# Draft Technical Support Document for HWC MACT Standards

U.S. Environmental Protection Agency Office of Solid Waste and Emergency Response (5305) 401 M Street, SW Washington, D.C. 20460

February 1996 

# Volume VII

Miscellaneous Technical Issues

# ACKNOWLEDGMENTS

This document was prepared by the U.S. EPA's Office of Solid Waste, Waste Management Division. Energy and Environmental Research Corporation (EER) provided technical support under EPA Contract No. 68-D2-0164.

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# ABSTRACT

This seventh volume of the Technical Support Document for HWC MACT Standardsaddresses miscellaneous technical issues and provides additional information on several topics of importance to tasks described in the other six volumes of this document. These topics include the treatment of measurements below analytical detection limits, the procedures for handling missing data, the impact of metals and chlorine spiking on trial burn results, and the rationale for grouping metals of similar volatility. The impact of these methodologies on the proposed MACT limits, the national emissions and cost estimates, and estimates of the 50th and 90th emission percentiles of HAPs are also discussed.

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# TABLE OF CONTENTS

ACKNOWLEDGMENTS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . ii ABSTRACT . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . iii LIST OF FIGURES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vi LIST OF TABLES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . vii ACRONYMS GLOSSARY

..................................... viii

1.0 INTRODUCTION . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1-1

2.0 GENERAL ND ISSUES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-1 MACT ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-3 NATIONAL EMISSIONS AND COST ESTIMATES . . . . . . . . . 2-4 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-5 EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”) . . . . . . . . . . 2-6

3.0 SUBSTITUTION METHODOLOGY FOR LVM, SVM, AND TCl . . . . 3-1 MACT ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-2 NATIONAL EMISSIONS AND COST ESTIMATES . . . . . . . . . 3-3 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-3 EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”) . . . . . . . . . . 3-4

4.0 METAL AND CHLORINE SPIKING . . . . . . . . . . . . . . . . . . . . . . . . 4-1 MACT ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 LVM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-2 SVM . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 Mercury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 TCl . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-3 NATIONAL EMISSIONS AND COST ESTIMATES . . . . . . . . . 4-4 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4-4

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# EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”) . . . . . . . . . . 4-4

5.0 SUPPORT FOR SELECTION OF METALS VOLATILITY GROUPS . 5-1 METALS PARTITIONING AND ENRICHMENT . . . . . . . . . . . 5-2 METALS PENETRATION RANKING . . . . . . . . . . . . . . . . . . . 5-4 CONTRIBUTION OF ELEMENTS TO EMISSIONS AND FEED RATES OF LVM, SVM, AND TCl GROUPS . . . . . . . . . . . . . . . . . . 5-5

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# LIST OF FIGURES

Figure 2-1. Contribution of feed streams to stack emissions of mercury for cement kilns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 2-9 Figure 3-1. Contribution of feed streams to stack emissions of LVM for cement kilns. . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 3-5 Figure 5-1. Metals partitioning in cement kilns burning hazardous wastes. . . . 5-7

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# LIST OF TABLES

Table 2-1. Contribution of spiking, full detection limit for ND data, and substitution to MTECs and emissions.

................................ 2-10 Table 2-2. Average and median contributions of full detection limit ND data and substitution to emissions of HAPs.

.......................... 2-22 Table 2-3. Average and median contributions of spiking and full detection limit ND data to MTECs of HAPs.

................................ 2-23 Table 2-4. 50th and 90th emission percentiles assuming ND data at full and 1⁄2 detection limits (using average rank based emission substitution).

.... 2-24 Table 3-1. 50th and 90th emission percentiles assuming average rank based and zero emission substitutions (using ND data @ full detection limit). . . . . . . . . 3-6 Table 5-1. Enrichment (ratio of FF/ESP ash concentration to clinker concentration) of metals in cement kilns (detected data only). . . . . . . . . . . . . . . . . . . . . . 5-8 Table 5-2. Average and median enrichment factors based on all conditions for each metal in cement kilns (detected data only).

.................... 5-11 Table 5-3. Penetration relative ranking of metals for all combustion systems. 5-12 Table 5-4. Average and median contributions of elements to emissions of LVM, SVM, and TCl.

............................................ 5-13 Table 5-5. Average and median contributions of metals to feed rates of LVM and SVM.

.............................................. 5-14

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# ACRONYMS GLOSSARY

APCD Air Pollution Control Device BIF Boiler and Industrial Furnace CAAA Clean Air Act Amendment of 1990 CK Cement Kiln EPA environmental Protection Agency EU Expanded Universe HAP Hazardous Air Pollutant HW Hazardous Waste HWC Hazardous Waste Combustor INC Incinerator LNDS Log-Normal Data Set LVM Low-Volatility Metals LWAK Light Weight Aggregate Kiln MACT Maximum Achievable Control Technology MTEC Maximum theoretical Emission Concentration ND Non-Detected OSW Office of Solid Waste RCRA Resource Conservation Recovery Act SRE System Removal Efficiency SVM Semi-Volatile Metals TCl Total Chlorine U.S. United States

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## SECTION 1

INTRODUCTION

The U.S. Environmental Protection Agency (EPA) regulates the burning of hazardous waste in incinerators under 40CFR Part 264/265, Subpart O, and inindustrial furnaces under 40 CFR Part 266, Subpart H. The Agency is proposing revised regulations applicable to these hazardous waste combustion (HWC) devices. This document provides technical background for the MACT floor and beyond-the-floor emissions standards that are considered for the proposed rule. It is the last in a series of seven volumes of technical background documents for the rule. These include:

Technical Support Document for HWC MACT Standards, Volume I: Description of Source Categories, which provides process descriptions of major design and operating features including different process types and air pollution control devices currently in use and potentially applicable to various combustion source categories; description of air pollution control devices including design principles, performance and operating efficiency, process monitoring options, and upgrade/retrofit options; and major source determination for all sources including a discussion on the methodology used to estimate annual emissions, assumptions used, and an emissions summary for each source listing each HAP.

