1

MEMORANDUM

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

FROM: Kristen James, Jason Huckaby, and Amber Allen, Easter n 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 Indus trial Solid Waste Incinerators (CISWI) unit database. The database discussed in this mem orandum 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. EP A intends to review the additional data submitted from a quality assurance and completeness perspectiv e and incorporate that data into the final standards, as appropriate. To the extent the A gency receives additional emissions data during the comment period, the Agency will assess that dat a 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 t he CISWI database and Appendix B provides a table showing the data conversions used to standa rdize emission units.

2.0 DATA COLLECTION

The initial database of CISWI units operating in the Unit ed 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 initia lly 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 wa s 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 CISW I units (e.g., location of unit, contact person, emissions, fuel type, waste type, and co ntrols). Data from the Phase I survey2

were reviewed to include only data for incinerators or ene rgy recovery units that were currently in operation and are expected to be in operation at the C ISWI rulemaking compliance date. EPA used the data collected from the ICR Phase I survey to upda te 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 CI SWI unit within EPA’s understanding of the proposed solid waste definition and the units that wo uld 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 datab ase. Facilities submitted emissions test reports using various means including hard copies of st ack test reports, ERG Excel spreadsheet template files, and EPA’s Electronic Reporti ng Tool (ERT).

Based on the responses to the Phase I and II surveys, t he CISWI database was revised to reflect previously unidentified units, units that were no lo nger 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 faci lity 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 crem atory).

• The unit qualifies as a small power production facility or qualifying cogeneration facility and is statutorily exempt under section 129 of the Clean Ai r 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 incor porate the Phase I and II survey responses, units were removed from the CISWI database base d upon direct communications between the facility and EPA representatives.

Some units in the inventory were not required to conduct em issions tests as part of the Phase II survey. Very small units, smart ash units, an d 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 vol untarily submitted additional data for a

unit listed in the database.

EPA’s solid waste definition rule proposes to define whi ch non-hazardous secondary materials that are used as fuels or ingredients in combus tion units are solid wastes under Subtitle D of RCRA. In addition to the primary proposed approach s et forth in the Solid Waste Definition rule, the rule solicits comments on an al ternative 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 datab ase to facilitate EPA’s rulemaking3

decisions: the Proposed Approach Database, and the Alte rnative Approach Database. These databases contain information for waste-firing units as de fined 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 th e Phase II survey using both the Microsoft ® Excel spreadsheet templates and the EPA’s E RT. To avoid duplicate records in the CISWI emissions database, the following hierarchical appro ach was developed to determine which data to incorporate into the database:

1. If a test report summary (either hard or electronic co py) and an electronic data summary (either ERT or Microsoft ® Excel spreadsheet t emplate) were provided, the electronic data summary was used in the emissions da tabase to minimize data entry and processing time.

2. If the Microsoft ® Excel spreadsheet template and an E RT file contained data for the same pollutant, the Microsoft ® Excel spreadsheet t emplate was used to populate the emissions database.

3. If the respondent did not provide a Microsoft ® Excel sprea dsheet template for a pollutant, the ERT data was used in the emissions database

. 4. After the data from the ERT and Microsoft ® Excel spre adsheet templates were consolidated, any pollutants with negative or zero values or suspected outliers for high or low emission rates were compared to the hard co py and electronic files to confirm these questionable values. If the test report had values that differed from the ERT or Microsoft ® Excel spreadsheet templates, th e 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 th e test list were also reviewed for any pollutants not reported in the ERT or M icrosoft ® Excel spreadsheet templates. These data gaps were reviewed to dete rmine 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 certa in 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 databa se were taken directly from the Microsoft ® Excel spreadsheet templates or ERT files a s populated by the respondent. However,

additional data fields were added to the database to standa rdize the various types of qualitative and quantitative data reported. These fields allowed for a nalysis 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 the4

