MEMORANDUM

TO: Brian Shrager/SPPD

FROM: Eastern Research Group , Inc.

DATE: November 2011

SUBJECT: Revised (November 2011) Standardization of Reported Data from the Public Comment Period and Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units

1.0 INTRODUCTION

This memorandum discusses the changes since the promulgation of the March, 2011 final rule (76 FR 15608) in the methods used to standardize unit

- level and emissions data reported by industry under the development of the Major Source Industrial, Commercial, and Institutional Boiler and Process Heater NESHAP. The methods used to standardize data for consideration in the promulgated rule are des cribed in the memorandum, “Revised Standardization of Reported Data from the Public Comment Period and Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units” in the docket

. 1 This memorandum only discusses the changes in method ology, and incorporates the memorandum for the promulgated rule by reference. This memorandum is divided into the following sections:
1.0 Introduction 2.0 Summary of Changes in Standardization Methodology 3 .0 References Appendix A: New Pollutant Emissions Conversion Equations Appendix B: Changes to Fuels for Emissions Testing Data Appendix C: Summary of Changes in Control Configurations2.0 SUMMARY OF CHANGES IN STANDARDIZATION METHODOLOGY

This section summarizes the changes in standardization methodology since the promulgated March, 2011 rule. The methods used to standardize unit

- level and emissions data for the promulgated rule are described in the memorandum, “Revised Standardization of Reported Data from the Public Comment Period and Questionnaire for Boilers, Process Heaters, Incinerators and Other Combustion Units” in the docket 1 . The majority of the methods used to standardize data remained unchanged for the reconsideration of the promulgated rule; only the changes to the standardization methodolog y are discussed in this section.

2. 1 New Pollutant Emission Conversion Equations Two new pollutant emission conversion equations were created in order to standardize additional emissions data received during the reconsideration proposal period. These two equations are presented in Appendix A of this memorandum. The first equation standardizes emissions reported as concentrations corrected to a carbon dioxide (CO 2 ) percentage into the
desired concentrations cor rected to three percent O 2 . The equation is derived from Equations
19

- 1 and 19

- 6 from EPA Method 19

. 2 Emissions are first converted into an emission factor using a carbon F factor (F c ) using Equation 19

- 6 from Method 19. The resultant emission factor is then converted back into a concentration usin g a dry F factor (F d ) and Equation 19

- 1 from Method 19. These separate conversions were combined into one equation. Some emissions data were initially reported in concentrations corrected to a CO 2 percentage for the development of the Major Source Indust rial, Commercial, and Institutional Boilers and Process Heaters NESHAP; those data were not utilized in any impacts analyses for the promulgated rule. The previously

- reported emissions data and new emissions data reported as concentrations
corrected to a CO 2 percentage were standardized and utilized in the impacts analyses and the development of MACT floors for the reconsideration proposal. The methods used to estimate cost and emission impacts and the methods used to develop MACT floors are provided in o ther memoranda

. 3,4 The second equation standardizes dioxin/furan emissions data reported in units of micrograms per cubic meter at seven percent oxygen (μg/dscm @ 7% O 2 ) into the desired units of nanograms per cubic meter at seven percent oxygen (ng/dscm @ 7% O 2 ). Additionaldioxin/furan emissions data were reported in units of μg/dscm @ 7% O 2 ; no dioxin/furan emissions data had previously been reported in these units of measure. A summary of all new emissions data submitted after the promulgation of the March, 2011 final rule is presented in another memorandum

. 5

2. 2 Molecular Weight Change for NO x When standardizing emissions data from a heat input basis to a concentration (or vice versa), the molecular weight of the specific pollutant in question is used in the standardization equation. Industry reported emissions testing and continuous emissions monitoring (CEMS) data for NO x in units of lb/MMBtu; the standardization of these data required a molecular weight for NO x in order to convert to parts per million (ppm) concentrations. All analysis conducted for the promulgated rule used a molecular weight of 76.0116 grams per gram

- mole (g/mol). Emissions of NO x primarily consist of nitric oxide (NO) and nitrogen dioxide (NO 2 ), and thus the molecular weigh t used to standardize emissions data for the promulgated rule was the

sum of the molecular weights of these two compounds. However, the U.S. EPA guidance for developing emission factors suggests using only the molecular weight of NO 2 (46.01 g/mol)
when analyzing or standardizing NO x emissions

. 6 All NO x emissions data were re

- standardized using th is corrected molecular weight, where necessary.