TechnicalSupport Document for HWC MACT Standards, Volume II: HWC Emissions Data Base, which contains a summary of the emissions information on toxic metals, particulate matter (PM), HCl and Cl2

## , hydrocarbons, carbon monoxide, semi-volatile and volatile organic compounds, and dioxins/furans from HWCs. Other detailed information encompassed in the data summary include company name and location, emitting process information, combustor design and operation information, APCD design and operation information, stack conditions during testing, feed stream feed rates, and emissions rates of HAPs by test condition.
Technical Support Document for HWC MACT Standards, Volume III: Selection of Proposed MACT Standards and Technologies, which identifies the MACT floor for each HAP and source category for existing sources and new sources and discusses the approach used to define the floor and beyond-the-floor alternatives considered for the proposed rule.
Technical Support Document for HWC MACT Standards, Volume IV: Compliance with the Proposed HWC Standards, which contains detailed discussions of continuous emissions monitors and operating limits for the proposed rule.

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## TechnicalSupport Documentfor HWC MACT Standards, Volume V:Engineering Costs, which contains the cost estimates for APCD requirements for existing and new facilities to meet the proposed emissions standards.

TechnicalSupport Document forHWC MACT Standards, Volume VI:Development of ComparableFuels Specifications,which summarizesthe composition includinghazardous species in benchmark fossil fuels such as gasoline, #2 fuel oil, #4 fuel oil, and #6 fuel oil. This information is being used to develop specifications which EPA is considering to allow comparable fuels to be excluded from the definition of hazardous waste.

Technical Support Document for HWC MACT Standards, Volume VII: Miscellaneous Technical Issues,which provides additional information on several topics such as the treatment ofmeasurements below analytical detectionlimits, the procedures for handling missing data, and the rationalefor grouping metals of similar volatility. Theimpact of these methodologies on the proposedMACTlimits, the cost estimates, and the national emissions estimates are also discussed.
The MACT emission standards are being proposed for three types of hazardous waste combustion facilities:

• Cement Kilns • Lightweight Aggregate Kilns • Incinerators (On-site and Commercial)
The hazardous air pollutants for which emission standards are proposed are:

• Mercury (Hg) • Low Volatility Metals (LVM) • Semi-Volatile Metals (SVM) • Particulate Matter (PM) • Hydrogen Chloride and Chlorine as Total Chlorine (HCl/Cl2

## ) • Carbon Monoxide (CO) • Hydrocarbons (HC) • Dioxins/Furans (PCDD/PCDF)
These emission standards are being developed through the “maximumachievable control technology” (MACT) approach defined in Title 3 of the 1990 Clean Air Act Amendments (CAAA). In this approach the MACT floor standard for existing facilities is established at the level of the average performance of the best 12% of existing sources. Depending on cost effectiveness,more stringent, but technically achievable, beyond-the-floor standards for specific HAPs are considered. The proposed floor and beyond-the-floor standards have been selected based on a database (described in VolumeII) of trial burn and compliance test emissions measurements from 77 incinerators, 35 cement kilns, and 12 lightweight aggregate kilns.

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## This report addresses and discusses miscellaneous issues and assumptions of importance to tasks described in the Technical Support Documents. In particular, this report focusses on four major topics of interest: the treatment of non-detected data (General NDIssues), substitution of data for cases where certain hazardous air pollutants (HAPs) were not measured during a trial burn (Substitution Methodology for LVM, SVM, and TCl), metals and chlorine spiking, and the selection of and justification for metals volatility groupings (Support for Selection of Metals Volatility Groups). These four topics are examined in detail in the remainder of this report.

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# SECTION 2

GENERAL ND ISSUES

In a trial burn, emission and feed rate measurements of metals and other hazardous air pollutants (HAPs) are sometimes below detection limits of analytical instruments. For such measurements, facilities are required to report the detection limit of the instrument and identify the value as ND (non-detected). The reported ND measurements may still be used to represent the emissions or feed rates of HAPs through using the full detection limit (i.e., the reported detection limit of the instrument is assumed to be equal to the feed or emission rate of the HAP) or other conventions such as 1⁄2 the detection limit (i.e., the emission or feed rate measurement is considered equal to 1⁄2 the detection limit of the instrument). The choice of ND data treatment, however, may ultimately impact the results of any analysis performed on the data. For example, using the full detection limit for emission measurements may lead to conservative emission predictions (i.e., provide an upper limit of emissions for that measurement), but also may exaggerate emissions if the actual emission value is much less than the detection limit of the instrument. Using 1⁄2 the detection limit value, however, may overestimate or underestimate emissions depending on whether the true emission value is higher or lower than 1⁄2 the detection limit.

For most of the OSW tasks, the reported ND values were generally used at the full detection limit, particularly for analyses involving stack emission measurements. Since emissions of toxic metals and other HAPs are of concern to the public and the environment, it was important to estimate an upper limit for emissions so that when emissions are used to set standards, risk analysis may indicate whether these standards are protective. HAPs are generally introduced to the combustion system through several feed streams, particularly if the system is using pumpable and non-pumpable wastes, and also may be emitted from the system through multiple stacks. The total feed rate of a HAP per run is, therefore, the sum of all metals in all feed streams, and the total emission rate of each HAP is the sum of emissions from the different stacks.

