1

MEMORANDUM 

TO: Toni Jones, Charlene Spells, Ketan Patel U.S. Environmental Protection Agency 

FROM: Kristen James, Jason Huckaby, and Amber Allen, Eastern Research Group, Inc. 

DATE: April 26, 2010 

SUBJECT: CISWI Test Data Database

 

1.0 INTRODUCTION 

This memorandum summarizes the information collection activities and data 

standardization procedures used to develop the Commercial Industrial Solid Waste Incinerators 

(CISWI) unit database. The database discussed in this memorandum reflects the data utilized in 

preparation of the proposed regulations. The EPA received additional data late last year and 

early this year, but due to the court-ordered deadline, did not have sufficient time to review and 

evaluate the additional data and revise the analyses. EPA intends to review the additional data 

submitted from a quality assurance and completeness perspective and incorporate that data into 

the final standards, as appropriate. To the extent the Agency receives additional emissions data 

during the comment period, the Agency will assess that data as it develops the final emission 

standards. 

Section 2.0 summarizes the data collection efforts and Section 3.0 discusses the 

procedures used to reconcile duplicates and standardize the reported data. Appendix A contains 

a list and brief description of the tables contained in the CISWI database and Appendix B 

provides a table showing the data conversions used to standardize emission units. 

2.0 DATA COLLECTION 

The initial database of CISWI units operating in the United States as of 1998 was 

obtained from the information collected to support EPA’s Industrial Combustion Coordinated 

Rulemaking (ICCR). In 2006, the list of CISWI units initially identified was distributed to 10 

EPA regional offices to confirm whether the units were operational. Based on the information 

supplied by the EPA Regions, the initial CISWI database was revised to reflect the unit 

deletions/additions provided by the Regional contacts. The regions also provided emissions test 

reports, as available. 

In 2008, CISWI units for which EPA regional offices did not have any information were 

included in EPA’s Combustion Survey (ICR No. 2286.01). This “Phase I” survey requested that 

facilities provide information concerning any operating CISWI units (e.g., location of unit, 

contact person, emissions, fuel type, waste type, and controls). Data from the Phase I survey 
2

were reviewed to include only data for incinerators or energy recovery units that were currently 

in operation and are expected to be in operation at the CISWI rulemaking compliance date. EPA 

used the data collected from the ICR Phase I survey to update the inventory of CISWI units and 

identify gaps in emissions test data. 

In May of 2009, the Agency distributed EPA’s Test Plan for Boilers, Process Heaters, 

and Commercial Industrial Solid Waste Incinerators (ICR No. 2286.03) to targeted facilities. For 

CISWI units, the targeted facilities were each unique CISWI unit within EPA’s understanding of 

the proposed solid waste definition and the units that would be considered CISWI as a result of 

the definition. This “Phase II” survey asked facilities to conduct emission tests for pollutants 

where emissions data were missing from the Phase I database. Facilities submitted emissions 

test reports using various means including hard copies of stack test reports, ERG Excel 

spreadsheet template files, and EPA’s Electronic Reporting Tool (ERT). 

Based on the responses to the Phase I and II surveys, the CISWI database was revised to 

reflect previously unidentified units, units that were no longer operational, and units that were 

not considered to be CISWI units for the reasons shown below: 

• The unit burned on-spec used oil only. 

• The unit was shutdown (Conditional Exemption) and the facility indicated that it does not 

plan to operate the unit in the future. 

• The unit was a metals recovery unit. 

• The unit no longer burns waste. 

• The unit was a hazardous waste unit under SWDA 3005. 

• The unit was classified as an OSWI unit (e.g., animal crematory). 

• The unit qualifies as a small power production facility or qualifying cogeneration facility 

and is statutorily exempt under section 129 of the Clean Air Act. 

• The unit is a cogeneration unit. 

• The unit is government-owned and should be classified as an OSWI. 

In addition to the revisions made to the database to incorporate the Phase I and II survey 

responses, units were removed from the CISWI database based upon direct communications 

between the facility and EPA representatives. 

