# Final Portland Cement

Reconsideration

Technical Support Document

December 20, 2012i 

## Table of Contents

1. Introduction

................................ ................................ ................................ ......................... 1

2. Impacts of Revised PM Standard

................................ ................................ ........................ 1

3. Cost of Final 2012 Portland Cement Reconsideration Rule

................................ ............... 1

3.1 Revised Emission Standards for oHAP Alternative (for THC) and PM

................ 1

3.2 CPMS Compliance Demonstration

................................ ................................ ......... 3

3.3 Inline Coal Mill Testing

................................ ................................ .......................... 4

3.4 Open Clinker Storage Pile Work Practices

................................ ............................. 4

3.5 Summary of Costs

................................ ................................ ................................ ... 4

4. Final MACT Floor Limits

................................ ................................ ................................ ... 8

5. Beyond the Floor Analysis for PM and Mercury

................................ ................................ 8

5.1 PM

................................ ................................ ................................ ........................... 8

5.2 Mercury

................................ ................................ ................................ ................... 9



## List of Tables

Table 1. Summary of Industry Cement Plant Timeline Compliance Assessments Survey

........... 5

Table 2. Kiln s, for Which Potential Cost Savings Can be Estimated, by Pollutant Resulting
from Revised Control Strategy

................................ ................................ ........................... 6

Table 3. Number and Percentage of Kilns Affected by Revised Control Strategies for Which
Cost Savings Can be Estimated

................................ ................................ .......................... 6

Table 4. Cost Savings for ea ch Revised Control for a 650,000 TPY Kiln and Nationwide Cost
Savings a



### ................................ ................................ ................................ ............................... 7

Table 5. Capital and Annual Cost for Clinker Pile Enclosures (50,000 ton capacity)

................... 7

Table 6. Annual Cost Savings for Clinker Pile Enclosures

................................ ............................ 8

Table 7. Summary of Annual Costs of Final Amendments to Portland Cement NESHAP and

NSPS a



### ................................ ................................ ................................ ................................ .. 8

Table 8. Summary of 2012 Final NESHAP for Existing Sou rces

................................ ................ 11

Table 9. Summary of 2012 Final NESHAP for New Sources

................................ ...................... 111 

## 1. Introduction

Since the proposal (77 FR42368, July 18, 2012), new information was provided to EPA that required re

- evaluation of the impacts and cost savings resulting from the revised standards. Specifically, industry demonstrated that the Lehigh Union Bridge kiln was not a CISWI kiln (it was previously identified by EPA at proposal as CISWI). In their public comments, the cement industry also provided a survey of cement plants addressing the anticipated changes in compliance control strategies that might result from revisions in the PM and alternative organic HAP (oHAP) standards (see Docket item EPA

- HQ

- OAR

- 2011

- 0817

- 0505

- A5)

.



## 2. Impacts of Revised PM Standard

The amended rule revised the PM limit for existing sources from 0.04 lb/ton clinker to 0.07

lb/ton clinker. The PM limit for new sources also is changed to 0.02 lb/ton clinker from 0.01 lb/ton clinker. Compliance with the final PM standard is measured on a 3

- run Method 5 performance test rather than on a 30

- day basis with a CEMS. The changes in the PM standards,

wh ile not considered significant in absolute terms

, may result in a small increase in total nationwide emissions. As explained in the impacts analysis for the 2010 rule (see Docket item

EPA

- HQ

- OAR

- 2002

- 0051

- 3438), emission reductions were estimated by compar ing baseline emissions to the long

- term av erage emissions of the MACT floor kilns. As a practical matter, plants operate to comply with this lower average emissions level (the so

- called design level)

, , rather than the emissions limit, so that on those days where there is normal operating variability they do not exceed the emissions limit. See 77 FR 42386

- 87.