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# As mentioned earlier, some of these measurements in any of the feed or exit streams may be below the detection limit of the instrument used in a trial burn. The portion of the total feed and emission rate of a HAP attributable to a ND measurement per run was calculated assuming all measurements at full detection limits. These values were then averaged per condition for every HAP and combustion source (where a condition is usually composed of three runs). The feed and emission rate ND percentage contributions for HAPs and source categories per condition are shown in Table 2-1. This table also includes other results which are discussed in the various sections throughout this report.

The HAPs in Table 2-1 are represented by the low-volatility metals (LVM) group including Sb, As, Be, and Cr; by the semi-volatility metals (SVM) group encompassing Cd and Pb; by mercury; and by total chlorine (TCl) based on total chlorine measurements in the feed streams and on HCl and Cl2 

# stack emissions measurements. The selection of and justification for metals groupings are discussed in detail in the last section of this report. The particulate matter (PM) is not shown in Table 2-1 because all of the reported PM measurements from all source categories (except for one run from one facility) are above the detection limit of PM measuring instruments. The feed rate in Table 2-1 is represented by the maximum theoretical emission concentration (MTEC) which is basically the feed rate of the HAP normalized by the stack gas flow rate of the facility. The results in Table 2-1 show the substance, combustion source, Condition ID, average MTECs, contribution of ND measurements to total MTEC (Avg % ND MTEC), percentage attributable to spiking, percentage attributable to waste feed, classification of each condition based on the MACT analysis (MACT Status), average emission concentrations, and corresponding percentages attributable to ND measurements at the stack and emissions substitution, respectively. The contribution of ND measurements to both feed and emissions and the impact of ND data treatment on various tasks in this program are discussed in this section, while the contributions of emissions substitution and spiking are discussed in following sections of this report. The data in Table 2-1 are sorted from low to high based on stack emissions. For some conditions, only stack measurements of some HAPs were performed and, therefore, MTECs corresponding to these conditions are designated as NA (not available) in Table 2-1. A summary of the average and median contributions of ND measurements and emissions substitution to stack emissions from all conditions, HAPs, and source categories is presented in Table 2-2, and a summary of the average

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# and median contributions of ND measurements and spiking to feed rate MTECs is presented in Table 2-3. Additionally, Table 2-3 shows a breakdown of ND percentages in the various feed streams.

The impact of ND data contribution on the various analyses performed in this program, based on results from Tables 2-1 through 2-3, will be discussed shortly. However, there are some general comments that can be deduced from Tables 2-1 through 2-3. The contribution of high percentage ND conditions to emissions is not generally limited to low emitting facilities, particularly for metals in cement kilns (CKs), where 100% ND contribution for LVM, for example, extends all the way to the top seven highest emitting conditions. For CKs, Table 2-2 shows that the median ND contribution to emissions appears to be significant for LVM and Hg, but not significant for SVM and TCl; while the median ND contribution for all HAPs for incinerators (INCs) and light weight aggregate kilns (LWAKs) may not be significant. Table 2-3 shows that the contribution of median ND data to total MTECs is significant only for Hg from CKs and marginally significant for Hg from INCs. The convention used for treating ND data and whether ND values were used in the analyses are discussed below for each major OSW task.

2.1 MACT ANALYSIS

Details of the MACT procedure and analysis for all HAPs and source categories are presented and discussed in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. In brief, the MACT analysis was performed by selecting MACT pool facilities based on the lowest 6% emitting facilities or the lowest three emitting facilities (if the lowest 6% emitting facilities were fewer than three) for each HAP and source category. The control technologies as well as the hazardous waste (HW) MTECs for these lowest emitting conditions were then identified. The MACT expanded universe (EU) was determined by selecting all conditions with similar technologies to the MACT pool technologies with HW MTECs equal to or less than the MACT-defining HW MTEC (the highest MACT pool HW MTEC for a given control technology). The MACT floor level was then determined based on the worst emitting condition in the MACT EU. The percentages of ND emissions and feed rate MTECs were not considered in selecting the lowest 6% MACT pool facilities nor the MACT-defining HW MTECs. However, conditions with “high” percentage of ND emissions contribution were screened out

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# from the MACT EU, particularly, if the high percentage ND conditions correspond to relatively high detection levels (e.g., the seven highest emitting conditions for LVM from CKs in Table 2-1). In these cases, the emissions level may be significantly less than reported. What constitutes “high” for this analysis is determined in comparison with other measurements and the detection limit that should be routinely achievable.

Based on the above discussion, the choice of ND data treatment may potentially impact the selection of the MACT pool facilities as well as the MACT EU. For example, if 1⁄2 the detection limit were considered instead of the current full detection limit, it would be possible for the ranking of a facility, with low emission and high ND percentage (e.g., 315C1 for LVM from CKs, Table 2-1, has 98% ND contribution), to change and become part of the lowest emitting 6% pool, particularly, if the lowest 6% emitting facilities had detected emissions or low ND percentages. This may also act to change the definition of MACT control (i.e., air pollution control equipment and MTEC level). Similarly, if the ND MTEC data were treated at 1⁄2 the detection limit, the MACT-defining HW MTECs may change (become lower), potentially altering the MACT EU facilities. Thus, since the MACT floor level is determined by the worst emitting condition in the MACT EU, the convention for using ND data may potentially impact floor standards.