Some units in the inventory were not required to conduct emissions tests as part of the 

Phase II survey. Very small units, smart ash units, and identical units to those already identified 

for testing at a facility were not required to be tested. Emissions data are not available for the 

units that were not required to test unless a facility voluntarily submitted additional data for a 

unit listed in the database. 

EPA’s solid waste definition rule proposes to define which non-hazardous secondary 

materials that are used as fuels or ingredients in combustion units are solid wastes under Subtitle 

D of RCRA. In addition to the primary proposed approach set forth in the Solid Waste 

Definition rule, the rule solicits comments on an alternative approach for determining which 

secondary materials are solid waste under Subtitle D of RCRA, when combusted. Therefore, 

two separate databases were created from the revised database to facilitate EPA’s rulemaking 
3

decisions: the Proposed Approach Database, and the Alternative Approach Database. These 

databases contain information for waste-firing units as defined in the proposed and alternative 

definitions of the solid waste definition rule. 

3.0 DATA STANDARDIZATION PROCEDURES 

3.1 ICR Phase II Data Hierarchy 

For some CISWI units, emissions data were reported in the Phase II survey using both the 

Microsoft ® Excel spreadsheet templates and the EPA’s ERT. To avoid duplicate records in the 

CISWI emissions database, the following hierarchical approach was developed to determine 

which data to incorporate into the database: 

1. If a test report summary (either hard or electronic copy) and an electronic data 

summary (either ERT or Microsoft ® Excel spreadsheet template) were provided, 

the electronic data summary was used in the emissions database to minimize data 

entry and processing time. 

2. If the Microsoft ® Excel spreadsheet template and an ERT file contained data for 

the same pollutant, the Microsoft ® Excel spreadsheet template was used to 

populate the emissions database. 

3. If the respondent did not provide a Microsoft ® Excel spreadsheet template for a 

pollutant, the ERT data was used in the emissions database. 

4. After the data from the ERT and Microsoft ® Excel spreadsheet templates were 

consolidated, any pollutants with negative or zero values or suspected outliers for 

high or low emission rates were compared to the hard copy and electronic files to 

confirm these questionable values. If the test report had values that differed from 

the ERT or Microsoft ® Excel spreadsheet templates, the data from these test 

reports replaced the ERT and Microsoft ® Excel spreadsheet template data in the 

database. The reported emissions data for each unit on the test list were also 

reviewed for any pollutants not reported in the ERT or Microsoft ® Excel 

spreadsheet templates. These data gaps were reviewed to determine if fuel or 

material analysis data were used in lieu of stack testing or if EPA had granted a 

testing waiver for certain pollutants (such as for certain burn-off ovens). If the 

data were found to be missing, the stack test reports were reviewed, and used to 

populate the database. 

3.2 Data Standardizations 

Most of the fields presented in each table of the database were taken directly from the 

Microsoft ® Excel spreadsheet templates or ERT files as populated by the respondent. However, 

additional data fields were added to the database to standardize the various types of qualitative 

and quantitative data reported. These fields allowed for analysis of the raw data while 

maintaining a record of the data as originally reported. Further, seeing the reported data 

alongside the analyzed data facilitated the process of quality assurance (QA) on the standardized 

fields. Finally, a few fields in the Data:Emissions Tests table of the database were added to the 
4

CISWI database and were populated during data extraction from stack test reports submitted by 

the facility. 

3.2.1 Emissions Test Data 

 Before the emissions data contained in the CISWI database could be evaluated, the data 

reported by facilities were converted into the following standardized units of measure (see 

Appendix B for data conversion tables): 

• Parts per million by volume on a dry basis, corrected to 7 percent oxygen 

(ppmvd @ 7% O2) for hydrogen chloride (HCl), hydrogen fluoride (HF), 

sulfur dioxide (SO2), carbon monoxide (CO), and nitrogen oxides (NOx); 

• Milligrams per dry standard cubic meter, corrected to 7% O2 (mg/dscm @ 

7% O2) for metals (including cadmium (Cd), mercury (Hg), and lead (Pb)), 

condensable particulate matter (PM), filterable PM; PM10; PM2.5; total PM 

(including condensables); 

• Nanograms per dry standard cubic meter, corrected to 7% O2 (ng/dscm @ 

7% O2) for dioxin/furans (both totals and specific congeners); and 

• Percent (%) for opacity. 