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 data base 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 t o 7 percent oxygen (ppmvd @ 7% O 2 ) for hydrogen chloride (HCl), hydrogen fluoride (HF), sulfur dioxide (SO 2 ), carbon monoxide (CO), and nitrogen oxides (NOx);

• Milligrams per dry standard cubic meter, corrected to 7% O 2 (mg/dscm @

7% O 2 ) for metals (including cadmium (Cd), mercury (Hg), and lea d (Pb)), condensable particulate matter (PM), filterable PM; PM 10 ; PM 2.5 ; total PM (including condensables);

• Nanograms per dry standard cubic meter, corrected to 7% O 2 (ng/dscm @

7% O 2 ) for dioxin/furans (both totals and specific congeners); an d

• 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 em issions data reported in units of lb/hr, lb/ton of kiln feed, lb/ton clinker, and zero emi ssions values were not able to be converted

to the standardized units due to the lack of volumetric flo w 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 i nput 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) an d control(s) used during the reported ERT

test results were assumed to be identical to the fuel an d 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 a ny 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 sur vey. For facilities with outlying emissions test data, test reports were reviewed to confir m the fuels and controls installed during

the tests.

3.2.3 Fuel Types

Fuel type is reported in 6 tables in the database. To assi gn CISWI units to a fuel category and analyze data across different fuel types, these repor ted fuels needed to be standardized across all data tables where fuel type is used to characterize th e unit. Table 1 shows each occurrence of5

“fuel” in the database and the corresponding standardized fuel field. The reported design capacity fuels were not standardized because they do not n ecessarily 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

Fuel Common Fuel Data: Materials Combusted

NRC_Fuel Common NRC_Fuel

Data: Non-Fossil Fuels NonFossilFuel Common Fuel

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

database. The level of detail within the common fuel ca tegories were based on fuel categories provided in Appendix C of the Survey Overview Document 1 . If the reported fuel did not match any of the corresponding fuel categories in Appendix C, a ne w common fuel category was

created.

Fuels were occasionally reported as a mixture of fuels wi thin a single record. Each reported fuel in the mixture was standardized to the format listed in Appendix C of the Survey

Overview Document 1 , separated by “and” in the standardized fuel field. For e xample, 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 se ries of drop-down lists in the Microsoft ® Excel spreadsheet templates. These templa tes 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 use d in the database.

3.2.4 Air Pollution Control Devices6

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

Table 2 shows the occurrence of “control device” in the databa se 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 Control Device

The standardized control types were based on the list of control devices provided in the drop down lists in the Survey Answer Key 2 . If the reported control did not match any of the corresponding control devices in the Answer Key, a new c ontrol 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 t emplates also allowed industry to select “other control device” and enter a description of the co ntrol device installed on the unit. In these cases, the description was what was reported as the cont rol type in the database.

Occasionally, combinations of control devices were ente red when respondents selected “other control device” from the drop-down list of cont rols 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 standard ized field.

3.2.5 Standardizations of Reported Emission Test and CEMS Data

The emissions data obtained from test reports and conti nuous emissions monitoring systems (CEMS) were standardized to provide a common b asis 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 dat a, all emissions data were imported into the survey results database in a text field format. N umeric 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 re spondents were asked to enter the detection limit for a given pollutant and test by enclosi ng the detection limit in brackets. Any reported data in this format was deemed non-detect and the v alue inside the brackets was used as the detection limit. Non-detect data were also reporte d in other formats; therefore, any reported data that included any text other than a numeric value wer e considered to be “non-detect”. For example, if the reported emission value was “ND 0.5,” th e 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 repor t any units of measurement corresponding to that value. These data po ints were compared to other data points from the same facility, unit, and pollutant. If there w ere additional data with reported units of

measure and the value without units of measure was of the same order of magnitude, the7

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 assum ed that the “12” was intended to be “12 ppm.” If the reported emission value without any u nits 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 rec overy 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 facilit y did not report a total heat input value and instead reported fuel input rates, the sum of all standardi zed 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 emissio ns per mass of fuel combusted. To standardize these reported values into units of lb/MM Btu, 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 c ommon specification of oil reported to be combusted in the ICR. An unspecified type of coal was as signed 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 Memo randum from Jack Johnson, ERG, to Fred Porter, US EPA 3

.

