1 MEMORANDUM

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

FROM: Eastern Research Group, Inc.

DATE: August 2012

SUBJECT: Beyond the Floor Technology Analysis for Major Source Boilers and Process

Heaters (Revised August 2012)

1.0 INTRODUCTION

This memorandum describes the selection of “beyond

‐ the

‐ floor” (BTF) control options

for filterable particulate matter (PM), mercury (Hg), and hydrogen chloride (HCl) for the boiler

MACT reconsideration amended final rule. The overall approach to the BTF technology analysis

is described in the docketed memo entitled “Beyond the Floor Technology Analysis for Major

Source Boilers and Process Heaters,” January, 2011, that was developed in support of the final

boiler MACT that was published in the Federal Register in March 2011. This beyond the floor

option compares the MACT floor emission limits in the amended final rule to the limits in the

March 21, 2011 final rule notice (76 FR 15608). Where the emission limit for PM, Hg, or HCl for a

certain subcategory has become significantly less stringent since the March 2011 rule notice, a

follow

‐ up BTF analysis was conducted to determine whether or not it was cost effective to

require controls beyond the MACT level of controls identified in this final notice. This

memorandum is organized as follows:

1.0 Introduction

2.0 Summary of Beyond the Floor Option for Existing Units

3.0 Emissions and Cost Impacts of Beyond the Floor Option for Existing Units

4.0 Effectiveness of Beyond the Floor Option for Existing Units2 5.0 Summary of Beyond the Floor Option for New Units

6.0 References

Appendix A: Summary of Beyond the Floor Analysis for Existing Sources

Appendix B: Summary of Beyond the Floor Analysis for New Sources3 2.0 SUMMARY OF BEYOND THE FLOOR OPTION FOR EXISTING UNITS

This section summarizes the subcategories chosen for the beyond

‐ the

‐ floor (BTF)

technology analysis for existing sources, and also summarizes the aspects of the BTF option.

2.1 Comparison of Emission Limits

In this BTF option, the PM, Hg, and HCl emission limits in the 2012 final reconsideration

notice were compared to the emission limits in the March 21, 2011 final rule notice (76 FR

15608). Carbon monoxide (CO) was not considered for the BTF option because oxidation

catalysts are the only control type considered in this rulemaking that achieve reductions in CO

emissions. The use of an oxidation catalyst for a BTF option for CO is not cost

‐ effective for the

minimal additional reduction in organic hazardous air pollutants (HAP) that would be achieved.

If an emission limit for a subcategory has become much less stringent since the March

2011 rule notice, the BTF option was analyzed for that subcategory. Tables 1 through 3 show a

comparison of the PM, Hg, and HCl limits between the two rule notices, respectively. The tables

also identify the subcategories and pollutants to which a BTF option was analyzed.

Table 1

– Comparison of March 2011 Existing PM Emission Limits to Amended Final Rule

Fuel Category Combustor Design March 2011

Limit

(lb/MMBtu) Amended Final

Rule MACT

Floor Limit

(lb/MMBtu) % Change BTF Option

Applicable?

Coal FB 0.039 0.039 0% No

FB

‐ HE 0.039 0.039 0% No

PC 0.039 0.039 0% No

Stoker/Other 0.039 0.039 0% No

Biomass Dutch Oven/Pile

Burner 0.039 0.18 362% YES

FB 0.039 0.11 182% YES

Fuel Cell 0.039 0.02

‐ 49% No

Suspension Burner 0.039 0.051 31% No

Suspension/Grate 0.039 0.44 1,028% YES

Wet Biomass Stoker/Other 0.039 0.034

‐ 13% No

Dry Biomass Stoker/Other 0.039 0.32 721% YES

Heavy Liquid N/A 0.0075 0.062 727% YES

Light Liquid N/A 0.0075 0.0079 5% No4 Fuel Category Combustor Design March 2011

Limit

(lb/MMBtu) Amended Final

Rule MACT

Floor Limit

(lb/MMBtu) % Change BTF Option

Applicable?

Non

‐ Continental

Liquid N/A 0.0075 0.27 3,500% YES

Process Gas N/A 0.043 0.0067

‐ 84% No

Table 2

– Comparison of March 2011 Existing Hg Emission Limits to Amended Final Rule

Fuel Category Combustor

Design March 2011

Limit

(lb/MMBtu) Amended Final

Rule MACT

Floor Limit

(lb/MMBtu) % Change BTF Option

Applicable?