If the parameters needed to convert emissions into the standardized units were missing 

for a particular unit, the assumption was made that the facility reported the pollutant emissions in 

the desired (standardized) units. Some values, including emissions data reported in units of 

lb/hr, lb/ton of kiln feed, lb/ton clinker, and zero emissions values were not able to be converted 

to the standardized units due to the lack of volumetric flow rates and other relevant data. These 

values are maintained in the database but are not used in the emissions analyses. 

3.2.2 Controls and Fuels 

Fuel input rates and controls on a per-run basis are needed in the emissions and costing 

analyses; however, ERT does not track multiple fuel input rates or control devices used during 

each test run. If a facility submitted emission test results using both the ERT file and the 

Microsoft ® Excel spreadsheet template, the fuel(s) and control(s) used during the reported ERT 

test results were assumed to be identical to the fuel and control data reported in the Microsoft ® 

Excel spreadsheet templates. If the Microsoft ® Excel spreadsheet templates did not provide 

fuel and control data, or if the facility did not submit any Microsoft ® Excel spreadsheet 

templates as part of its Phase II test response, the reported test results were assigned using the 

fuel and control data reported for that unit ICR Phase I survey. For facilities with outlying 

emissions test data, test reports were reviewed to confirm the fuels and controls installed during 

the tests. 

3.2.3 Fuel Types 

Fuel type is reported in 6 tables in the database. To assign CISWI units to a fuel category 

and analyze data across different fuel types, these reported fuels needed to be standardized across 

all data tables where fuel type is used to characterize the unit. Table 1 shows each occurrence of 
5

“fuel” in the database and the corresponding standardized fuel field. The reported design 

capacity fuels were not standardized because they do not necessarily represent the fuels routinely 

combusted in the CISWI units. 

Table 1 - Standardized Fuel Fields

Table Reported Fuel Field Standardized Fuel Field 

TypFuel Common Fuel 

Data: CEMS Backgrnd 

MaxFuel Common MaxFuel 

Data: EmissionsTest Fuel 

Data FuelParameter_Type Common Fuel 

Data: Fuel Analysis Fuel_Material Common Fuel 

Data: Fuel Analysis 

Background Information Fuel_Material Common Fuel 

StartupFuel Common StartupFuel 

Data: Materials Combusted Fuel Common Fuel 

NRC_Fuel Common NRC_Fuel 

Data: Non-Fossil Fuels NonFossilFuel Common Fuel 

A “common” fuel field was created corresponding to each reported fuel type in the 

database. The level of detail within the common fuel categories were based on fuel categories 

provided in Appendix C of the Survey Overview Document1. If the reported fuel did not match 

any of the corresponding fuel categories in Appendix C, a new common fuel category was 

created. 

Fuels were occasionally reported as a mixture of fuels within a single record. Each 

reported fuel in the mixture was standardized to the format listed in Appendix C of the Survey 

Overview Document1, separated by “and” in the standardized fuel field. For example, a reported 

fuel of “#2 Fuel Oil, kerosene” was standardized to “No. 2 Distillate and Kerosene.” 

Survey respondents were asked to select a fuel from a series of drop-down lists in the 

Microsoft ® Excel spreadsheet templates. These templates also allowed respondents to select 

“other fuel” and enter a description of the type of fuel they combust. In these cases, the 

description of the fuel type provided by the respondent was used in the database. 

3.2.4 Air Pollution Control Devices 
6

Add-on air pollution control devices are reported in the Data:Control Device table. 

Table 2 shows the occurrence of “control device” in the database and the corresponding 

standardized control device field. 

Table 2 - Standardized Control Device Fields 

Table Reported Control Device 

Field 

Standardized Control Device 

Field 

Data: Control Device ControlDevice Standardized ControlDevice 

The standardized control types were based on the list of control devices provided in the 

drop down lists in the Survey Answer Key2. If the reported control did not match any of the 

corresponding control devices in the Answer Key, a new control device category was added. 

Survey respondents were asked to select a control device from a series of drop-down lists 

in the Microsoft ® Excel spreadsheet templates. These templates also allowed industry to select 

“other control device” and enter a description of the control device installed on the unit. In these 

cases, the description was what was reported as the control type in the database. 