Although the contribution of ND data (at full detection limit) to emission measurements was considered when expanding the MACT universe conditions, determination of the MACT-defining HW MTEC did not consider the contribution of ND percentages to feed rate MTECs. Treating the ND feed data at 1⁄2 detection limit instead of full detection limit, however, may have an impact on the MACT-defining HW MTEC and further on the number of conditions selected while expanding the MACT universe. The 1⁄2 detection limit choice may result in selecting more or less MACT conditions than have currently been selected based on full detection limits. For example, if the MACT-defining HW MTEC has a high percentage of ND data, then using 1⁄2 the detection limit would lower the MACT-defining HW MTEC and thus increase the number of conditions screened out of the expanded universe due to high MTECs. On the other hand, the use of the 1⁄2 detection limit convention may bring additional facilities into the MACT EU which have ND-influenced MTECs that are slightly higher than the MACT-defining HW MTEC. Since the MTEC of each condition is an integral part of the MACT evaluation process, only conditions with reported emissions and feed rate MTEC measurements were considered in the MACT

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# analysis. Cases where stack gas emissions were available, but feed rate MTECs were not (designated as NA in Table 2-1), were excluded from the MACT analysis.

2.2 NATIONAL EMISSIONS AND COST ESTIMATES

The methodology and procedure for estimating national emissions of HAPs from combustion sources and national cost for meeting the proposed floor and beyond the floor limits are explained in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. These analyses were performed using stack emissions data only. Therefore, the choice of ND data treatment and its impact on emissions and cost estimates are important for these tasks, while the ND MTEC percentages have no direct impact on national emission/cost estimates. Note that ND MTEC treatment may have an indirect impact on costs because, as explained above, they may impact the definition of MACT and the resulting MACT floor emissions limits. For these analyses, the full detection limit was used for ND emission measurements. Hence, the impact of the percentage of ND attributable to each emission condition is to overestimate the true emission of the HAP, particularly, if the actual emission is much less than the detection limit (as is probable at facilities with “high” detection levels). Consequently, this will also lead to an overestimate of the cost required for emissions reduction to meet MACT standards for a particular HAP and facility. The national emissions and cost estimates are based on emissions data from all facilities in the United States and, therefore, the impact of using full detection limits for all facilities should be considered.

As indicated above, national emissions were estimated based on reported emissions data for each HAP from all facilities within a source category. Emission factors were then calculated based on measured data and used to predict emissions for facilities with no reported data. The percentages of ND emissions in Table 2-1 for measured data can therefore be used to give an indication of whether the ND data contribution to emissions and cost estimates is significant. In fact, the average ND emission percentages for each HAP and source summarized in Table 2-2 are good indicators of the potential impact of using full detection limit on national emission/cost estimates. Results in Table 2-2 indicate that using a full detection limit may significantly overestimate emissions of LVM and Hg from all source categories and SVM from CKs and INCs. However, the impact of using full detection limits on overestimating TCl emissions and costs does not appear to be significant for CKs and

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# LWAKs but may be marginally significant for INCs. For example, since national emissions are roughly proportional to average emissions, and since nearly 40% of the average mercury emissions from CKs is attributable to non-detected measurements (treated at full detection limit), treatment of non-detected data at 1⁄2 detection limit would lower the national estimate for emission of mercury from CKs by nearly 20%. Since national emission estimates for HAPs and source categories were used to calculate emission reduction requirements and subsequently to estimate national costs for meeting the proposed standards, similar qualitative conclusions to the above can be drawn regarding the impact of using full detection limit on national cost estimates.

2.3 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS

In addition to national emission estimates, characteristic risk estimates are required in order to estimate risks from typical facilities. Estimates for various HAPs of the 50th and 90th percentile emission concentrations were performed for the different hazardous waste combustors (HWC) source categories. These characteristic emission estimates served as inputs to EPA risk assessment model plants to allow estimation of local and global risks posed by current emissions; and the consequent risk reduction provided by floor and beyond-the-floor standards. 50th and 90th emission percentile results for metals and other HAPs are provided in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. The percentiles were generated assuming the emissions data have a log-normal distribution.

For this analysis, emission data below detection limits were assumed at full detection limit. Since emission data for each HAP and source category had to be ranked from low to high before the 50th and 90th percentiles can be determined, the distribution of ND percentages, shown in Table 2-1, may provide a qualitative assessment of whether the choice of ND treatment impacted the 50th and 90th percentile results for this analysis. Ideally, if the high ND conditions correspond to lowest emissions, the 50th and 90th percentile ranked emissions may not be impacted by assuming full or 1⁄2 detection limit for ND data. However, as shown in Table 2-1, the high ND percentages span the whole range of emissions for many HAPs and source categories. For example, choosing 1⁄2 detection limit instead of full detection limit for ND data may impact the ranking of emissions for LVM from CKs, INCs, and LWAKs because significant ND percentages are distributed across the whole range of emissions. Therefore, the 50th and 90th emission percentiles may be different than the ones based on full detection limit.

