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MEMORANDUM

TO: Jim Eddinger, U.S. Environmental Protection Agency, OAQPS

FROM: Eastern Research Group, Inc.

DATE: August 2012

SUBJECT:   Revised (August 2012) Summary of Test Report Data Review from Best

Performing Units at Industrial, Commercial, and Institutional Boilers and Process

Heaters National Emission Standards for Hazardous Air Pollutants ‐ Major Source

1.0 INTRODUCTION

This memorandum describes the procedures used to review test reports from best

performing units in each subcategory for consistency in reporting stack test and laboratory

data.  ERG reviewed test reports for the top performing emitters of carbon monoxide (CO) and

filterable particulate matter (PM).  EPA reviewed test reports for the top performing emitters of

hydrogen chloride (HCl), mercury (Hg), and eight metallic hazardous air pollutants (TSM8).  This

memorandum focuses only on the differences in the methods used to review top performer

test reports since the review conducted for the December 21, 2011 proposed reconsideration

of the rule (76 FR 80598).  The methods used to review test reports for the proposed

reconsideration of the rule are provided in another memorandum.1

This memorandum is organized as follows:

1.0 Introduction

2.0 Carbon Monoxide Data Review

3.0 Filterable Particulate Matter Data Review

4.0 Hydrogen Chloride Data Review

5.0 Mercury Data Review

6.0 Metallic HAP Data Review
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7.0 References

Appendix A:  Summary of Filterable Particulate Matter Data Review

Appendix B:  Summary of Hydrogen Chloride Data Review

Appendix C:  Summary of Mercury Data Review

Appendix D:  Summary of Metallic HAP Data Review

   
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2.0 CARBON MONOXIDE DATA REVIEW

ERG conducted a review of test reports for the carbon monoxide (CO) top performers

for two main purposes:  First, the test reports were reviewed for consistency.  Second, the test

reports were reviewed to obtain CO calibration span information for the purposes of estimating

CO measurement error that could be applied to the CO emissions testing data in the EPA ICR

Databases.  The methods used to develop and implement CO measurement error, as well as a

list of the top performer test reports reviewed for CO consistency are provided in another

memorandum.2 None of the test reports reviewed for CO consistency required  

3.0 FILTERABLE PARTICULATE MATTER DATA REVIEW

As was done in the previous analysis, the total filterable particulate matter (PM) mass

was adjusted upward to account for negative filter weights, as well as adjusting for improper

reporting of non‐detect sample portions.  However, the guidance provided in 64 FR 53028 was

revised by EPA; it was determined that the appropriate method detection limit (MDL) for

Method 5 is 2 milligrams (mg) instead of 1 mg.  The change in the MDL for Method 5 is

explained in another memorandum.3 If the revised total PM catch for any test run was less than

2 mg, the total catch was revised upward to 2 mg and the PM emission rate was recalculated.  

The emission rates, in units of pounds of PM per million British thermal units of heat input

(lb/MMBtu), were calculated using Equation 1below.

ܧ௉ெ ൌ ቀ ଵ

ସହଷ,ହଽ଴ቁ ቀ௠ುಾ

௏ೞ೟೏

ቁ ሺܨ஽ሻ ቀ ଶ଴.ଽସ଺

ଶ଴.ଽସ଺ିைమ

ቁ           (Equation 1)

Where:

EPM = PM emission rate, lb/MMBtu

453,590 = Conversion factor, milligrams to pounds

20.946 = Approximate amount of oxygen in ambient air, percentage

mPM = Total PM catch, milligrams

Vstd = Sample volume, cubic feet at dry standard conditions (dscf)

FD = Fuel‐specific factor from Method 19, dscf per MMBtu

O2 = Reported oxygen concentration at stack conditions, percentage

In total, there were 73 test reports reviewed for consistency in PM data.  Not all best

performing boilers had test reports available, but a majority of the units were covered.  
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Appendix A‐1 contains the raw data extracted from the PM test report review.  Appendix A‐2

contains the results of the top performer emissions testing data that were modified or removed

based on the review of the test reports.

The results of the top performer PM test reports reviewed during the previous analysis

were reviewed to see if any required updating based on the new Method 5 MDL guidance from

EPA.  It was found that 43 test runs previously reviewed required an additional update based on

the updated guidance.  The emission rates for these test runs were recalculated using Equation

1 above.  Not all 43 test runs were updated in the EPA ICR Databases for multiple reasons, such

as the facility shutting down.  A summary of the previously reviewed test runs that were

updated in the EPA ICR Databases is provided in Appendix A‐3.  