Under the 2010 rule, the average PM emissions from the existing floor kilns were estimated as

0.02296 lb/ton clinker. Under the reconsideration fina l rule, the average PM emissions of the existing floor kilns is 0.02655 lb/ton clinker (see Appendix E of the TSD for proposal, docket

item EPA

- HQ

- OAR

- 2011

- 0817

- 0225). This is an estimated increase of 0.00359 lb/ton clinker over the 2010 rule (although the estimated difference is so small as to be viewed as “directional” rather than precisely quantitative; see 77 FR 42387). The average emissions for new kilns did not change, so there would be no change in emissions from new kilns. With the change in kiln

cl assification noted above, total clinker production from existing kilns increased to 76,664,662 tons per year (at proposal, clinker production of 75,355,116 was used). With an increase in PM emissions under the proposed rule of 0.00359 lb/ton clinker compar ed to the 2010 rule, nationwide emissions of PM would increase by 138 tons per year (0.00359 x 76,664,662/2000). Thus, the EPA estimates that the main effect of this final rule for PM will be to provide flexibility for those days when emissions increase as a result of normal operating variability, but would not significantly alter long

- term average performance for PM.



## 3. Cost of Final 2012 Portland Cement Reconsideration Rule

3.1 Revised Emission Standards for oHAP Alternative (for THC) and PM

Cost savings may be realized as a result of the change in the emission standards for organic HAP (in the form of the oHAP alternative) and PM from the 2010 rule. The organic HAP alternative limit changed from 9 ppmvd to 12 ppmvd for new and existing source s. The PM standard changed from 0.04 lb/ton clinker (30

- day average) to 0.07 lb/ton clinker (method 5 stack test) for2 

### existing sources and from 0.01 to 0.02 lb/ton clinker for new sources (with the same change in averaging times) . Because of normal variabi lity in the performance of PM control technology, we assumed that sources would need to comply with the MACT floor average to ensure continuous compliance. The average changed from 0.02296 lb/ton clinker for the 2010 standard

to 0.02655 lb/ton clinker for the proposed rule , as explained above

.

Based on an industry survey of 18 portland cement facilities (20 kilns) after proposal (see Docket

item EPA

- HQ

- OAR

- 2011

- 0817

- 0505

- A5) , it appears that the changes proposed to these

standards may have the following aff ects, which may result in savings in capital and annu a l cost s associated with implementing control technologies for these pollutants :

• RTO’s may not need to be installed due to the revised oHAP alternative

.

• Carbon injection rates may be lowered or not requi red for THC control

.

• Existing PM controls (ESP and baghouse) may not need to be replaced, but may instead be upgraded

.

• Additional P M control s may not have to be implemented

.

• Polishing and hybrid filter configurations may be implemented instead of total replacement s

.

• Higher volume, less efficient (and less expensive) sorbent could be used due to the new

PM limit

.

These survey results mirror the types of technologies EPA had previously indicated were likely to be newly available as a result of a mendments to the PM standard. See 77 FR 42386. W e have estimate d the potential cost savings using the industry survey results to determine what portion of the industry may be able to select a less costly control strategy as a result of the

revised emiss ion limits for PM and organic HAP

. Table 1 summarizes the results of the industry survey. In the survey, the respondents indicated the likely control strategy they were considering to comply with the 2010 emission limits and their likely compliance methods under the revised

limits of the 2012 rule. Under the 2010 rule, several kilns were already in compliance with the emission limits; for these kilns, no additional control methods would be needed. Other kilns were considering the addition of new controls or modifications to existing controls under the 2010 rule. As a result of the revised PM and organic HAP limits under the 2012 rule, some sources reported that they would be able to consider less costly measures, such as upgrading an ESP instead of replacing it with a new baghouse. And for other sources , the revised limits were unlikely to alter their likely control methods. A further summary of the survey results is presented in Table 2 showing each kiln and pollutant and whether a cost savings may be likely

under the 2012 rule. Because we do not have information on costs for some of the revised strategies, such as dust shuttling, we did not include them in our estimates of cost savings and they are not reflected in Table 2. Table 3 summarizes the numb er of kilns likely to have a cost savings by the type of revised control strategy. For example, a total of 7 kilns, or 35 percent of the kilns in the industry survey, are likely to upgrade their existing ESP instead of replacing or adding a new baghouse. A s just stated, strategies such as dust shuttling for which we do not have

cost information are not reflected in this table. Assumptions were also made when the survey did not identify the specific revised control strategy that would be considered under th e 2012 rule. For example, when the survey respondent stated that they would consider less costly

alternatives to RTO (five responded this way) , they did not identify the alternative technology.3 

### For purposes of these estimates, we assumed they would use ACI to meet the revised organic

HAP limit

.