Occasionally, combinations of control devices were entered when respondents selected 

“other control device” from the drop-down list of controls in the Microsoft ® Excel template 

files. In these instances, each reported control device in the mixture was standardized, with 

individual control devices separated by “and” in the standardized field. 

3.2.5 Standardizations of Reported Emission Test and CEMS Data 

The emissions data obtained from test reports and continuous emissions monitoring 

systems (CEMS) were standardized to provide a common basis for analyzing and comparing 

emissions data from various CISWI subcategories. To allow for reporting of both non-detect 

data (with detection limits) and detectable emissions data, all emissions data were imported into 

the survey results database in a text field format. Numeric fields mirroring the contents of this 

text field were created to apply mathematical operations to the emissions data and the reported 

detection limits for non-detect emissions data. These data were reported as text fields due to the 

format in which non-detect data were reported. Survey respondents were asked to enter the 

detection limit for a given pollutant and test by enclosing the detection limit in brackets. Any 

reported data in this format was deemed non-detect and the value inside the brackets was used as 

the detection limit. Non-detect data were also reported in other formats; therefore, any reported 

data that included any text other than a numeric value were considered to be “non-detect”. For 

example, if the reported emission value was “ND 0.5,” the value was assumed to be non-detect 

and 0.5 was used as the detection limit. 

Some respondents reported an emission value but did not report any units of 

measurement corresponding to that value. These data points were compared to other data points 

from the same facility, unit, and pollutant. If there were additional data with reported units of 

measure and the value without units of measure was of the same order of magnitude, the 
7

assumption was made that the units were consistent. For example, if a combustion unit reported 

CO emissions to be “10 ppm,” “14 ppm,” and “12,” it was assumed that the “12” was intended to 

be “12 ppm.” If the reported emission value without any units of measure was not within the 

same order of magnitude, no units of measure were assigned to the data points and those values 

were not standardized and not used in subsequent analyses. 

3.2.6 Heat and Fuel Input Rates 

Some emissions data conversion equations for energy recovery units required the heat 

input or fuel input during the test to be standardized to MMBtu/hr. If emissions were reported as 

a pollutant mass per unit of time, the total reported heat input during the test run was the 

preferred conversion parameter. However, if a facility did not report a total heat input value and 

instead reported fuel input rates, the sum of all standardized fuel input rates were used to convert 

the emissions test values. Permit limits that required similar conversions were based on the 

design capacity of the unit and not heat or fuel input rates. 

Some emissions data were reported as a mass of emissions per mass of fuel combusted. 

To standardize these reported values into units of lb/MMBtu, the average higher heating value 

(HHV) reported in the survey for each fuel listed as an input was needed to convert the emission 

data. If a combination of fuels was reported, an equally weighted mixture was assumed and the 

HHV for each constituent fuel was averaged. Sometimes the fuel reported with the design 

capacity units was a generic “fuel oil” or “coal.” Any unspecified specification of fuel oil was 

assumed to be No. 2 Distillate because it is the most common specification of oil reported to be 

combusted in the ICR. An unspecified type of coal was assigned the HHV of bituminous coal 

because it was the most common type of coal reported in the survey. All types of wood were 

assumed to have the same HHV as was assumed in the Memorandum from Jack Johnson, ERG, 

to Fred Porter, US EPA3. 

The conversions used to standardize the energy recovery unit fuel and heat input rates are 

identical to those used to standardize the design capacity of each unit (see Section 3.2.11). 

3.2.7 Exhaust Oxygen and Moisture Content 

Some emissions data conversions required the amount of O2 and/or moisture present in 

the exhaust stream to be standardized to a percent. The 2008 Combustion Survey asked for O2

and moisture to be reported as percent and it was assumed that all reported values were already 

in these units since the survey respondent could not specify other units of measure. Values such 

as “0.05” were assumed to be “0.05%” and not “5%” since the survey specifically asked for units 

in percent format. 