Solid N/A 4.6E

‐ 06 5.7E

‐ 06 24% No

Heavy Liquid N/A 3.5E

‐ 06 2.0E

‐ 06

‐ 43% No

Light Liquid N/A 3.5E

‐ 06 2.0E

‐ 06

‐ 43% No

Non

‐ Continental

Liquid N/A 7.8E

‐ 07 2.0E

‐ 06 156% No

Process Gas N/A 1.3E

‐ 05 7.9E

‐ 06

‐ 39% No

Table 3

– Comparison of March 2011 Existing HCl Emission Limits to Amended Final Rule

Fuel Category Combustor

Design March 2011

Limit

(lb/MMBtu) Amended Final

Rule MACT

Floor Limit

(lb/MMBtu) % Change BTF Option

Applicable?

Solid N/A 0.035 0.022

‐ 37% No

Heavy Liquid N/A 0.00033 0.0011 233% No

Light Liquid N/A 0.00033 0.0011 233% No

Non

‐ Continental

Liquid N/A 0.00033 0.0011 233% No

Process Gas N/A 0.0017 0.0017 0% No

Note that a positive percent change in the limits shows that limit in the amended final

rule is less stringent than the limit in the March 2011 rule. Due to the percent change in

emission limits, it was determined that the BTF option was warranted for PM for six existing

source subcategories. In these cases, the basis of control for MACT in the final reconsideration

notice is based on a level of control less stringent than the level of control assessed in the March

2011 final rule.

The Hg limits became more stringent for all subcategories except for Solid fuels and the

non

‐ continental liquid fuel subcategory. The small percent increase did not warrant the BTF

option for Hg for the Solid fuel subcategory. This is because both the March 2011 limit and the5 MACT floor emission limit for the final reconsideration notice are based on a fabric filter level of

control technology. The revised limit accounts for fuel variability and adjusted dataset values

that corrected for misreported fractions of mercury in the ICR test report data and, although it is

a less stringent number, it does not represent a level of control technology less stringent than

the basis of control in the March rule. In the non

‐ continental liquid subcategory, there was a

large increase in the MACT floor emission limit; however, this correction was based on several

non

‐ continental units shutting down. Further, upon inspection of the reported Hg baseline

emissions from the remaining non

‐ continental liquid units in operation, it was determined that

that the control efficiency required for these units to meet the beyond the floor option of the

March 2011 floor value of 7.8E

‐ 07 lb/mmBtu was not technically achievable since this floor value

required greater than a 75 percent removal efficiency, which is the highest removal efficiency

expected for mercury removal from a fabric filter. 5 For HCl, only the liquid limit became less

stringent than the March 2011 rule; although the percent change in the limit values is large, the

actual level of control required to meet the emission limit is still based on scrubbing technology

and the change in the numeric emission values were based on corrections to the dataset since

the March 2011 rule. Thus, the BTF option was not analyzed for any subcategories for HCl.

2.2 Summary of BTF Control Technology Options

Since the BTF option was only identified as necessary for PM, only the BTF control

technology options for PM were reevaluated in this analysis. In estimating the cost impacts

associated with units demonstrating compliance with the MACT floor emission limits, a fabric

filter was assumed to be the best available control technology for PM. The methods used to

develop MACT floor emission limits are provided in another memorandum. 1 The methods used

to estimate the cost and emissions impacts of the rule are also provided in another

memorandum. 2 However, comments 3,4 submitted to EPA specified that many biomass units may

have difficulty installing and operating fabric filters due to the inherent ash characteristics

resulting from biomass combustion. The comments specified that an electrostatic precipitator

(ESP) would better serve as the best available control technology for PM for sources combusting

biomass fuels. Therefore, an ESP was determined to be the BTF PM control technology for6 sources in one of the biomass subcategories, while a fabric filter was determined to be the BTF

PM control technology for the remaining subcategories.

