined the FVF 

from the dataset of ratios of each individual coal sample chlorine concentration is 6.6, reflecting the 

substantial variability of chlorine in the coal supply over time. In the second analysis, we determined 

the FVF from the dataset of ratios of the monthly average chlorine concentrations is 3.6, reflecting a 

dampened variability and matching up with the 30 day average compliance periods for material balance 

calculations. We have included those FVF calculations in the attached Excel file “Coal ERU FVFs.xls”. We 

have shown the equivalent coal chlorine contents calculated applying these FVFs on both Figure 2 (for 

the individual samples’ analyses) and Figure 3 (for the monthly average analyses). The FVF based on the 

individual samples is used for Figure 2 since it would be appropriate if the averaging time were 3 hours. 

The FVF based on the monthly averages is used for Figure 3 since it would be appropriate for a 30 day 

rolling average. The latter of these two methods is recommended since in this case the top performer 

has no control device for HCl and would use material balance as the compliance method. The revised 

HCl emission limit would be 47 ppmvd.
Eastman CISWI Petition Supplement

EPA-HQ-OAR-2003-0119

January 21, 2013

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Figure 3

Sulfur dioxide (SO2): Figure 4 below shows the CEMS hourly emissions data from which the 

MACT floor emission standard for SO2 was set. These data were provided by Eastman in response to 

EPA’s 2009 Information Data Collection (ICR) survey. Knowing we have a variable coal supply, we 

voluntarily supplied data from a temporary SO2 CEMS from a one week period rather than conduct a 

single stack test as requested by EPA. Since coal shipments are received for this powerhouse 

approximately once a week, there were only two different shipments (one with a sulfur content of 0.88 

percent and the other with a sulfur content of 0.91 percent) burned during this 7 day period. 

Accordingly, the SO2 emissions did not vary significantly over this one week period. 

Figure 5 below shows the historical data for sulfur content in Eastman’s coal supply. Shown also on this 

chart is the average sulfur content (0.9 percent) that resulted in the 650 ppmvd emission limit. These

data were submitted in our comments in 2010 and we have extended the data set into 2013 for this 

submittal. The data from which this graph was drawn are included with this submittal as attached Excel 

file “Eastman Coal Sulfur and Chlorine Data 2005-2013.xls”.

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Adjustment to Coal ERU HCl Limit

Using Fuel Variability Factors

Monthly Average Cl

230 ppm Chlorine in Coal ~ 13 ppmvd CISWI Coal ERU Emission Limit (99% UPL)

830 ppm chlorine in coal ~ 47 ppmvd CISWI Coal ERU Emission Limit

FVF = 3.6
Eastman CISWI Petition Supplement

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January 21, 2013

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As can be seen from Figure 5, a 650 ppm standard would not be adequate to cover this top performer’s 

emissions every day under all operating conditions. Similarly to our presentation above for HCl, we also 

include Figure 6 to show that at even a 30 day average, a 650 ppm standard is not adequate.

As discussed above for HCl, FVFs need to be developed and applied so that the emission standard will 

adequately cover the fuel variability experienced by the top performer. As we have done for HCl, we 

have determined the FVF ratios and included those calculations in the attached Excel file “Coal ERU 

FVFs.xls”. The FVF using the individual coal samples is 1.3 and the FVF using the monthly averages is 1.2. 

As in the HCl analysis, the latter of these two methods is recommended for SO2 since in this case the top 

performer has no control device for SO2 and would use material balance as the compliance method. 

The revised SO2 emission limit would be 780 ppmvd.
Eastman CISWI Petition Supplement

EPA-HQ-OAR-2003-0119

January 21, 2013

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CEMS SO2 Hourly Averages (ppm)

Figure 4

Eastman SO2 Hourly Averages

August 23 - 30, 2009

Hours Aug 23 - 30, 2009

CISWI Coal ERU Limit
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EPA-HQ-OAR-2003-0119

January 21, 2013

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Figure 5

Sulfur Content Variability

Coal Supply to Boilers 18, 19, 20

2004 - 2013

% Sulfur

0.9% Sulfur Content During 7

Day MACT Floor Period

CISWI Limit Adjusted for FVF =1.3
Eastman CISWI Petition Supplement

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January 21, 2013

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Figure 6

Issue Two - MACT Floor Analysis: As explained in our petition, Eastman is concerned that EPA’s MACT 

floor analysis does not fully account for actual operating conditions of the top performers when the 

units are not combusting solid waste. More specifically, Eastman is concerned that the NOx emission 

standard set for coal ERUs in Table 7 of the final rule does not meet the requirements of section 

129(a)(2). 