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# To thoroughly explore the impact of using 1⁄2 the detection limit instead of the current full detection limit on 50th and 90th emission percentiles, a comprehensive quantitative assessment was performed using run data to determine 50th and 90th percentiles for all HAPs and source categories based on 1⁄2 detection limits for ND data.As for full detection limit, the 1⁄2 detection limit analysis was performed assuming lognormal distribution for emissions data. The results from this analysis are summarized in Table 2-4. This table shows the substance, combustion source, 50th and 90th percentiles for ND emissions at full detection limit, and 50th and 90th percentiles for ND emissions at 1⁄2 detection limit. Results in Table 2-4 indicate:

The most significant impact of using 1⁄2 the detection limit is on LVM and SVM from CKs where 50th and 90th percentiles dropped between 20% to 30%. The most significant change for Hg due to using 1⁄2 the detection limit occurred for the 90th percentiles for CKs and LWAKs. TCl does not show significant change when 1⁄2 the detection limit was used for both 50th and 90th percentiles for all source categories. Changing to 1⁄2 detection limits for ND data reduced the magnitude of all 50th emission percentiles for all HAPs and source categories, reduced the magnitude of most 90th emission percentiles, and increased the magnitude of 90th percentiles for few HAPs and source categories (e.g., Hg from LWAKs and TCl from CKs and INCs).

The increase in the magnitude of the 90th percentile when using 1⁄2 the detection limit instead of full detection limit, as shown in Table 2-4 for some cases, may be surprising. This situation may occur, however, because the 90th percentile is calculated based on the arithmetic mean and the standard deviation of each log-normal data set (LNDS). And, although the arithmetic mean of the 1⁄2 detection limit LNDS may be lower (but not higher) than the arithmetic mean of the full detection limit LNDS, the standard deviation may be higher for the 1⁄2 detection limit LNDS than the full detection limit LNDS. Therefore, if the standard deviation for the 1⁄2 detection limit LNDS is higher than the full detection limit LNDS enough to offset the potential decrease in arithmetic mean in the log-normal plane, the magnitude of the 90th percentile for the 1⁄2 detection limit LNDS may then increase relative to the full detection limit LNDS. Note that the 50th percentiles in Table 2-4 are always lower than the 1⁄2 detection limit LNDS since they are dependent only on the arithmetic mean in the log-normal plane.

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# 2.4 EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”)

The methodology, procedure, and results for the “bar charts” are presented in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. For this analysis, the MACT emission bar charts for LVM, SVM, Hg, and TCl for all combustion sources were reproduced showing the contribution of waste, fuel, and raw material feed to emissions of HAPs. Figure 2-1 shows an example of these “bar charts” for mercury from CKs. It was assumed in this analysis that emission rates are proportional to feed rates and that the contribution of the various feed streams to the total feed rate of each HAP is the same as their contribution to emission rates. The purpose of these “bar charts” was to:

determine if any of the feed streams may dominate emissions; study the impact of HAPs in the raw material on emissions for CKs and LWAKs; and identify non-MACT conditions, and study the potential impact of waste feed reduction on HAPs emissions and on meeting the proposed floor standards.

Emission and feed rate MTEC data were used during this analysis. Full detection limits were assumed for both emissions and feed rate MTECs with measurements below detection limits. As Figure 2-1 illustrates, the X-axis of the bar charts shows the Condition ID, whether the raw material MTEC has significant ND percentage, baseline conditions, whether the condition is a MACT pool facility or a MACT EU facility, and projected emissions for non-MACT facilities if retrofitted with MACT technology. The raw material ND classification on the X-axis of Figure 2-1 is important since it helps to identify conditions where emissions due to high ND level in the raw material contribute to higher than the floor emissions even if the waste feed were eliminated.

The impact of ND data on emissions and on the MACT analysis was discussed earlier. The impact of feed rate MTEC ND data may be important for this task since the emissions distribution is based on the distribution of feed rate data. Table 2-3 summarizes the median and average percentages of total MTECs attributable to assuming full detection level for ND measurements. This table also shows the

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# breakdown of ND percentages between the different feed streams. In general, average ND percentage results in Table 2-3 indicate that assuming full detection limit for ND total feed rate MTECs may be marginally significant for LVM from CKs and INCs and for SVM from INCs, and significant for Hg from all source categories. The impact of ND feed rate MTEC data on TCl results may not be significant for this analysis due to only few high condition ND percentages for TCl (as shown in Table 2-1). In the following discussion, the contribution of ND data is classified to be significant if the ND percentages are roughly greater than 25%, marginally significant if the ND percentages range between roughly 8% and 18%, and insignificant if the ND percentages are roughly 5% or less. Moreover, a significant impact means that using a different choice than full detection limit for ND data, such as 1⁄2 the detection limit, is likely to change the emissions distribution results. Table 2-3 results of ND feed breakdown indicate that, on the average:

For Hg, the contribution of ND data is significant for CKs and marginally significant for INCs in the fuel, significant for CKs and LWAKs in the raw material, insignificant for all source categories in the spike, and significant for INCs and marginally significant for CKs and LWAKs in the waste. For LVM, the contribution of ND data may be marginally significant for CKs and INCs in the fuel, significant for CKs in the raw material, and insignificant for all source categories in the spike and waste (except for INCs in the waste where it may be marginally significant). For SVM, the contribution of ND data may be marginally significant for CKs in the fuel, for CKs and LWAKs in the raw material, and for INCs in the waste, and insignificant for all source categories in the spike. For TCl, the contribution of ND data may be marginally significant for CKs in the fuel, significant for CKs and LWAKs in the raw material, and insignificant for all source categories in the spike and waste.