2.3 Logistics of BTF Option

The first step in conducting the BTF analysis was to determine whether or not sources

could install any additional controls above those required to meet the MACT floor emission

limits. The following steps were used to determine which sources would install additional

control devices, such as an ESP or fabric filter for the BTF option:

1. Since the BTF option looks at the incremental impacts compared to those calculated

at the MACT floor, it was necessary to determine the level of control installed for

compliance with all of the MACT floor emission limits (PM, Hg, HCl) that could have

an effect on whether or not additional PM reductions were an option. CO controls

were not considered in this BTF analysis since these controls do not have any co

‐

benefits of removing PM. A detailed description of the compliance options for

sources to demonstrate compliance with the MACT floor emission limits are provided

in another memorandum. 2 There are 293 unique boilers and process heaters in one

of the biomass or liquid subcategories where the BTF option was analyzed that are

subject to emission limits for PM, of which 165 units reported baseline emission

levels for PM or TSM below the corresponding MACT floor emission levels specified in

the 2012 Final Reconsideration notice. The remaining 128 units were expected to

require controls to meet either the PM, TSM, Hg, or HCl emission limit, of which 124

were expected to install a fabric filter, and 4 were expected to install an ESP.

2. The 165 units demonstrating compliance with the PM or TSM MACT floor emission

limit were investigated to see if additional add

‐ on controls for a BTF option were

technically feasible. If units had already installed ESP or fabric filter equipment, we

assumed these units could not install a second ESP or fabric filter control due to

space constraints and the fact that additional ESP or baghouses in a series do not lead

to additional substantive reductions. If the unit was in a biomass subcategory and7 didn’t already have an ESP installed, it was assumed that the unit would install an ESP

for the BTF option. If the unit was in one of the liquid subcategories and didn’t

already have a fabric filter installed, it was assumed that the unit would install a

fabric filter for the BTF option. This step produced 38 additional units that could

install a fabric filter, and an additional 74 units that could install an ESP.

3. If a unit had either a pre

‐ existing ESP or had installed an ESP for compliance with the

MACT floor emission limit, and if the unit was in one of the liquid subcategories, it

was determined that the unit could replace the ESP with a fabric filter in order to

demonstrate compliance with the BTF limit. There were no units that met the criteria

for replacing a pre

‐ existing ESP with a fabric filter. Additionally, it was determined

that only one unit installing an ESP for compliance with the MACT floor limit would

instead install a fabric filter to demonstrate compliance with the BTF limit.

4. If any of the units would have been expected to install DIFF or ACI for PM, Hg, or HCl

for compliance with the MACT floor emission limit, those units would have been

investigated to see if they had a pre

‐ existing fabric filter, in which case the BTF option

would not apply. It was assumed that no incremental impacts could be estimated for

these units since they already had a fabric filter installed. However, since none of the

units in the six biomass and liquid subcategories evaluated for a BTF option were

installing DIFF or ACI, this step was not applicable.

A total of 163 boilers and process heaters in the liquid subcategories were estimated to

be able to install a fabric filter for the BTF option. Additionally, a total of 77 boilers and process

heaters in the biomass subcategories were estimated to be able to install an ESP for the BTF

option. No incremental impacts were estimated for the remaining 242 boilers and process

heaters (including 189 units not subject to emission limits) in the subcategories identified for the

BTF option.

3.0 EMISSIONS AND COST IMPACTS OF BEYOND THE FLOOR OPTION FOR EXISTING UNITS8 This section summarizes the procedures used to estimate incremental emission

reductions and annual costs for the BTF option. The resultant incremental emission reductions

and costs are also presented.

3.1 Emission Reductions

It was assumed that units installing a control for the BTF option would operate the

control to its maximum efficiency. As detailed in another memorandum, it is expected that an

ESP can achieve 98% reduction in PM emissions (95% reduction in metallic HAP) and a fabric

filter can achieve 99% reduction in both PM and metallic HAP emissions. 5 It was assumed that

units installing these controls for the BTF option would achieve the corresponding percent

reduction from their reported baseline emissions.

Since the BTF option is an alternative regulatory option, the incremental emission

reductions were estimated compared to the reductions estimated for compliance with the

MACT floor emission limits. This was accomplished by subtracting the emission reductions

estimated for complying with the MACT floor from the maximum possible emission reductions

based on the efficiency of the control. This accounts for cases where, for floor compliance,

emission reductions were estimated only for bringing baseline emissions to the level of the

MACT floor, when in reality the control may be able to achieve a much higher reduction in

baseline emissions. The methods used to estimate emission reductions for the floor are

provided in another memorandum. 2

A summary of the incremental emission reductions in PM and metallic HAP by

subcategory is provided in Table 4 below. Detailed calculations of the incremental emission

reductions for the BTF analysis for existing sources are provided in Appendix A

‐ 1.