C osts and cost savings were estimated for an average size kiln and then extrapolated to nationwide cost savings. Using the same information used in analysis of impacts for the 2010 rule (excluding CISWI kilns), the a verage size kiln in the industry has a capacity of about 650,000 tons clinker per year. Control costs under the 2010 rule were compared with the revised

control methods under the 2012 rule to estimate savings. The approach used to calculate the cost

of con trols are described in the environmental and cost impacts analysis for the 2010 rule (Summary of Environmental and Cost Impacts for Final Portland Cement NESHAP and NSPS, August 6, 2010, Docket item EPA

- HQ

- OAR

- 2002

- 0051

- 3438). The costs for the 2010 and 20 12 control methods and the savings for a 650,000 ton/yr kiln are presented in Table 4.

To estimate nationwide cost savings, the total number of affected kilns for each of the changed control strategies was estimated by multiplying the percentage of kiln s a ffected (from Table 3) by 133, the total number of non

- CISWI kilns in the cement industry. An exception to this is the kilns that were planning to install RTO. In our 2010 analysis, we identified six non

- CISWI kilns that were likely to require RTO to meet the THC/organic HAP limit. We believe this number is still appropriate . So the number of kilns identified in Table 4 is based on applying the 25 percent

of kilns affected to the six non

- CISWI kilns identified in the 2010 analysis as needing RTO , and

t he re sulting number of kilns in shown in Table 4

. Nationwide cost savings for each revised control strategy is the product of the number of affected kilns and the cost savings associated with each changed control strategy. Summing the nationwide savings for ea ch revised control strategy gives the total nationwide cost savings associated with the revised PM 1 

### and organic

HAP emission limits in the 2012 rule. As shown in Table 4, total cost savings resulting from the revised PM and organic HAP limits and the poten tial revised control strategies is approximately $42 million per year. The cost savings associated with just the revised control strategies for PM emissions is approximately $36.8 million. (Refer to the first 3 items listed in Table 4.)

3.2 CPMS Compliance Dem onstration

The 2010 rule required the use of CEMS to demonstrate compliance with the PM limit

. Under the final 2012 rule, compliance will be demonstrated using a three

- run Method 5 performance test with continuous compliance based on the use of continuous parametric monitoring system (CPMS). This change will save the industry the cost of performing multiple Method 5 tests necessary to establish the required corre lations under Performance Specification (PS) 11. As part of the PS 11 calibration requirements, a minimum of fifteen Method 5 test runs are required to develop a correlation curve, with no limit to the maximum number of test runs. One Method 5

test consist s of three test runs. Therefore, fifteen Method 5 test runs is equivalent to five Method 5 tests. Because one Method 5 test is required under the 2012 rule, four fewer tests are necessary

1 As explained in section V.A of the preamble to the final rule, the amendments to the PM standard afford opportunities for changed compliance strategies for the remaining stack emission standards, in the form of different options for control of PM capture associated with those standards (e.g polishing baghouses for activated carbon or residue from use of dry scrubbing, etc). These flexibilities, and associated savings, are refl ected in the PM cost

estimates shown in Tables 1 and 2 below to the extent that we have sufficient information to estimate cost of these newly

- available options..4 

### under the 2012 rule than under the 2010 rule . Omitting the need for these multiple test runs will save the facility a minimum of $20,000 per kiln (each three

- run Method 5 test costs $5,000 and an additional four tests would be required ; 4 x $5000 = $20,000 ). At a savings of $20,000 per kiln, nationwide savings for 133 new and existing kilns would be $2.7 million per year. Because the CPMS is the same type of device as a PM CEMS, the capital cost of the CPMS would not be

different than the CEMS device.

3.3 Inline Coal Mill Testing

Under the 2012 final rule, annual testing of inl ine coal mills for mercury, THC and HCl is required to account for these pollutants in kiln exhaust gases that are diverted to an inline coal

mill . Annual testing at these coal mills will cost an estimated $51,000 ($22,800 per Method 30B test for mercury + $8,000 per year for Method 25A test for THC + $20,000 per year for Method 321 test for HCl). According to the Portland Cement Association (see docket item EPA

- HQ

OAR

- 2011

- 0817

- 0612), there are approximately 26 facilities that will be affected by the testi ng requirements. At $51,000/yr for 26 facilities, the total additional annual cost is estimated at $1.3

million.

