From: Hanks, Katie P.

Sent: Tuesday, October 19, 2010 1:32 PM

To: Pinkerton, John

Cc: Schrock.Bill@epamail.epa.gov

Subject: RE: Survey ‐ CEMS Spreadsheet

My initial thoughts are below, and I envision some related clarifications in the survey instructions.

Just to clarify – SO2, NOx, CO, and opacity CEMS data from boilers are not being requested, correct?

‐>  CEMS data are not being requested for boilers.  No stack test data is requested for boilers either.

Entering CEMS data into the survey spreadsheets may have to be done by hand, depending on how  

the CEMS software is configured.  Hourly production rates may not be coupled to the CEMS data since  

most limits are concentrations.  A less burdensome alternative would be submission of existing CEMS  

data summaries or the quarterly/semi‐annual exceedance reports.

‐> Hand entry  of that many records is not feasible and should not be expected.  It seems reasonable  

to me to request data in the preferred spreadsheet format but allow other alternative formats if the  

records cannot feasibly be structured in the spreadsheet format.  A format suitable for data analysis  

would be needed (e.g., pdf reports of thousands of records are not useful) so we’d need to request  

electronic (e.g., spreadsheet or data base format) wherever possible.  We ran into facilities submitting  

pdf data in the electric utilities survey (and had to call facilities back to request data in an analyzable  

form – which many of them had).  The excess emissions reports would be useful if no other data are  

available (but summaries aren’t as helpful in understanding the hour‐to‐hour variability in emissions).   

                                         

Regarding opacity, the Subpart MM and Subpart BB NSPS require 6‐minute averages.  It is unlikely  

hourly averages have been calculated.  

‐>The hourly average column is shaded.  I believe we put it there in case someone had hourly average  

data (but not 6‐minute average data).  Perhaps we should just delete the hourly average column.   

The number of pulp mill units with CEMS data is significant:

Kraft recovery furnaces – 147 TRS, 50 SO2, 30 NOx, 31 CO, 146 opacity (a few units have two stacks with  

a monitor on each)

Lime kilns – 117 TRS, 34 opacity, about 5 SO2, NOx, and CO.

‐>Not surprising, but very helpful to know specifics.  I see many megabytes of data storage in the  

future (considering the blank spreadsheet is 8 MB).  We’ll need to clarify that CEMS data for both  

stacks are requested (would be quite interesting to see how they compare).   

As far as we know, there are no PM, methanol, chlorine, or other HAP CEMS systems in use.   

‐>Not surprising, but the questions are in there just in case (particularly since some of these CEMS  

were written into the rules as monitoring options). It is helpful to know what compliance and  

monitoring options mills are using (or not using).  
Katie Hanks

RTI International

3040 Cornwallis Road (800Pk‐C314)

Research Triangle Park, NC 27709

(919) 316‐3732

(919) 541‐7155 (fax)

From: Pinkerton, John [mailto:JPinkerton@NCASI.org]   

Sent: Tuesday, October 19, 2010 7:52 AM  

To: Hanks, Katie P.  

Subject: Survey ‐ CEMS Spreadsheet

Katie,

Just to clarify – SO2, NOx, CO, and opacity CEMS data from boilers are not being requested, correct?

Entering CEMS data into the survey spreadsheets may have to be done by hand, depending on how  

the CEMS software is configured.  Hourly production rates may not be coupled to the CEMS data since  

most limits are concentrations.  A less burdensome alternative would be submission of existing CEMS  

data summaries or the quarterly/semi‐annual exceedance reports.

                                       

Regarding opacity, the Subpart MM and Subpart BB NSPS require 6‐minute averages.  It is unlikely  

hourly averages have been calculated.  

The number of pulp mill units with CEMS data is significant:

Kraft recovery furnaces – 147 TRS, 50 SO2, 30 NOx, 31 CO, 146 opacity (a few units have two stacks with  

a monitor on each)

Lime kilns – 117 TRS, 34 opacity, about 5 SO2, NOx, and CO.

As far as we know, there are no PM, methanol, chlorine, or other HAP CEMS systems in use.   

John

John Pinkerton

NCASI

National Council for Air and Stream Improvement, Inc.

P.O. Box 13318

Research Triangle Park, NC 27709‐3318

Telephone:  919‐941‐6406

Fax:                   919‐941‐6401

Deliveries:   4815 Emperor Boulevard, Suite 110, Durham, NC 27703

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