Table 4 – Incremental PM and TSM10 Emission Reductions for BTF Option

Fuel Category Combustor

Design Incremental Emission Reductions

(tpy)

PM TSM10 1

Biomass Dutch Oven/Pile

Burner 168 1

FB 47 1

Suspension/Grate 1,884 39 Fuel Category Combustor

Design Incremental Emission Reductions

(tpy)

PM TSM10 1

Dry Biomass Stoker/Other 1,903 24

Heavy Liquid N/A 4,284 378

Non

‐ Continental

Liquid N/A 340 75

1 TSM10 represents the sum of 10 metallic HAP: As, Be, Cd, Co, Cr, Pb, Mn, Ni, Sb, and Se.

3.2 Costs

Annual costs for an ESP or fabric filter were estimated for the units installing one of the

control technologies for the BTF option. As described in another memorandum, the annual

costs for a fabric filter include bag leak detection monitoring costs. 2 There are no monitoring

costs included in the cost impacts for an ESP. The annualized costs of an ESP are a function of

the required percent reduction in PM emissions. For compliance with the floor, the ESP percent

reduction was estimated as the percent reduction necessary to bring baseline emissions down to

the level of the MACT floor emission limit. This value was not always the maximum achievable

percent reduction available for PM (98%). Since it was assumed that the installed control for the

BTF option would be operated at maximum efficiency, the costs for units installing an ESP were

based on a 98% reduction in PM baseline emissions. Fabric filter annualized costs were not a

function of variable PM removal efficiency; instead, this cost algorithm is based on a 99%

removal efficiency. In order to calculate the incremental costs, the fabric filter or ESP annualized

costs estimated for each unit for compliance with the MACT floor emission limit were subtracted

from the estimated BTF option costs. If a unit was installing a fabric filter for the BTF option, any

associated costs for a fabric filter and an ESP estimated for floor compliance were subtracted.

This accounted for cases where a unit would be replacing an ESP with a fabric filter. This

method also estimated zero incremental costs for units that were already installing a fabric filter

for floor compliance. While these units could potentially see incremental emission reductions,

they would not be subject to incremental costs since costs for a fabric filter were already

estimated for the unit at the floor. For the biomass units installing an ESP, only the floor costs

for an ESP were subtracted. Similar to fabric filters, this accounted for units which were already

installing an ESP for floor compliance. However, since the annualized cost of an ESP is10 dependent on a PM removal efficiency, some sources installing an ESP for floor compliance still

saw incremental annual costs under the BTF option. None of the biomass sources covered

under the BTF option installed a fabric filter (or DIFF) for floor compliance.

A summary of the incremental annual costs by subcategory for the BTF option is provided

in Table 5 below. Detailed calculations of the incremental costs for the BTF analysis for existing

sources are provided in Appendix A

‐ 1.

Table 5 – Incremental Annual Costs for BTF Option

Fuel Category Combustor Design Incremental

Annual Costs

($/yr)

Biomass Dutch Oven/Pile

Burner $2,073,672

FB $348,917

Suspension/Grate $24,820,518

Dry Biomass Stoker/Other $17,167,911

Heavy Liquid N/A $1,076,331

Non

‐ Continental

Liquid N/A $5,730,399

4.0 EFFECTIVENESS OF BEYOND THE FLOOR OPTION FOR EXISTING UNITS

The cost

‐ effectiveness of the BTF option was determined based on the annual cost

required to see an additional ton of pollutant reduction. Since costs and reductions are largely

dependent on the operating parameters of each boiler or process heater, the cost

‐ effectiveness

was calculated on a unit

‐ by

‐ unit basis by dividing the incremental annual cost by the incremental

emission reductions. The resultant values were then summed for each subcategory where the

BTF option was analyzed. The resultant cost

‐ effectiveness for each subcategory is shown in

Table 6, below. A summary of the incremental cost and emission impacts and the cost

‐

effectiveness of the BTF analysis for existing sources is also provided in Appendix A

‐ 2.11 Table 6 – Summary of Cost-Effectiveness of BTF Option

Fuel Category Combustor

Design Cost

‐ Effectiveness ($/ton)