Because a percentage cannot be greater than 100, the O2 and moisture contents were 

reviewed to ensure that no reported data were above that threshold. If a facility did not submit 

O2 or moisture data, the standardized fields were not populated. Oxygen data were only a survey 

requirement when reporting carbon monoxide data. If the reported units of measure for other 

pollutants required an O2 concentration for standardization, an O2 concentration of zero percent 

was used in the conversion calculation. 
8

3.2.8 Exhaust Flow Rate 

Some emissions conversions required the exhaust stream flow rate to be standardized to 

dry standard cubic feet per minute (dscfm). Any reported unit of measure that contained the 

letter “d” was assumed to be an abbreviation for “dry.” Similarly, any reported unit of measure 

that listed an “s” was assumed to be an abbreviation for “standard.” If a unit reported an “s” but 

no “d” (such as “scfm,” an acronym for “standard cubic feet per minute”), the units were 

corrected for moisture where percent moisture information was available, otherwise the units 

were assumed to be at dry standard conditions. 

3.2.9 Exhaust Temperature 

Some emissions conversions required the exhaust stream temperature to be standardized 

to degrees Fahrenheit (°F). Any standardized temperature greater than 2,000 °F was compared 

against the other temperatures reported at that facility to identify typographical errors. If the 

reported temperature was a suspected typographical error, the order of magnitude for the 

reported and standardized temperature values was reduced to maintain consistency between all 

data points at that facility. For example, if a facility reported temperatures of “356.746 °F,” 

“359.617 °F” and “364223 °F,” the latter was changed to “364.223 °F.” 

 

3.2.10 F-Factors 

A unique, fuel-specific F-Factor was assigned to each emissions test based on the fuel 

reported during the test, and that value was used in the standardization of the reported data. A 

list of all F-Factors used in converting emissions test, CEM and permit data (and the sources 

from which the F-Factors were found) can be found in the Boiler Survey Results Database,

LOOKUP: F-Factors table4. 

3.2.11 Capacity 

The reported design capacity of each energy recovery unit was standardized to units of 

million British thermal units per hour (MMBtu/hr) to provide a common basis for analyzing and 

comparing data from various sizes of units. 

First, two data fields called “Standardized Capacity” and “Standardized CapacityUnit” 

were created in the Data: Unit Design/Operation table to hold the standardized design capacity 

data. These fields were created so as to not overwrite the data originally reported during the 

standardization process. Additionally, because the reported design capacity was a text-based 

field the “Standardized Capacity” field was created as a numeric field. This allowed 

mathematical operations to be applied to the reported design capacities to standardize the 

parameter to the preferred units of measure. Next, a list was created to identify unique units of 

measure reported with each design capacity. This list was reviewed to identify and update 

design capacities without reported units of measure. Missing units of measure were corrected in 

one of two ways: 
9

• For units that reported a design capacity value but did not report any units, the 

design capacity was compared to design capacities from other combustion units at 

the same facility. If additional combustors of a similar size were reported with 

units of measure and the value was of the same order of magnitude, it was 

assumed that the units were consistent. For example, if Boiler 1 and Boiler 2 

were located at the same facility, and Boiler 1 reported a design capacity of “100 

MMBtu/hr” while Boiler 2 reported a design capacity of “120,” and did not report 

any units, it was assumed that the “120” was intended to be “120 MMBtu/hr.” In 

this case, the “Standardized CapacityUnit” field was updated to “MMBtu/hr” 

while the “Standardized Capacity” field was updated to “120.” If a distinction 

could not be made for the unit with missing units of measure, the “Standardized 

CapacityUnit” field was updated to “unknown.” 

• If the user selected units of measure for the design capacity from the survey drop 

down menu and also provided a note about these units in the field reserved for 

collecting “other” units of measure, this description was reported as the units of 

measure in the database. In these cases, the original Microsoft ® Excel templates 

were reviewed and the correct units of measure were entered in the standardized 

design capacity and design capacity unit fields. 

Design capacities for multiple units at the same facility were compared to find errors 

conversions (see Standardization of Reported Data from the Questionnaire for Boilers, Process 

Heaters, Incinerators and Other Combustion Units Memo5 for discussion on capacity 

conversions). The total ranges of converted design capacities for each group of reported units of 

measure were investigated to identify questionable data points. Standardized design capacities 

greater than 1,800 MMBtu/hr were deemed illogical and the “Standardized CapacityUnit” field 

was updated to “unknown” for those combustion units. 