3.4 Open Clinker Storage Pile Work Practices

The 2010 rule required that clinker storage piles be either fully enclosed (if 1,000 ft or closer to a property line) or enclosed in a three

- sided structure (if greater than 1,000 feet from a property line). Based on industry information (docket item EPA

- HQ

- OAR

- 2011

- 0817

- 0141) and a review of state permits (see docket item EPA

- HQ

- OAR

- 2011

- 0817

- 0225, section 2, for the results of the review) , the EPA determined that most, if not all, facilities are already required to use work practices to control fugitive dust emissions from open clinker storage piles. In th e final 2012 rule, the EPA has codif ied those work practices.

T he 2012 final rule will result in savings to the industry by avoiding the construction of full or partial enclosures for clinker piles

. Industry cost estimates for en closures are presented in

Table 5 . Industry also estimated that at least 30 plants in the U.S. would be required to build these enclosures under the 2010 rule. To estimate the savings to industry, we estimated that one

half of the facilities would construct the full enclosure and o ne

- half the partial enclosure. We also used the cost midpoints of the industry ranges for our cost estimates. The work practice requirements for clinker piles in the final 2012 reconsideration rule will result in an annual savings of $ 8.25 million over the clinker pile requirements in the 2010 rule. The results are

summarized in Table 6

.

3.5 Summary of Costs

Table 7 summarizes the costs of the final 2012 amendments to the portland cement NESHAP

and NSPS. Total costs for the in dustry are estimated at a savings of $52 million per year.5 

### Table 1. Summary of Industry Cement Plant Timeline Compliance Assessments Survey

Likely Compliance Method Under 2010 Rule Likely Compliance Method Under 2012 Rule

Kiln

ID PM HCl Mercury THC/ oHAP PM HCl Mercury THC/oHAP

A New BH None None RTO New BH None None alt to RTO

B New BH None DS GC New BH None None None

C Add PBH Lime inj. None RTO Hybrid ESP Lime inj. None alt to RTO

D Add PBH Lime inj. None RTO Hybrid ESP Lime inj. None alt to RTO

E Add PBH Lime inj. DS+ACI GC Add PBH TBD TBD GC

F New bag filters None None RTO None None None alt to RTO

G New bag filters None None RTO None None None alt to RTO

H New BH None None None new BH None None None

I None None None None none None None None

J MF Lime inj. DS None TBD alt sorbent re

- eval DS TBD

K PBH Lime inj. ACI None upgrade ESP Lime inj. ACI None

L Reconfig existing BH None ACI None upgrade BH syst. None ACI None

M upgrade ESP None None None upgrade ESP None None None

N upgrade ESP None None None upgrade ESP None None None

O Add PBH None None None upgrade ESP None None None

P Add PBH None None None upgrade ESP None None None

Q New BH None ACI + DS None upgrade ESP None ACI + DS None

R PBH None ACI None upgrade ESP None ACI None

S New BH Wet/dry

scrubber Wet/dry

scrubber None Modify existing

BH Wet/dry

scrubber Wet/dry

scrubber None

T major repairs/replace None mix change mix change New bag filters None mix change mix change
BH=baghouse, PBH=polishing baghouse, MF=membrane filters, DS=dust shuttling, ACI=activated carbon injection, GC=good combustion, RTO=regenerative
thermal oxidizer, ESP=electrostatic precipitator , TBD=to be determined.

Source: Docket Item EPA

- HQ

- OAR

- 2011

- 0817

- 0505

- A56 

### Table 2. Kilns , for Which Potential Cost Savings Can be Estimated, by Pollutant Resulting from Revised Control Strategy

Kiln ID PM HCl Mercury THC/oHAP

A no no no yes

B no no no no

C yes no no yes

D yes no no yes

E no no no no

F yes no no yes

G yes no no yes

H no no no no

I no no no no

J yes no no no

K yes no no no

L no no no no

M no no no no

N no no no no

O yes no no no

P yes no no no

Q yes no no no

R yes no no no

S yes no no no

T yes no no no

NOTE: Savings would include those related to ancillary control of PM under mercury and HCl control
strategies but are not included here because of lack of cost information for those ancillary controls.