PM TSM10

Biomass Dutch Oven/Pile

Burner $59,043 $20,171,264

FB $15,004 $1,219,188

Suspension/Grate $525,476 $260,449,698

Dry Biomass Stoker/Other $727,584 $172,557,242

Heavy Liquid N/A $273,068 $98,244,253

Non

‐ Continental

Liquid N/A $1,414,695 $8,921,715

As Table 6 summarizes, the incremental cost

‐ effectiveness for the metallic HAP is greater

than $1.2 million dollars per ton for any of these subcategories. Overall, the BTF option is not a

valid option for any of these six existing subcategories due to the minimal impact on the

environment and excessive costs to the individual sources.

5.0 SUMMARY OF BEYOND THE FLOOR OPTION FOR NEW UNITS

This section summarizes the subcategories chosen for the beyond

‐ the

‐ floor (BTF)

technology analysis for new sources, and also summarizes the aspects of the BTF option.

5.1 Comparison of Emission Limits

The BTF analysis was also conducted for new sources. However, instead of comparing

the new source emission limits in the final reconsideration notice to the March 21, 2011 final

rule notice (76 FR 15608), the final reconsideration notice limits were compared to the emission

limits required by the Standards of Performance for Industrial

‐ Commercial

‐ Institutional Steam

Generating Units (40 CFR 60, Subpart Db) (“NSPS”). The NSPS provides emission limits for PM,

but not for Hg or HCl. Because of this, and since the BTF option was not deemed necessary for

Hg and HCl for existing sources, the beyond the floor analysis for new sources was limited to PM

only. Table 7 below provides a comparison of the PM emission limits in the 2012 final

reconsideration notice and the emission limits in the NSPS. Similar to the analysis completed for

existing sources, the BTF option was analyzed for subcategories where the MACT floor emission

limit was less stringent than the corresponding NSPS limit.12 Table 7 – Comparison of March 2011 New Source PM Emission Limits to Amended Final Rule

Fuel Category Combustor Design NSPS Emission

Limit

(lb/MMBtu) Amended Final

Rule MACT

Floor Limit

(lb/MMBtu) % Change BTF Option

Applicable?

Coal FB 0.030 0.0011

‐ 2,627% No

FB

‐ HE 0.030 0.0011

‐ 2,627% No

PC 0.030 0.0011

‐ 2,627% No

Stoker/Other 0.030 0.0011

‐ 2,627% No

Biomass Dutch Oven/Pile

Burner 0.030 0.0032

‐ 838% No

FB 0.030 0.0098

‐ 206% No

Fuel Cell 0.030 0.020

‐ 50% No

Suspension Burner 0.030 0.051 41% YES

Suspension/Grate 0.030 0.026

‐ 15% No

Wet Biomass Stoker/Other 0.030 0.037 19% YES

Dry Biomass Stoker/Other 0.030 0.32 91% YES

Heavy Liquid N/A 0.030 0.013

‐ 131% No

Light Liquid N/A 0.030 0.0011

‐ 2,627% No

Non

‐ Continental

Liquid N/A 0.030 0.023

‐ 30% No

Process Gas N/A N/A 0.0067 N/A No

The NSPS only provides emission limits for units burning coal, biomass, or oil, or any

mixture thereof. Thus, there is no NSPS PM limit that applies to dedicated process gas units.

Because of this, and since the BTF option for the process gas subcategory was not analyzed for

existing sources, it has not been analyzed for new sources burning process gas. The new source

PM MACT floor emission limit only became more stringent compared to the NSPS for three of

the seven biomass subcategories.

5.2 Selection of Controls for New Sources

For each of the subcategories identified for the new source beyond the floor analysis in

Table 7, two model units were created to show examples of how the beyond the floor option

would work. New model units were created for stokers designed to burn dry biomass because

the original model units developed to estimate cost and emission impacts for the final

reconsideration notice contained only stoker boilers combusting wet biomass and

suspension/grate units. Two model units were developed for each of the three subcategories13 covered by the new source BTF analysis; the two model units were given a maximum rated head

input capacity of 10 and 25 million British thermal units per hour (MMBtu/hr). These smaller

model units were selected for the BTF analysis because the NSPS PM emission limit already

applies to units with a heat input capacity of greater than 30 mmBtu/hr, and thus the only units

with a potential incremental cost for going BTF for PM would be units below this size. Baseline

emissions were assigned based on the appropriate baseline emission factor developed for the

subcategory. 5

Using the same methods to determine the level of control installed for compliance with

the MACT floor emission limits that were used for existing sources, it was determined that all of

the model units would be expected to install add on controls in order to demonstrate

compliance with the new source Hg MACT floor emission limit, and these add

‐ on controls would

have the co

‐ benefit of reducing PM emissions down to the levels of the NSPS PM emission limit.