2.3 Changes to Toxic Equivalency Factors It was determined that toxic

- equivalent dioxin/furan (TEQ D/F) emissions were calculated improperly for the March, 2011 rule. TEQ D/F emissions are calculated by multiplying the total mass emissions of 17 specific congeners by their respective toxic equivalency factor (TEF). This provides standardized emissions of a ll congeners on a relative toxicity basis. The procedures used to calculate TEQ D/F emissions are detailed in another
memorandum. 7 For the March, 2011 rule, the 2005 World Health Organization toxic equivalency factor for octa

- chlorinated dibenzodioxins an d octa

- chlorinated dibenzofurnas was applied to all dioxin/furan congeners for which a TEF was not specified. 8 These additional congeners for which a TEF was not specified should not have been factored into the TEQ D/F
calculation since these congeners hav e a TEF of zero. TEQ D/F emissions were recalculated in
the EPA ICR databases for only the select 17 congeners.2.4 Corrections to Fuels Combusted during Emissions Testing Fuel information was not readily available for all reported emissions testing dat a. For several data sets

— particularly those reported in the Electronic Reporting Tool (ERT)

— assumptions were made as to the specific fuels combusted during the emissions testing period. These assumptions were typically based on other reported data sets f rom the same facility, or based on the universe of fuels specified to be combusted by the particular emission unit. These assumptions were investigated for their accuracy. A summary of the resultant changes based on this review is provided in Appendix B.

2.5 Comparison of Controls Installed Versus Controls Employed for Emissions Testing Control devices were reported in several parts of the ICR survey. Some of the controls represented current configurations while other controls represented historical control device configurations. Facility correspondence from the University of Notre Dame ( facility ID: INNotreDame) specified that previously

- reported test data should be disregarded since the emissions control technologies employed by their units have been upgraded since the emissions testing occurred. This correspondence initiated an invent ory
- wide investigation into the units which reported test data employing outdated control configurations. This review led to test data being designated as being outdated and inappropriate to use for 22 boilers or process heaters because the data were representative of historical control configurations . A list of these units and an explanation of the data that were disregarded is provided in another memorandum. 4 This review also led to changes in the total level of control currently installed on 9 specific units. These c hanges in control type also affected the emissions and cost impacts estimated for the units. The methods used to estimate emission and cost impacts are described in another memorandum. 3 A summary of the changes to t he level of control for these 9 units is provided in Appendix C.3 .0 REFERENCES

1. Gibson, G., and A. Singleton, ERG. Revised Standardization of Reported Data from the Public Comment Period and Questionnaire for Boilers, Process Heaters, Incinerators an d O ther Combustion Units. January 2011.

2

. U.S. Environmental Protection Agency. Method 19

– Determination of Sulfur Dioxide Removal Efficiency and Particulate Matter, Sulfur Dioxide, and Nitrogen Oxide Emission Rates.

3

. Eastern Research Group , Inc

. Revised (November 2011) Methodology for Estimating Cost and Emissions Impacts for Industrial, Commercial, and Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants

– Major Source. November 2011.

4

. Eastern Res earch Group , Inc . Revised MACT Floor Analysis (November 2011) for the Industrial, Commercial, and Institutional Boilers and Process Heaters National Emission Standards for Hazardous Air Pollutants

– Major Source. November 2011.

5. Eastern Research Group , Inc . Handling and Processing of Corrections and New Data in the EPA ICR Databases

– Revised November 2011. November 2011.

6

. U.S. Environmental Protection Agency. Procedures for Preparing Emission Factor Documents. EPA

- 454/R

- 95

- 015. Revised Novembe r 1997.

7. Eastern Research Group , Inc . Revised November 2011 Development of Baseline Emission Factors for Boilers and Process Heaters at Commercial, Industrial, and Institutional Facilities. November 2011.

8. Van den Berg, M. et. al. The 2005 World H ealth Organization Reevaluation of Human and Mammalian Toxic Equivalency Factors for Dioxins and Dioxin

- Like Compounds. Oxford Journals: Toxicological Sciences. Volume 93, Issue 2. July 2006.APPENDIX A

New Pollutant Emissions Conversion EquationsTable A

- 1: New Pollutant Emission Conversion Equations Added since Promulgation
Reported Emission

Units Associated Pollutants EQ ID Conversion Equation Resulting Converted Emission Units ppm @ 12% CO 2 1 Non

- metals FF11 * (100/12% CO 2 ) * ((20.946

- 3)/20.946) * (F c /F d ) ppm @ 3% O 2 μg/dscm @ 3% O 2 Dioxin/Furans FF13 * (1000 ng/ug) * ((20.946

- 7)/(20.946

- 3)) ng/dscm @ 7% O 2

1 Conversion is derived from Equations 19

- 1 and 19

- 6 from EPA Method 19. Emission concentration s are first standardized to a lb/MMBtu emission factor using a carbon F factor (F c ) and Equation 19

- 6. Then, the emission factor is converted back to a concentration using a dry F factor (F d ) and Equation 19

- 1. Equation FF11 in the table above combines those two ste ps into one equation. A list of F c and F d (in dscf/MMBtu) for specific fuels can be found in Table 19

- 2 of EPA Method 19.APPENDIX B
Changes to Fuels for Emissions Testing DataAPPENDIX C
Summary of Changes in Control Configurations