### Table 3. Number and Percentage of Kilns Affected by Revised Control Str ateg ies for Which Cost Savings Can be Estimated

Kiln ID Revised Control Strategy No of kilns % of

total

C,D,K,O,P,Q,R ESP upgrade instead of new baghouse 7 35

T,S Upgrade to membrane bags instead of new baghouse 2 10

F, G, J Retain standard filters instead of upgrading to membrane bags 3 15

A,C,D,F,G Install ACI instead of RTO 5 257 

### Table 4. Cost Savings for each Revised Control for a 650,000 TPY Kiln and Nationwide

Cost Savings a

Change in Control
Strategy 650,000 TPY Kiln Nationwide

Cost of 2010

control

strategy

($/yr) Cost of

2012

control

strategy

($/yr) Savings ($/yr) Percent

of kilns

affected (%) Number of

kiln

affected

nationwide b Nationwide
savings
ESP upgrade

instead of new
baghouse $987,000 $493,500 $493,500 35 47 $22,972,425
Upgrade to membrane bags

instead of new
baghouse $987,000 $109,000 $878,000 10 13 $11,677,400

Retain standard

filters instead of
upgrading to membrane bags $109,000 $0 $109,000 15 20 $2,174,550

Install ACI instead

of RTO $3,266,034 $593,837 $2,672,197 25 2 $ 5

, 344

, 395

TOTAL $ 4 2, 168

, 770

a See cost impacts description in Summary of Environmental and Cost Impacts for Final Portland Cement NESHAPand NSPS, August 6, 2010 (Docket item EPA

- HQ

- OAR

- 2002

- 0051

- 3438)

b Nationwide there are 133 nonCISWI kilns.



### Table 5 . Capital and Annual Cost for Clinker Pile Enclosures (50,000 ton capacity)

Distance from property line Capital costs Annual operating costs < 1000 feet (fully enclos ed) $10

- 25 million $400,000

- 500,000

> 1000 feet (three sided structure with tarps) $550,000

- 1.5 million $50

- 150,000

Source: Portland Cement Association, Clinker Piles, September 7, 2011, docket item EPA

- HQ

- OAR

- 2011

- 0817

- 01418 

### Table 6

. Annual Cost Savings for Clinker Pile Enclosures

Enclosure type Annual operating costs a Affected facilities b Annual savings Fully enclosed structure $450,000 15 $ 6.75 million Partially enclosed structure $100,000 15 $ 1.5 million

Total $8.25 million

a Used the midpoint of the industry’s cost range.

b Of the 30 facilities affected by the 2010 enclosure requirements, assumed that one

- half would use full enclosures and one

- half would use partial enclosures.



### Table 7

. Summary of Annual Costs of Final Amendments to

Portland Cement NESHAP and NSPS a

Final Amendment Annualized Cost

Revised oHAP and PM standard ($ 42.2 million)

CPMS Compliance Demonstration ($2.7 million)

Inline Coal Mill Testing $1.3 million

Open Clinker Storage Pile Work Practices ($8.25 million)

Total ($ 51.85 million)

a Parentheses indicate cost savings. All costs are in 2005 dollars.



## 4. Final MACT Floor Limits

The proposed MACT floor limits are unchanged for the 2012 final rule. A detailed discussion of the development of these standards was presented in the 2012 reconsideration proposal (77 FR 42368) and the June 2012 technical support document (docket item EPA

- HQ

- OAR

- 2011

- 0817

- 0225 ). After proposal, EPA received information that the Lehigh Union Bridge Kiln is not a CISWI kiln according to the definition of soli d waste in the NHSM rule. Therefore, the floor for the THC standard from the 2010 rule remains unchanged (since there is no change in any of the sources or their performance) e ( 75 FR 54970; see also docket item EPA

- HQ

- OAR

- 2002

- 0051

- 3403) and the THC limi t for existing and new kilns is the same as in the 2010 rule.

A summary of the 2012 final MACT floor limits is presented below (Tables 8 and 9 ) . The

emissions data and calculations used to determine these limits , which are available in documents

cited in the above paragraph, are presented in the attached appendices (A

- H ) for convenience

.



## 5. Beyond the Floor Analysis for PM and Mercury

5.1 PM

The EPA proposed to use the floor levels for PM as the standard, rejecting more stringent standards on the grounds of poor cost effectiveness. See 77 FR 42376. One commenter argued9 

### that the EPA should adopt a beyond the floor standard for PM, maintaining that such a standard was justified under the factors set out in section 112 (d)(2).