1-9MEC : Uses MACT, NMEC : Does not use MACTTP : Adjusted based on control technology, MP : Adjusted based on MTEC levelBL : Baseline, ND : Contribution of raw material to feed was below detection level 

### ND, MEC, 404C1
ND, MEC, 203C1
ND, MEC, 207C1
ND, MEC, 206C1
ND, MEC, 204C1
ND, MEC, 208C1
ND, MEC, 202C2
ND, MEC, 205C1
ND, MEC, 304C1
ND, MEC, 319C1

ND, NMEC-MP, 335C1
ND, NMEC-MP, 406C1
BL, NMEC, 303C1
ND, NMEC-MP, 405C1
NMEC-MP, 305C1
ND, NMEC-MP, 401C1
ND, NMEC-MP, 402C1
ND, NMEC-MP, 401C5
NMEC-MP, 309C1
NMEC-MP, 402C4
ND, NMEC-MP, 301C2
NMEC-MP, 303C3
NMEC-MP, 306C1050100150200250300350400450 

### Mercury Emissions (μg/dscm @ 7% O2

### )Raw MaterialFuelWasteSubst FuelFigure 2-1. Contribution of feed streams to stack emissions of mercury for cement kilns.

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution LVM CK 320C1 68,164.6 51 0 37 MEC-P 4.3 0 33 LVM CK 316C2 74,379.8 1 54 5 MEC-P 4.8 18 13 LVM CK 204C1 169,503.2 7 81 5 MEC-P 6.2 65 0 LVM CK 308C1 70,976.5 0 39 3 MEC-EU 7.1 0 12 LVM CK 206C1 231,100.7 0 87 2 NMEC 8.7 17 0 LVM CK 315C1 286,229.8 0 83 8 NMEC 8.9 98 10 LVM CK 309C1 134,708.2 0 79 0 MEC-EU 9.3 37 0 LVM CK 208C1 28,602.9 34 53 1 MEC-EU 9.9 14 0 LVM CK 303C3 39,889.7 0 6 57 MEC-EU 10.5 0 27 LVM CK 315C2 278,207.2 0 81 8 NMEC 10.8 68 7 LVM CK 335C1 51,649.9 11 75 1 MEC-EU 10.8 100 0 LVM CK 316C1 98,236.4 0 62 4 MEC-EU 11.0 8 19 LVM CK 321C1 373,888.3 44 0 22 MEC-EU 11.5 0 28 LVM CK 306C1 263,985.4 1 85 0 NMEC 13.3 0 0 LVM CK 208C2 24,527.6 45 29 0 MEC-EU 13.7 9 0 LVM CK 30142 54,284.4 8 43 0 MEC-EU 16.4 100 0 LVM CK 30152 54,284.4 8 43 0 MEC-EU 17.2 100 0 LVM CK 205C1 192,453.2 0 86 3 NMEC 18.5 3 0 LVM CK 318C2 17,782.4 0 88 0 MEC-EU 18.6 97 70 LVM CK 305C3 70,027.6 8 62 1 MEC-EU 20.3 82 0 LVM CK 317C1 79,376.7 0 49 0 MEC-EU 23.1 96 13 LVM CK 317C3 41,223.4 1 00 MEC-EU 23.2 100 13 LVM CK 317C2 93,974.4 1 38 0 MEC-EU 23.5 100 13 LVM CK 322C1 188,320.5 3 91 2 NMEC 24.1 0 26 LVM CK 303C1 5,610.7 2 00 MEC-EU 25.4 0 0 LVM CK 401C5 21,020.6 4 5 66 NMEC 26.9 37 0 LVM CK 302C1 381,461.1 21 47 22 NMEC 27.5 0 29 LVM CK 202C2 132,969.0 0 83 8 MEC-EU 29.3 20 0 LVM CK 203C1 53,654.9 3 85 3 NMEC 31.4 40 0 LVM CK 403C1 73,641.5 6 62 27 NMEC 33.6 100 0 LVM CK 305C1 94,988.5 0 91 0 NMEC 38.5 100 0 LVM CK 402C4 25,405.9 0 17 47 NMEC 49.6 0 0 LVM CK 207C2 29,625.4 30 43 8 MEC-EU 55.4 16 0 LVM CK 304C1 214,193.5 1 76 5 NMEC 56.7 0 0 LVM CK 207C1 31,117.9 32 51 2 MEC-EU 57.5 6 0 LVM CK 319C1 25,650.2 3 0 63 MEC-EU 60.2 0 0 LVM CK 300C2 495,321.9 0 99 0 NMEC 102.4 0 0 LVM CK 323C1 172,702.9 12 74 10 NMEC 123.3 0 46 LVM CK 404C1 175,825.8 2 67 28 NMEC 130.4 100 0 LVM CK 402C1 224,229.0 7 84 5 NMEC 162.0 100 0 LVM CK 401C1 44,164.4 11 35 23 NMEC 172.8 100 0 LVM CK 406C1 142,060.6 14 69 16 NMEC 184.3 100 0 LVM CK 405C1 197,865.6 3 71 18 NMEC 304.3 100 0 LVM CK 200C1 370,131.3 3 94 1 NMEC 367.0 100 0 LVM CK 201C1 311,735.0 4 93 2 NMEC 520.2 100 0 LVM INC 500C1 1,029.5 74 0 100 MEC-P 3.5 31 0 LVM INC 348C1 6,237.9 4 89 8 MEC-P 3.6 17 16 LVM INC 342C1 NA NA NA NA NC 3.8 0 16 LVM INC 344C1 NA NA NA NA NC 4.1 0 28 LVM INC 351C1 NA NA NA NA NC 6.3 0 26 LVM INC 806C2 NA NA NA NA NC 7.0 5 0 LVM INC 325C3 NA NA NA NA NC 7.1 68 0 LVM INC 347C1 NA NA NA NA NC 7.2 24 0 LVM INC 351C2 NA NA NA NA NC 7.5 0 27