For the coal ERU subcategory, Eastman’s Boiler 18 was identified by EPA as the top performer and, in 

fact, is the only unit in this very small subcategory for which EPA has NOx emission data in its CISWI 

database. Eastman provided the data from which the MACT floor was established in response to EPA’s 

2009 ICR request. Rather than provide data from just one performance stack test as requested by EPA, 

Eastman voluntarily operated a temporary NOx CEMS for a one week period from August 23 – 30, 2009 

and submitted hourly average concentrations corrected to 7 percent oxygen. EPA used this data to set a 

MACT floor based emission standard of 340 ppmvd (corrected to 7 percent oxygen). 

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Adjustment to Coal ERU SO2 Limit

Using Fuel Variability Factors

Montly Average % Sulfur

0.9 % Sulfur in Coal ~ 650 ppmvd CISWI Coal ERU Limit

1.1% Sulfur in Coal ~ 780 ppmvd CISWI Coal ERU Limit

FVF = 1.2
Eastman CISWI Petition Supplement

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January 21, 2013

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As we were planning this data collection, during consultation with the former EPA CISWI rule-writer, we 

were instructed not to submit data from periods when the boiler was not burning solid waste. These 

three coal-fired boilers, along with four other coal-fired boilers in the same powerhouse that are 

permitted as RCRA hazardous waste treatment units (and, thus exempt from definition as CISWI 

affected units), combust coal along with, at times, a solid waste (biosolids from Eastman’s on-site 

biological industrial wastewater treatment facility). However, the three CISWI units (Boilers 18, 19, and 

20) only burn the solid waste during a small percentage of their operating hours. Since two of the other 

four boilers are equipped with NOx CEMS (since they are part of the EPA’s NOx Trading Program in 40 

CFR Part 96), Eastman was aware that the combustion of the biosolids along with coal results in a 

suppression of NOx emissions due to the high moisture content (approximately 12 percent) of the 

biosolids. For this reason, we were concerned that if Boilers 18, 19, and 20 were identified as top 

performers by EPA, a MACT floor determination using just data derived from periods of combustion of 

solid waste would not reflect emissions of these top performers during the coal-only mode of operation. 

However, we followed EPA’s instructions and did not collect NOx data during the coal-only mode of 

operation. 

Understanding this could be a problem, Eastman included in our comments to the June 4, 2010 

proposed rule a request that EPA allow a CISWI unit to comply with Boiler MACT (40 CFR 63 Subpart 

DDDDD) during periods when solid waste is not combusted (see page 16 of Eastman comments dated 

August 23, 2010) similar to provisions in the Hazardous Waste Combustor MACT1. We cited our 

example of differing NOx emissions during the two modes of operation in our comments. EPA did not 

adopt our suggestion in the March 21, 2011 final rule but did include new provisions to switch from 

CISWI to Boiler MACT, but only after 6 months have passed since ceasing to burn solid waste. EPA’s 

reasoning for allowing only limited rule switching is stated at 76 FR at 15714:

“EPA acknowledges that sources may stop and start burning solid waste in their combustion 

units, and that regulatory procedures are necessary to guide sources through the changes in 

applicability that may result due to a switch in combustion materials. New provisions in the final 

rule account for the fact that facilities may start and stop burning solid waste and ensure that 

any resulting changes in applicability between section 129 and section 112 rules do not occur 

with so much frequency that sources are unable to demonstrate continuing compliance with the 

applicable standards. To ensure that frequent switching does not impede our ability to 

determine continuous compliance and create undue permitting and testing burdens, sources 

remain subject to CISWI for a minimum of six months.”

Unsatisfied with these changes, numerous petitioners requested reconsideration of this issue, EPA

granted reconsideration and accepted comments during the comment period on the December 23, 2011 

 

1

Throughout the rulemaking process Eastman and other commenters have reminded EPA of the precedent set in the Hazardous Waste Combustor MACT that allows those 

units to comply with otherwise applicable requirements during periods when hazardous waste is not in the unit. In fact, EPA discussed this provision in multiple Federal 

Registers (see e.g. 64 Fed. Reg. 52828, 52904 (Sept. 30, 1999), 66 Fed. Reg. 35090, 35145 (July 3, 2001), 67 Fed. Reg. 6968, 6979 (Feb. 14, 2002), 69 Fed. Reg. 21198, 21203 

(April 20, 2004), and 70 Fed. Reg. 54498, 54499 (Oct, 12, 2005)) and has maintained the position that a unit can remain subject to one MACT standard (e.g. HWC MACT), but 

comply with otherwise applicable requirements in either section 112 or 129, while remaining a MACT affected source.
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reconsideration proposed rule (see 76 FR at 80458). Trade Associations, including the American 