3.2.12 Subcategories 

Under section 129 (a)(2) of the Clean air Act, the Administrator may distinguish among 

classes, types (including mass-burn, refuse-derived fuel, modular and other types of units), and 

sizes of units within a category in establishing such standards. The degree of reduction in 

emissions that is deemed achievable for new units in a category shall not be less stringent than 

the emissions control that is achieved in practice by the best controlled similar unit, as 

determined by the Administrator. Emissions standards for existing units in a category may be 

less stringent than standards for new units in the same category but shall not be less stringent 

than the average emissions limitation achieved by the best performing 12 percent of units in the 

category (excluding units which first met lowest achievable emissions rates 18 months before the 

date such standards are proposed or 30 months before the date such standards are promulgated, 

whichever is later). 
10

For evaluating alternative standards, CISWI units were subcategorized based on 

fundamental technical differences and other differences in the processes, such as combustor 

design, draft type and availability of utilities. The five proposed subcategories that were 

developed are listed below, followed by an explanation of the reasons for creating each 

subcategory: 

• Incinerators (general waste burning units without integral heat recovery), 

• Energy recovery units (waste burning units that recover thermal energy), 

• Waste-burning kilns (tire and waste burning kilns), 

• Burn-off ovens (small units that clean metal parts), and 

• Small, remote incinerators (small incineration units located in remote areas). 

Incinerators: Incinerators, which are the units currently regulated by the 2000 CISWI rule, are 

used to dispose of solid waste materials and emissions are a function of the types of materials 

burned. Incinerators are designed without integral heat recovery (but may include waste heat 

recovery). While there are different designs, they all serve the same purpose; reduction in the 

volume of solid waste materials. Incinerators can be operated on a batch or continuous basis. 

The same types of add-on controls, including fabric filters, wet scrubbers, selective noncatalytic 

reduction (SNCR), and activated carbon injection, can be applied to most incinerators. Although 

the composition of the materials combusted is highly variable and is a key factor in the profile of 

emissions, we determined it was not appropriate to further subcategorize incinerators because the 

sources in this subcategory are sufficiently similar such that the incinerators can achieve the 

same level of performance for the nine regulated pollutants. 

Energy-recovery units: Energy recovery units are typically waste-fired boilers and process 

heaters that combust solid waste materials as a percentage of their fuel mixture and are designed 

to recover thermal energy in the form of steam or hot water. Energy recovery units are generally 

larger than incinerators. Energy recovery units typically fire a mixture of solid waste and other 

fuels, whereas incinerators burn predominantly solid waste, although sometimes a small amount 

of supplemental fuel is fired in an incinerator to maintain combustion temperature. Energy 

recovery units are also different from incinerators in terms of how the fuel is fed into the 

combustion chamber, the combustion chamber design (which typically includes integral heat 

recovery), and other operational characteristics. These differences can result in emission profiles 

for energy recovery units that are different from incinerators but similar to boilers. Combustion 

of waste materials in these units impacts the emissions profile to some degree, although 

emissions from these units often resemble emissions from boilers that combust traditional fuels. 

Waste-burning kilns: Waste-burning kilns are fundamentally different than any other unit being 

regulated under CISWI. Kilns of all types are physically larger than an incinerator with a 

comparable heat input. Kiln design and operation are also different. For example, the design is 

typically a rotating cylindrical kiln with a fuel burner on one end and raw materials being fed in 

the other (cold) end. Fuel (particularly solids such as tires) may also in some cases be fed at the 

midpoint of the kiln. Some kilns also have a large preheater tower with a precalciner that is an 

additional firing point for both fossil and waste fuels. The temperature profile of kilns is critical 

in order to produce a saleable product. Another key distinction is that for cement kilns, the 

source of most of the pollutants is typically the raw materials, not the fuels, and emissions from 
11

the raw materials and the solid wastes and fuels are comingled and emitted together. As a result, 

waste-burning kilns have a very different emissions profile than other CISWI subcategories and 

that difference can influence the design of applicable controls. 