4.0 HYDROGEN CHLORIDE DATA REVIEW

EPA conducted a review of the top performing hydrogen chloride (HCl) test reports.  

Results were provided on a pass/fail basis on the test run level.  Based on EPA’s

recommendation, tests that were flagged as failures were disregarded from any future analyses

involving HCl emissions data.  If only one run in the test was flagged as a failure, only that run

was ignored from future analyses.  If two runs in a single test were flagged as failures, the

entire test was ignored from future analyses even if the remaining run exhibited no issues.  A

total of 18 test reports were reviewed for consistency in HCl data.  Appendix B contains a

summary of the HCl test report review conducted by EPA, as well as appropriate notation on

which test runs were disregarded.

5.0 MERCURY DATA REVIEW

EPA conducted a review of the top performer mercury (Hg) test reports.  As was done

for HCl, results were provided on a pass/fail basis on the test run level.  A total of 29 test

reports were reviewed for consistency in Hg data.  The same methodology used to disregard

test runs flagged as failures from the HCl test report review was used to ignore the Hg test runs

flagged as failures.  Appendix C contains a summary of the Hg test report review conducted by

EPA, as well as appropriate notation on which test runs were disregarded.
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6.0 METALLIC HAP DATA REVIEW

EPA conducted a review of top performer test reports for the sum of eight metallic

hazardous air pollutants (HAP) (TSM8).  These metals include arsenic (As), beryllium (Be),

cadmium (Cd), chromium (Cr), lead (Pb), manganese (Mn), nickel (Ni), and selenium (Se).  EPA

provided pass/fail nomenclature as was done for Hg and HCl, but also provided a corrected

total sample catch for each of the eight metals.  Using the same methods as used to flag the Hg

and HCl failed test runs, the TSM8 test runs flagged as failures were ignored for future analyses.

The corrected sample catches, in units of micrograms (μg), were used to recalculate the

emission rates for each metal in the EPA ICR Databases.  These revised metallic HAP emission

rates were then used to re‐calculate the corresponding TSM8 emission values for the same test.  

Based on other information provided in the test report, the metallic HAP emission rates were

revised using Equation 2 below.

ܧெ௘௧௔௟ ൌ ቀ ଵ

ସହଷ,ହଽ଴,଴଴଴ቁ ቀ௠ಾ೐೟ೌ೗

௏ೞ೟೏

ቁ ሺܨ஽ሻ ቀ ଶ଴.ଽସ଺

ଶ଴.ଽସ଺ିைమ

ቁ         (Equation 2)

Where:

EMetal = Metallic HAP emission rate, lb/MMBtu

453,590,000 = Conversion factor, micrograms to pounds

20.946 = Approximate amount of oxygen in ambient air, percentage

mMetal = Total metallic HAP catch, micrograms

Vstd = Sample volume, cubic feet at dry standard conditions (dscf)

FD = Fuel‐specific factor from Method 19, dscf per MMBtu

O2 = Reported oxygen concentration at stack conditions, percentage

In total, there were 56 test reports reviewed for consistency in TSM8 data.  Not all best

performing boilers had test reports available, but a majority of the units were covered.  

Appendix D contains the raw data extracted from the TSM8 test report review, as well as the

results of the top performer emissions testing data that were modified or removed based on

the review of the test reports.

   
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7.0 REFERENCES

1. Eastern Research Group, Inc.  Summary of Test Report Data Review from Best

Performing Units at Industrial, Commercial, and Institutional Boilers and Process Heaters

National Emission Standards for Hazardous Air Pollutants ‐ Major Source.  November

2011.

2. Eastern Research Group, Inc.  Incorporating Measurement Error in Reported Carbon

Monoxide (CO) and Total Hydrocarbon (THC) Data (Revised August 2012).  August 2012.

3. Merrill, Ray, U.S. EPA OAQPS SPPD.  Revision of Estimated Method 5 Detection Limit.  

May 23, 2012.

   
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Appendix A

Summary of Filterable Particulate Matter Data Review

   
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Appendix B

Summary of Hydrogen Chloride Data Review

   
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Appendix C

Summary of Mercury Data Review

   
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Appendix D

Summary of Metallic HAP Data Review