### 2-10

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution LVM INC 341C2 1,214.1 78 0 100 MEC-P 7.7 100 0 LVM INC 347C2 NA NA NA NA NC 7.8 21 0 LVM INC 806C1 NA NA NA NA NC 8.7 5 0 LVM INC 902C1 1,438.7 0 0 100 NMEC 9.5 17 0 LVM INC 354C1 26,731.4 1 2 98 NMEC 10.1 100 2 LVM INC 712C2 2.7 29 0 100 NMEC 10.5 4 9 LVM INC 341C1 775.1 100 0 100 MEC-EU 11.0 100 0 LVM INC 340C2 27,852.8 16 0 100 NMEC 11.2 97 0 LVM INC 325C8 NA NA NA NA NC 12.1 81 0 LVM INC 325C4 5,672.4 0 0 100 MEC-EU 12.8 5 0 LVM INC 209C2 248,537.0 0 100 0 NMEC 13.8 0 0 LVM INC 346C1 NA NA NA NA NC 14.9 17 60 LVM INC 347C4 NA NA NA NA NC 16.6 12 0 LVM INC 351C3 NA NA NA NA NC 17.2 0 35 LVM INC 221C2 1,042.2 31 5 95 MEC-EU 18.2 19 18 LVM INC 327C3 7,558.6 6 0 100 NMEC 20.3 65 0 LVM INC 327C2 4,589.5 11 0 100 MEC-EU 22.7 61 0 LVM INC 221C3 12,503.5 2 0 100 NMEC 28.2 11 15 LVM INC 705C1 0.6 71 0 100 NMEC 28.3 20 0 LVM INC 353C1 NA NA NA NA NC 28.7 99 0 LVM INC 347C3 NA NA NA NA NC 31.2 9 0 LVM INC 209C1 215,384.9 0 100 0 NMEC 31.5 0 0 LVM INC 325C6 7,344.1 0 0 100 NMEC 34.1 1 0 LVM INC 214C3 88,167.5 0 0 100 NMEC 34.3 0 5 LVM INC 327C1 66,577.5 3 0 100 NMEC 38.2 27 0 LVM INC 330C2 50.0 33 0 27 NMEC 40.1 42 0 LVM INC 229C1 699.5 7 0 100 MEC-EU 40.8 1 11 LVM INC 216C6 NA NA NA NA NC 46.7 10 0 LVM INC 325C5 3,203.9 0 0 100 MEC-EU 48.2 1 0 LVM INC 331C1 NA NA NA NA NC 50.0 1 25 LVM INC 725C1 NA NA NA NA NC 50.7 1 0 LVM INC 216C5 NA NA NA NA NC 50.9 19 0 LVM INC 221C1 118.1 77 0 100 MEC-EU 53.1 7 12 LVM INC 807C3 271,670.8 7 88 12 NMEC 55.2 88 18 LVM INC 712C1 1.4 24 0 100 NMEC 56.5 2 10 LVM INC 214C2 57,412.3 0 0 100 NMEC 59.0 0 3 LVM INC 229C2 1,406.7 5 0 100 MEC-EU 59.9 1 9 LVM INC 330C1 12.5 51 0 0 NMEC 62.9 54 0 LVM INC 229C6 803.8 0 0 100 MEC-EU 66.0 1 10 LVM INC 502C1 57.7 100 0 100 NMEC 66.1 100 22 LVM INC 229C3 251.1 1 0 100 MEC-EU 67.9 1 8 LVM INC 338C2 NA NA NA NA NC 71.9 84 0 LVM INC 229C5 587.6 0 0 100 MEC-EU 77.5 1 8 LVM INC 338C1 NA NA NA NA NC 97.1 63 0 LVM INC 324C1 5,424.9 0 0 100 NMEC 97.7 0 16 LVM INC 325C7 3,868.0 0 0 100 MEC-EU 100.7 0 0 LVM INC 400C1 622,483.6 0 85 2 NMEC 102.1 69 0 LVM INC 324C2 3,308.8 0 0 100 NMEC 111.8 0 15 LVM INC 324C3 3,238.2 0 0 100 NMEC 114.6 0 12 LVM INC 216C7 NA NA NA NA NC 120.8 67 0 LVM INC 824C1 8,552.2 0 0 100 NMEC 123.0 0 28 LVM INC 221C5 9,805.4 3 0 100 NMEC 135.0 0 7 LVM INC 221C4 500.8 61 4 96 MEC-EU 144.9 3 7 LVM INC 340C1 35,258.9 14 0 100 NMEC 147.4 54 0