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 O 2 and/or moisture present in the exhaust stream to be standardized to a percent. The 2008 Combustion Survey asked for O 2 and moisture to be reported as percent and it was assum ed that all reported values were already in these units since the survey respondent could not specif y other units of measure. Values such

as “0.05” were assumed to be “0.05%” and not “5%” since the sur vey specifically asked for units in percent format.

Because a percentage cannot be greater than 100, the O 2 and moisture contents were reviewed to ensure that no reported data were above that thr eshold. If a facility did not submit

O 2 or moisture data, the standardized fields were not populat ed. Oxygen data were only a survey requirement when reporting carbon monoxide data. If the reported units of measure for other pollutants required an O 2 concentration for standardization, an O 2 concentration of zero percent

was used in the conversion calculation.8

3.2.8 Exhaust Flow Rate

Some emissions conversions required the exhaust stream f low rate to be standardized to dry standard cubic feet per minute (dscfm). Any reported unit o f 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 fo r “standard.” If a unit reported an “s” but no “d” (such as “scfm,” an acronym for “standard cubic fe et per minute”), the units were corrected for moisture where percent moisture informati on 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 t emperature to be standardized to degrees Fahrenheit (°F). Any standardized temperature grea ter 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 o rder of magnitude for the reported and standardized temperature values was reduced to main tain consistency between all data points at that facility. For example, if a fac ility 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 e missions test based on the fuel reported during the test, and that value was used in the standa rdization 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 table 4

.

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 provi de 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 rep orted 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 de sign capacities to standardize the parameter to the preferred units of measure. Next, a lis t was created to identify unique units of measure reported with each design capacity. This list w as 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 no t report any units, the design capacity was compared to design capacities from oth er combustion units at the same facility. If additional combustors of a sim ilar 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 reporte d 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, t he “Standardized CapacityUnit” field was updated to “unknown.”

• If the user selected units of measure for the design capac ity from the survey drop down menu and also provided a note about these units in th e 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 entere d in the standardized design capacity and design capacity unit fields.

Design capacities for multiple units at the same faci lity were compared to find errors conversions (see Standardization of Reported Data from the Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units Memo 5 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 point s. Standardized design capacities greater than 1,800 MMBtu/hr were deemed illogical and the “S tandardized 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 Admin istrator may distinguish among classes, types (including mass-burn, refuse-derived fuel, modu lar and other types of units), and sizes of units within a category in establishing such standar ds. The degree of reduction in

emissions that is deemed achievable for new units in a cat egory 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 be st 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 da te such standards are promulgated, whichever is later).10

For evaluating alternative standards, CISWI units were subca tegorized based on

fundamental technical differences and other differences i n 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 he at recovery),

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

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

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

• Small, remote incinerators (small incineration units loca ted 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 ar e 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 al l serve the same purpose; reduction in the

volume of solid waste materials. Incinerators can b e operated on a batch or continuous basis. The same types of add-on controls, including fabric filt ers, 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 vari able 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 s uch that the incinerators can achieve the same level of performance for the nine regulated pollutan ts.

Energy-recovery units : Energy recovery units are typically waste-fired bo ilers and process heaters that combust solid waste materials as a percen tage 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 typical ly 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 maint ain combustion temperature. Energy recovery units are also different from incinerators in t erms of how the fuel is fed into the combustion chamber, the combustion chamber design (which typically includes integral heat recovery), and other operational characteristics. The se differences can result in emission profiles for energy recovery units that are different from inci nerators but similar to boilers. Combustion of waste materials in these units impacts the emission s 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 la rger 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 t ires) may also in some cases be fed at the midpoint of the kiln. Some kilns also have a large prehe ater 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 distinc tion is that for cement kilns, the source of most of the pollutants is typically the raw m aterials, not the fuels, and emissions from11

the raw materials and the solid wastes and fuels are co mingled 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 co ntrols.