Chemistry Council and the Council of Industrial Boiler Operators (Eastman is a member of both) 

repeated urgings for EPA to allow units to frequently switch back-and-forth between CISWI and Boiler 

MACT. EPA made no changes to these provisions and repeated its concerns about frequent switching 

and associated compliance burdens and enforcement concerns. EPA also rationalized erroneously in its 

response that the HWC MACT approach should not be adopted because it only involves switching 

between standards promulgated pursuant to section 112 when clearly the rule language says sections 

112 or 129 of the Clean Air Act (see EPA Summary of Public Comments and Responses for Commercial 

and Industrial Solid Waste Incineration Units: Final Rule Volume 1: CISWI, December 2012 at 185 

(Document Control No. EPA-HQ-OAR-2003-0119-2686, pages 50 - 53).

Eastman raises these points because if EPA had allowed frequent switching, we would not have an issue 

with the promulgated NOx emission standard. Since we have the need to burn solid waste in these 

boilers only on a periodic basis, the moment we stop burning solid waste we will not be able to comply 

with the NOx emission limit and the standard switching provision requires that we remain subject to 

CISWI for six months. Under these circumstances, the CISWI coal ERU NOx emission standard is 

unlawful because the top performer cannot comply “every day under all operating conditions.”

Therefore, Eastman requests that the NOx emission standard be such that the top performers (Boilers 

18, 19, and 20) can comply under both the coal-only operating condition as well as the coal and waste 

operating condition. Since EPA previously declined to accept NOx data from periods when Eastman’s 

top performing coal ERUs were burning coal only (and no solid waste), Eastman is now submitting these

NOx data so that EPA may establish a lawful MACT floor for that constituent.

From May 3 – June 10, 2013, Eastman operated a temporary NOx CEMS on Boiler 20, the only boiler of 

the three available during this time frame. Since Boilers 18, 19, and 20 are identical, these data are

representative of any of the three. The boiler was operated at various steam loads and included periods 

under both modes of operation (coal only and coal plus biosolids). The raw hourly data is included in an 

attached Excel file titled “Eastman Boiler 20 NOx Data May-June 2013.xls” and a quality assurance 

document to accompany the data is included as Appendix A. Using EPA’s methodology for setting MACT 

floors, Eastman included another spreadsheet with the resulting emission limit (titled “Eastman Boiler 

20 NOx MACT Floor Determination.xls”). Using all the data from this period, the NOx limit would be 480 

ppmvd (corrected to 7 percent oxygen). 

Figures 7 and 8 are shown below to illustrate the differences in NOx emissions with and without burning 

solid waste (biosolids) and at various steam loads. These graphs clearly demonstrate that Eastman’s top 

performer cannot comply with the emission standard every day under all operating conditions. Further, 

they demonstrate that because it is not possible to even introduce the biosolids to the combustion 

chamber below a minimum steam load, it is not possible to comply and operate the boiler to meet 

operational needs even if we could burn the solid waste at all times. 
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Figure 7

Eastman Coal ERUs

NOx Corrected to 7%O2 vs Steam Load

Minute Data from ICR Data and May 3 - June 10, 2013

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NOX ppmvd@ 7% O2

Steam Load, kpph

NOx @ 7% O2 WITH Burning

Waste

NOx @ 7% O2 WITHOUT

Burning Waste

ICR Data (WITH Burning Waste)

Current NOx Limit

Cannot burn waste 

below 100 kpph
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Figure 8

Eastman Coal ERUs

NOx Corrected to 7%O2 vs. Steam Load

Hourly Average Data from May 3 – June 10, 2013

Conclusion: For the foregoing reasons, Eastman respectfully requests that EPA grant its petition to 

reconsider, amend, and administratively stay the effective date of the offending provisions in EPA’s 

CISWI final rule so that the agency can reset the CISWI coal-ERU MACT floor for HCl, SO2 and NOx at 

levels that Eastman’s top performing units can meet “every day and under all operating conditions.” 

Based on the data provided in this document, the HCl emission standard should be changed to 47 

ppmvd, the SO2 emission standard should be changed to 780 ppmvd, and the NOx emission standard 

should be changed to 480 ppmvd.

Enclosures:

Excel file: Eastman Coal Sulfur and Chlorine Data 2005-2013.xls

Excel file: Coal ERU FVFs.xls

Excel file: Eastman Boiler 20 NOx Data May-June 2013.xls

Appendix A: NOx CEMS Quality Assurance Document

Excel file: Eastman Boiler 20 NOx MACT Floor Determination

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NOX ppmvd @ 7% O2

Steam Load, kpph

NOXCORR (with

sludge)

NOXCORR (no sludge)

Calculated New NOx Limit (480 ppmvd)

Current NOx Limit (340 ppmvd)