Burn-off ovens: These units typically are very small (<1 MMBtu/hr), batch-operated, 

combustion units that are used to clean residual materials from various metal parts that are then 

reused in the process. The amount of waste combusted in these units is generally small (pounds 

per year in some cases) and the configuration of the stacks that serve these units precludes the 

use of some EPA test methods for measuring emissions and could affect the ability to install 

certain control devices. 

Small, remote, incinerators: These are batch-operated units that combust less than 1 ton of waste 

per day and are farther than 50 miles driving distance to the closest municipal solid waste 

(MSW) landfill. To the extent that these units are located in Alaska, a major difference in these 

types of units is the inability to operate a wet scrubber in the northern climates and the lack of 

availability of wastewater handling and treatment utilities. We believe this would impact their 

ability to meet emission limits for pollutants controlled by wet scrubbers. In addition, because of 

the remote location, these units do not have lower-cost alternative waste disposal options (i.e., 

landfills) nearby and emissions associated with transporting the solid waste could be significant. 

3.2.13 Fields Added to the database 

The “Batch” and “In compliance” fields in the Data: Emissions Tests table were added to 

the database of CISWI units. These fields were populated during stack test extraction when a 

facility indicated that a unit was either continuously or batch fed with waste material or was in 

compliance with state or federal permit limits. 

The “lat” and “lon” (i.e. latitude and longitude) fields in the Data:Facility were also 

added to the CISWI unit database. These fields were populated using the physical address 

provided by the facility along with TeleAtlas's Geocoder USA_Geo_002 service.6 Addresses 

that were not found in the geocoder were searched in http://www.earthpoint.us/Townships.aspx, 

Google Earth, and batchgeocode.com to find the appropriate latitude and longitude coordinates. 
12

4.0 References

1. Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units: 

Survey Overview. OMB Control No. 2060-0616, http://survey.erg.com/ss/wsb.dll/s/7g8d

2. Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Devices: 

Answer Key. OMB Control No. 2060-0616, http://survey.erg.com/ss/wsb.dll/s/7g8d

3. Memorandum from Jack Johnson, ERG, to Fred Porter, EPA/ESD, Emissions Data 

Conversions And Calculations in the ICCR Emissions Test Database. June 25, 1999.Survey 

4. Results Database, Survey Database containing Results of the 2008 Questionnaire for Boilers, 

Process Heaters, & Other Combustion Units (ICR No. 2286.01).

5. Memorandum from Amanda Singleton and Graham Gibson, ERG, to Jim Eddinger, U.S. 

Environmental Protection Agency, OAQPS, Standardization of Reported Data from the 

Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units. April, 

2010. 

6. TeleAtlas's Geocoder USA_Geo_002 service, 

http://www.geocode.com/documentation/USA_Geo_002.pdf

7. Memorandum from Jason Huckaby, Amber Allen, Kristen James, Eastern Research Group, 

Inc, to Charlene Spells, Toni Jones, Ketan Patel, U.S. Environmental Protection Agency, 

Compliance Cost Analyses for CISWI Units Table 4C. April 28, 2010. 
13

Appendix A: CISWI Database Contents 

Table 

Type Data Table Name Contents 

Data CEMS CEMS data for CO, NOx, SO2, and PM. 

Data CEMS Backgrnd Background information for continuous emissions monitoring 

data for CO, NOx, SO2, and PM. 

Data Emissions Tests Emissions test data for dioxin/furans (both totals and specific 

congeners); 15-, 16-, and 7-PAH; acetaldehyde; antimony; 

arsenic; benzene; barium; beryllium; cadmium; chlorine;

chromium; CO; cobalt; copper; formaldehyde; hexavalent 

chromium; HCl; HF; Pb; manganese; mercury; nickel; NOx; 

filterable PM; PM10; PM2.5; condensable PM; total PM 

(including condensables), phosphorus; selenium; silver; SO2; 

thallium; toluene; total hydrocarbons; xylenes; and zinc. 

Data EmissionsTest Background 

Info 

Background information for the Emissions Tests table. 

Data Emissions Test and CEMS 

Installed 

Background information including start up fuel types and 

emission test locations for data included in the Emissions Tests 

and CEMS tables. 