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

combustion units that are used to clean residual material s from various metal parts that are then reused in the process. The amount of waste combusted in t hese units is generally small (pounds per year in some cases) and the configuration of the sta cks 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 tha n 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 lo cated 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 utilit ies. We believe this would impact their ability to meet emission limits for pollutants control led 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 transpo rting 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 dur ing 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 i n the Data:Facility were also added to the CISWI unit database. These fields were populate d using the physical address provided by the facility along with TeleAtlas's Geocoder U SA_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 C ombustion 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 C ombustion 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/ES D, 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 C ombustion 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, SO 2 , and PM. Data CEMS Backgrnd Background information for continuous emissions monitoring data for CO, NOx, SO 2 , and PM.

Data Emissions Tests Emissions test data for dioxin/furan s (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; PM 10 ; PM 2.5 ; condensable PM; total PM (including condensables), phosphorus; selenium; silver; SO 2 ; 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 Emissio ns 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 co nvert 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 burne d 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 rela ted to

the units listed in the Incinerator table.

Data Incinerator Waste Management Information on the type of waste related to the units lis ted in the Incinerator table and provides information on alterna tive 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 Ove ns,’ ‘Air Curtain Incinerators,’ ‘Waste-burning Kilns,’ and ‘Sma ll, Remote’ units (see Subcategorization Memo.) Data Materials Combusted Information on the type of mat erials combusted related to the units listed in the Unit Design/Operation table. Data Non-Fossil Fuels Information on the type of non-f ossil 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 poll utant
emission limits. Data Stack Background stack information for units listed in t he Unit Design/Operation table including whether the stack is a s ingle, common, or multiple stack. Data Unit Design/Operation The units subcategorized as Ener gy 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 cont ained in the database with their associated subcategory and contr ol

device.15Appendix B: Data Conversion TableVariableFromToData RequiredConstantsConversion Equationlb/hr mg/dscm flow rate (dscm/m)453.592 g/lb60 m/hr1000 mg/g(mg/dscm) = (lb/hr)*453592/(60*dscm/m)gr/dscf mg/dscm (applies to PM)7000 gr/lb35.31 ft3/m3453592 mg/lb(mg/dscm) = (gr/dscf)*35.31*453592/7000lb/MMBtu mg/dscm F-Factor7(mg/dscm) = ((lb/MMBtu)/(F-Factor))*35.31*453592mg/dscm ppmvd(ppmvd) = (mg/dscm)/(0.041552*(MW))ppmvd mg/dscmMolecular Weight (MW):NO2 = 46 lb/molCO = 28.01 lb/molSO2 = 64.06 lb/molHCl = 36.45 lb/molHF = 20.01 lb/mol.041552 mg/dscm (@ 7%O2 and 68oF)(mg/dscm) = 0.041552*(MW)*(ppmvd)mg/dscm ng/dscm (ng/dscm) = (10^6)*(mg/dscm)ppmv ppmvd moisture (%H2O) (ppmvd) = (ppmv)*100/(100 - %H2O)Pollutantemissionat X%O2 at 7% O2 O2 content (%O2) (at 7% O2) = (at X%O2)*(20.9 - 7)/(20.9 - %O2)dscf/m dscm/m 35.315 ft3/m3 (dscm/m) = (dscf/m)/35.315Flow ratescf dscf moisture (%H2O) (dscf) = (scf)*(100 - %H2O)/1007F-Factors for each unit are dependent on the fuel type combusted. Refer to Table 4C in the ComplianceCost Analyses for Existing CISWI Units Memo7for a list of assigned F-Factors