The EPA disagrees, and is not adop ting a beyond the floor standard. After considering the cost of the emission reductions attributable to such a standard, and the associated non

- air and energy impacts of such a standard, the EPA determines that the standard is not “achievable” within the

m eaning of section 112 (d)(2). Specifically, the EPA estimates that a beyond the floor standard set at the level of the original (2010 final rule) standard would only result in 138 tpy

– nationwide

– of PM reduction (a value not questioned by any of the com menters). See section 2

above . We further estimate that the cost of achieving this modest incremental reduction would be approximately $ 36.8 million (the estimated cost savings attributable to the amended PM

standard. See section 3.1 above. These total costs are high compared to the small nationwide emission reductions, and the cost effectiveness of these reductions is correspondi ngly high: approximately $ 26 7 ,000 per ton of PM removed. This is significantly higher cost effectiveness

for PM t han the EPA has accepted in other NESHAP standards. See 76 FR 15704 (March 21, 2011)(rejecting $48,501 per ton of PM as not cost effective for PM emitted by CISWI energy recovery units); see also 72 FR 53814, 53826 (Sept. 20, 2007) (proposing (and later ac cepting) cost effectiveness of $10,000 per ton for PM as reasonable in determining Generally Available Control Technology, and noting that the EPA had viewed cost effectiveness only as high as approximately $31,000 per ton as reasonable under its Title II program for mobile sources). The EPA’s decision and rationale is also discussed in the preamble section V.A.3.

5.2 Mercury

The EPA is establishing a standard for mercury of 55 pounds per million (lb/MM) tons clinker for existing sources and is not changing the emission standard (21 lb/MM tons clinker) for new sources. The emission standard for existing sources is the same as the 2010 standard but is a beyond the floor standard. As explained at proposal, the reanalysis of the mercury floor, after removing CISWI kilns, resulted in a floor of 58 lb/MM tons clinker produced

– slightly higher than the previously calculated floor and standard of 55 lb/MM tons clinker produced. To achieve the emission standard, sources will need to operate their processes and controls so that they can achieve the average emissions level used in setting the existing source limit of 55 lb/MM ton

- the so

- called design level. That level is 31.7 lb/MM ton for the standard of 55 lb/MM ton. The average for the 58 lb/MM ton is 34.1 lb/MM ton. The additional reduction needed is therefore 2.4 lb/MM tons, or an estimated 180 pounds of mercury emissions nationwide.

In the Technical Support Document for the proposed rule (Portland Cement Reconsideration Technical Support Document, June 15, 2012, Do cket item EPA

- HQ

- OAR

- 2011

- 0817

- 0225), the cost of the beyond the floor standard was estimated. To estimate the additional cost of going beyond the floor, we assumed that the rate of carbon injection would be increased to increase the mercury removal rate. The additional cost would then be the increased usage of activated carbon. Under the 2010 rule, we based the cost of compliance in part on an activated carbon injection rate of 3 pounds per million ACFM. To achieve this additional reduction, we estimated a n additional cost of approximately $ 355,000 for the industry, to purchase additional carbon injection materials. This equates to a cost

- effectiveness of $ 2 ,000/lb of mercury reduction per

year . See Portland Cement Reconsideration Technical Support Documen t, June 15, 2012 (Docket10 

### item EPA

- HQ

- OAR

- 2011

- 0817

- 0225) for more information on these cost estimates. Additional discussion of the EPA’s decision is in the preamble section V.B.11 

### Table 8

. Summary of 2012 Final NESHAP for Existing Sources

Pollutant Unit o f Measure 2010 Final

NESHAP 2012 Final

NESHAP

Hydrogen Chloride ppmvd 3 3

Mercury lb/MM tons clinker 55 55

Particulate Matter lb/ ton clinker 0.04

(30

- day
average) 0.07

(Method 5
stack test)

Total Hydrocarbon ppmvd 24 24

Organic HAP ppmvd 9 12



### Table 9

. Summary of 2012 Final NESHAP for New Sources

Pollutant Unit of Measure 2010 Final

NESHAP 2012 Final

NESHAP

Hydrogen Chloride ppmvd 3 3

Mercury lb/MM tons clinker 21 21

Particulate Matter lb/MM tons clinker 0.01

(30

- day
average) 0.02

(Method 5
stack test)

Total Hydrocarbon ppmvd 24 24

Organic HAP ppmvd 9 12