As a result, no additional controls would be expected to be installed on the new source model

units for the BTF PM analysis. Therefore the limits for new sources in the amended final rule

were based on a BTF level of 0.03 lb/mmBtu from the NSPS rule in any case where the MACT

floor UPL emission limit calculations resulted in a value higher than 0.03.

5.3 Emissions and Cost Impacts for New Sources

Although no additional controls were expected to be installed to meet the BTF emission

limits for PM, incremental emission reductions were still possible where the NSPS emission limit

was more stringent than the MACT floor emission limit. It was assumed that the controls

installed to meet the Hg MACT floor emission limit would achieve the NSPS emission limit. To

calculate incremental emission reductions, the emissions associated with the PM MACT floor

emission limit were subtracted from the emissions associated with the BTF NSPS emission limit.

A percent reduction associated with the incremental PM emission reductions was calculated and

used as the basis of estimating incremental reductions in metallic HAP emissions. A summary of

the incremental emission reductions in PM and metallic HAP by subcategory for new sources is

provided in Table 8 below.14 Table 8 – New Source Incremental PM and TSM10 Emission Reductions for BTF Option

Fuel Category Combustor

Design Incremental Emission Reductions

(tpy)

PM TSM10

Biomass Suspension

Burner 43 1

Wet Biomass Stoker/Other 1 0

Dry Biomass Stoker/Other 43 1

Since no additional controls could be installed on the new source model units for the BTF

analysis, there are no incremental cost impacts to achieve these BTF limits for PM at new

sources. The costs associated with installing PM controls on units with a heat input of 30

mmBtu/hr or greater are expected to be incurred by the NSPS. The costs associated with

installing Hg controls on units with a heat input above 10 mmBtu/hr to 30 mmBtu/hr are part of

the cost of compliance with the Hg MACT floor analysis. Because there are no incremental costs,

the cost

‐ effectiveness for each subcategory is also zero. Thus, the BTF option is a viable

alternative to the biomass subcategories where the MACT floor emission limit is less stringent

than the NSPS limit, as those subcategories are assumed to be able to achieve greater

reductions in emissions without incurring additional costs. Detailed calculations of the

incremental emission reductions and costs for the BTF analysis for new sources are provided in

Appendix B

‐ 1. A summary of the incremental cost and emission impacts and the cost

‐

effectiveness of the BTF analysis for new sources is provided in Appendix A

‐ 2.15 5.0 REFERENCES

1. Eastern Research Group, Inc. Revised MACT Floor Analysis (August 2012) for the

Industrial, Commercial, and Institutional Boilers and Process Heaters National Emission

Standards for Hazardous Air Pollutants

– Major Source. August 2012.

2. Eastern Research Group, Inc. Revised (August 2012) Methodology for Estimating Cost

and Emissions Impacts for Industrial, Commercial, Institutional Boilers and Process

Heaters National Emission Standards for Hazardous Air Pollutants

– Major Source.

August 2012.

3. Comments submitted by Michael L. Steele, CraftMaster Manufacturing Inc. Submitted

on August 3, 2010. Docketed at: EPA

‐ HQ

‐ OAR

‐ 2002

‐ 0058

‐ 1907.1

4. Comments submitted by Stephen R. Gossett, Eastman Chemical Company. Submitted on

August 23, 2010. Docketed at: EPA

‐ HQ

‐ OAR

‐ 2002

‐ 0058

‐ 3137.1

5. Eastern Research Group, Inc. Revised August 2012 Development of Baseline Emission

Factors for Boilers and Process Heaters at Commercial, Industrial, and Institutional

Facilities. August 2012.16 Appendix A

Summary of Beyond the Floor Analysis for Existing Sources17 Appendix B

Summary of Beyond the Floor Analysis for New Sources