Data EmissionsTest Fuel Data Information on fuel types related to the Emissions Tests table. 

Data PaintAnalysis Additional information submitted by facilities with burn off 

ovens during ICR Phase II where the paint analysis 

information that did not fit into a template file. 

Lookup TEF Values Toxic Equivalent Factors (TEF) used to convert dioxin/furan 

emissions data from TEQ into total mass basis. 

Data Control Device Information on the type of control device in place related to 

the units listed in the Unit Design/Operation table. 

Data Facility Contact information and latitude/longitude coordinates for all 

facilities in the database. 

Data FuelAnalysis Information on the types of fuels burned in the CISWI units. 

Data FuelAnalysis Background 

Information 

Background information on the fuel types listed in the 

FuelAnalysis table. 

Data GCP and 

CombustionControls 

Background information on GCP and combustion controls 

related to the units listed in the Unit Design/Operation table. 

Data Incinerator Control 

Devices 

Information on the type of control device in place related to 

the units listed in the Incinerator table. 

Data Incinerator Waste 

Management 

Information on the type of waste related to the units listed in 

the Incinerator table and provides information on alternative 

waste management systems available and the cost as 

applicable. 
14

Appendix A: CISWI Database Contents 

Table 

Type Data Table Name Contents 

Data Incinerator The units classified as incinerators in the database and 

background information on these units including model type, 

capacity, and hours operated per year. Units listed in this table 

are further subcategorized as ‘Incinerators,’ ‘Burn-Off Ovens,’ 

‘Air Curtain Incinerators,’ ‘Waste-burning Kilns,’ and ‘Small, 

Remote’ units (see Subcategorization Memo.) 

Data Materials Combusted Information on the type of materials combusted related to the 

units listed in the Unit Design/Operation table. 

Data Non-Fossil Fuels Information on the type of non-fossil fuels burned related to 

the units listed in the Unit Design/Operation table. 

Data Regulatory and Permit 

Limits 

Local, state, and federal information on individual pollutant 

emission limits. 

Data Stack Background stack information for units listed in the Unit 

Design/Operation table including whether the stack is a single, 

common, or multiple stack. 

Data Unit Design/Operation The units subcategorized as Energy Recovery Units in the 

database and background information on these units including 

capacity, operating hours, and size classifications. 

Lookup CISWI Control Device 

Look Up 

List of all the facilities and combustion unit IDs contained in 

the database with their associated subcategory and control 

device. 
15

Appendix B: Data Conversion Table 

Variable From To Data Required Constants Conversi

lb/hr mg/dscm flow rate (dscm/m) 

453.592 g/lb 60 m/hr 1000 mg/g 

(mg/dscm) = (lb/hr)*453592/(

gr/dscf mg/dscm (applies to PM) 

7000 gr/lb 35.31 ft3/m3 453592 mg/lb 

(mg/dscm) = (gr/dscf)*35.31*

lb/MMBtu mg/dscm F-Factor7 (mg/dscm) = ((lb/MMBtu)/(F-mg/dscm ppmvd (ppmvd) = (mg/dscm)/(0.0415ppmvd mg/dscm 

Molecular Weight (MW): NO2 = 46 lb/mol CO = 28.01 lb/mol SO2 = 64.06 lb/mol HCl = 36.45 lb/mol HF = 20.01 lb/mol 

.041552 mg/dscm (@ 7% O2 and 68oF) 

(mg/dscm) = 0.041552*(MW)

mg/dscm ng/dscm (ng/dscm) = (10^6)*(mg/dscmppmv ppmvd moisture (%H2O) (ppmvd) = (ppmv)*100/(100 - 

Pollutant emission 

at X%O2 at 7% O2 O2 content (%O2) (at 7% O2) = (at X%O2)*(20.dscf/m dscm/m 35.315 ft3/m3 (dscm/m) = (dscf/m)/35.315 Flow rate scf dscf moisture (%H2O) (dscf) = (scf)*(100 - %H2O)/1

7 F-Factors for each unit are dependent on the fuel type combusted. Refer to Table 4C in the Compliance Cost Analyses for Existing CISWI Units Memo7 for a list of as