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MEMORANDUM

TO:    Brian Shrager and Jim Eddinger, U.S. EPA/SPPD

FROM:   Eastern Research Group, Inc.

DATE:    August 2012

SUBJECT: Handling and Process of Corrections and New Data in the EPA ICR Databases –

Revised August 2012

1.0 INTRODUCTION

This memorandum discusses the methods used to receive and process data corrections

and new data into the ICR databases.  Only data corrections or new data received after the

November 7, 2011 cutoff for consideration in the proposed December 23, 2011 Major Source

Boiler and Process Heater NESHAP (76 FR 80598) are discussed in this memorandum.  A

discussion of the methods used to receive and process data corrections and new data prior to

the promulgated rule is provided in the memorandum, “Handling and Process of Corrections

and New Data in the EPA ICR Databases – Revised November 2011” in the docket.1 No data

corrections or additions received after August 8, 2012 were processed into the EPA ICR

databases in order to finalize regulatory impacts analyses for the amended final rule.

This memorandum is separated into the following sections:

1.0 Introduction

2.0 Summary of Data Corrections and Additions

3.0 Outstanding Data Corrections

4.0 References

Appendix A:  Summary of Data Corrections and Additions from Public Comments

Appendix B:  Units Reclassified as Major Source Boilers from CISWI and MATS
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2.0 SUMMARY OF DATA CORRECTIONS AND ADDITIONS

This section discusses the changes to existing data or the addition of new data to the

EPA ICR databases since the December 23, 2011 proposed reconsideration of the rule (76 FR

80598).  The system of change codes used to flag and denote changes to or additions of data

into the EPA ICR databases is described in the memorandum, “Handling and Process of

Corrections and New Data in the EPA ICR Databases” in the docket.2 Only data corrections or

new data received after the November 7, 2011 cutoff for consideration in the proposed

reconsideration of the rule are discussed in this section.

2.1 Review of Top Performer Test Reports

EPA conducted a review of the test reports for the top performing emitters from the

development of MACT floor emission limits for the promulgated rule.  A discussion of the

methods used to develop MACT floor emission limits is provided in another memorandum.3

Test reports were reviewed for the top performing emitters of mercury (Hg), filterable

particulate matter (PM), hydrogen chloride (HCl), carbon monoxide (CO), and metallic HAP

(including As, Be, Cd, Cr, Pb, Mn, Ni, and Se).  As a result of the test report review, several

facilities were found to have incorrectly calculated and reported emission values.  It was also

found that several tests did not follow the required test method protocol, and should thus be

disregarded from future analyses.  A detailed analysis of the test report review and a summary

of the required corrections to the reported emissions data are provided in another

memorandum.4

2.2 Public Comments

EPA received public comments on the proposed reconsideration of the rule (76 FR

80598).  A total of 43 comment excerpts contained new data or corrections to existing data in

the EPA ICR databases.  Several of the comment excerpts contained identical data corrections

or additions.  A summary of the data additions and corrections received in the public comments

can be found in Appendix A.

2.3 Reclassified Sources
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EPA conducted a review of combustion units previously subject to the proposed

December 23, 2011 Emission Guidelines for Commercial and Industrial Solid Waste Incineration

Units (CISWI) (76 FR 80452) in order to determine if any units should be re‐classified as

industrial or commercial boilers or process heaters.  This review showed that three units from a

Wheelabrator Shasta facility located in Anderson, CA (Facility ID:  CAWheelabratorShasta)

should now be classified as major source boilers since the facility ceased waste combustion in

2009.  Each of the three boilers is rated at 339 million British thermal units per hour

(MMBtu/hr) and combusts primarily hog fuel and agricultural residue.  These units were

classified as Stoker/SlopedGrate/Other boilers combusting Wet Biomass.

EPA also conducted a review of combustion units previously subject to the promulgated

February 16, 2012 Mercury and Air Toxics Standards for Power Plants (MATS) (76 FR 9304) in

order to determine if any unit should be re‐classified as industrial or commercial boilers or

process heaters.  This review showed that two facilities in Virginia contained utility boilers that

were not large enough to meet the applicability criteria of MATS.  These facilities are the James

River Cogenerating Company in Hopewell, VA (Facility ID:  VACogentrixHopewell) and the

Cogentrix Virginia Leasing Company in Portsmouth, VA (Facility ID:  VACogentrixPortsmouth).  

The two facilities operate a combined total of 12 boilers, each rated at 200 MMBtu/hr and

combusting primarily bituminous coal.  These units were classified as

Stoker/SlopedGrate/Other boilers combusting Coal/Fossil Solid.

A summary of the boilers that were reclassified from other rulemaking efforts is

provided in Appendix B.

2.4 Other Data Corrections and Additions

Data corrections and additions were received after the November 7, 2011 cutoff for

consideration in the promulgation of the December 23, 2011 Major Source Boiler and Process

Heater NESHAP (76 FR 80598).  A summary of these previously‐outstanding data corrections are

provided in another memorandum.1 These data corrections and additions have since been

processed in the EPA ICR databases.

3.0 OUTSTANDING DATA CORRECTIONS
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August 8, 2012 was used as the cutoff for data submittals to be processed into the EPA

ICR databases.  However, no additional data were received after this date, and thus there are

no outstanding data corrections to report.  The additional data and reported corrections to

existing data received since the proposed reconsideration of the rule can be found in the

docket under the title, “DVD containing raw facility data received after November 7, 2011”.  A

late error was discovered in the reported beryllium (Be) emissions for a metal process furnace.  

The reported emissions were four orders of magnitude lower than the emissions specified in

the test report for the unit (Facility ID:  ILUSSGraniteCity; Unit ID:  No. 8 Galvanizing Line

Furnace).  Table 1 provides compares the Be emissions reported in the EPA ICR Database to the

Be emissions specified in the test report.  Because this error was identified late in the

rulemaking process, the changes were not made in the EPA ICR Databases.

Table 1 – Comparison of Reported and Actual Beryllium Emissions for ILUSSGraniteCity 

Run Number

Beryllium Emissions Reported in

EPA ICR Databases

(lb/MMBtu)

Beryllium Emissions Reported in

Test Report

(lb/MMBtu)

1 5.58E‐04 5.58E‐08

2 1.69E‐03 1.69E‐07

3 1.05E‐03 1.05E‐03
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4.0 REFERENCES

1. Eastern Research Group, Inc.  Handling and Processing of Corrections and New Data in

the EPA ICR Databases – Revised November 2011.  November 2011.

2. Gibson, G., ERG.  Handling and Processing of Corrections and New Data in the EPA ICR

Databases.  January 2011.

3. 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.

4. Eastern Research Group, Inc.  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.  August 2012.