### 2-11

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution LVM INC 504C1 73,630.6 37 34 26 NMEC 156.8 5 0 LVM INC 344C2 NA NA NA NA NC 177.0 67 88 LVM INC 807C1 239,157.3 8 82 18 NMEC 177.3 47 50 LVM INC 905C1 6,831.7 1 89 11 NMEC 178.9 0 45 LVM INC 324C4 3,844.5 0 0 100 NMEC 194.3 0 12 LVM INC 807C2 367,261.6 5 84 16 NMEC 199.3 46 53 LVM INC 503C2 538,274.5 0 0 100 NMEC 245.9 0 0 LVM INC 337C1 4,247.5 4 0 100 NMEC 261.3 99 0 LVM INC 216C3 NA NA NA NA NC 268.5 0 0 LVM INC 705C2 797.3 29 10 90 NMEC 301.0 0 0 LVM INC 810C1 55,023.1 0 0 100 NMEC 321.6 0 1 LVM INC 214C1 NA NA NA NA NC 338.5 6 0 LVM INC 353C2 NA NA NA NA NC 353.2 17 0 LVM INC 809C1 56,047.4 0 0 100 NMEC 397.1 0 0 LVM INC 334C2 6,827.4 49 0 100 NMEC 451.3 4 0 LVM INC 915C4 NA NA NA NA NC 622.6 0 11 LVM INC 503C1 194,078.5 0 0 100 NMEC 634.4 0 0 LVM INC 915C1 NA NA NA NA NC 684.1 0 54 LVM INC 700C1 6,850.8 3 97 2 NMEC 720.6 0 0 LVM INC 334C1 21,901.0 15 23 77 NMEC 819.8 0 0 LVM INC 810C2 2,250,206.7 0 0 100 NMEC 837.0 0 1 LVM INC 359C4 NA NA NA NA NC 1,064.4 87 0 LVM INC 809C2 1,332,198.8 0 0 100 NMEC 7,224.1 0 1 LVM INC 359C5 NA NA NA NA NC 10,971.2 100 0 LVM INC 359C6 NA NA NA NA NC 132,677.9 0 0 LVM LWAK 225C1 38,989.8 0 0 53 MEC-P 10.3 6 0 LVM LWAK 224C1 69,452.8 0 8 45 MEC-P 21.7 0 0 LVM LWAK 227C1 225,748.9 0 03 MEC-P 25.0 2 0 LVM LWAK 223C1 90,620.0 0 8 28 MEC-P 34.1 1 0 LVM LWAK 312C1 129,394.2 0 33 3 MEC-P 37.2 44 0 LVM LWAK 311C1 126,402.5 0 28 5 MEC-EU 41.4 77 0 LVM LWAK 310C1 5,792.0 11 3 0 NMEC 59.6 5 0 LVM LWAK 307C1 126,378.9 0 42 1 NMEC 66.8 2 0 LVM LWAK 307C3 102,580.4 0 45 4 NMEC 121.8 0 0 LVM LWAK 307C4 106,283.4 0 47 2 NMEC 145.4 0 0 LVM LWAK 307C2 108,824.3 0 46 1 NMEC 206.4 2 0 LVM LWAK 314C1 91,885.9 0 53 1 MEC-EU 227.3 19 0 LVM LWAK 313C1 110,430.6 0 52 8 NMEC 289.5 5 0 Mercury CK 303C1 217.9 0 00 NMEC 3.4 0 NS Mercury CK 404C1 42.6 23 0 65 MEC-P 4.4 100 NS Mercury CK 305C3 130,020.7 0 0 100 NMEC 5.0 0 NS Mercury CK 201C1 NA NA NA NA NC 5.4 0 NS Mercury CK 203C1 41.9 64 0 23 MEC-P 6.0 100 NS Mercury CK 406C1 117.3 31 0 82 MEC-P 7.7 100 NS Mercury CK 200C1 NA NA NA NA NC 11.1 0 NS Mercury CK 305C1 229.7 0 0 13 MEC-EU 16.3 0 NS Mercury CK 207C1 107.2 79 6 0 MEC-EU 17.0 0 NS Mercury CK 206C1 20,854.7 83 0 17 MEC-EU 17.4 0 NS Mercury CK 204C1 105.2 100 0 4 MEC-EU 18.9 0 NS Mercury CK 402C1 10,286.0 99 0 1 NMEC 19.5 100 NS Mercury CK 208C1 104.5 82 2 4 MEC-EU 19.5 25 NS Mercury CK 202C2 56.8 95 0 12 MEC-EU 20.2 0 NS Mercury CK 405C1 169.8 14 0 90 NMEC 20.8 100 NS Mercury CK 205C1 58.2 83 0 17 MEC-EU 29.8 0 NS



### 2-12

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution Mercury CK 401C5 58.0 19 0 78 MEC-EU 36.1 75 NS Mercury CK 304C1 96.5 92 0 9 MEC-EU 41.9 0 NS Mercury CK 309C1 151.1 0 58 0 MEC-EU 42.6 0 NS Mercury CK 402C4 45.6 0 0 72 MEC-EU 51.5 0 NS Mercury CK 319C1 75.3 100 0 7 MEC-EU 55.9 0 NS Mercury CK 335C1 25,928.4 2 0 98 NMEC 59.7 0 NS Mercury CK 303C3 377.8 0 0 14 MEC-EU 91.6 0 NS Mercury CK 30152 680.9 62 0 35 NMEC 105.5 33 NS Mercury CK 30142 680.9 62 0 35 NMEC 127.7 0 NS Mercury CK 401C1 556.4 6 0 94 NMEC 148.2 0 NS Mercury CK 403C1 75.8 27 0 70 NMEC 1,014.2 100 NS Mercury CK 306C1 3,835.8 0 83 0 NMEC 2,987.8 0 NS Mercury INC 221C5 51.1 5 0 100 MEC-P 0.1 0 NS Mercury INC 221C3 35.2 40 0 100 MEC-P 0.1 0 NS Mercury INC 216C7 NA NA NA NA NC 0.3 67 NS Mercury INC 346C1 NA NA NA NA NC 0.4 0 NS Mercury INC 347C4 NA NA NA NA NC 0.5 0 NS Mercury INC 824C1 5.1 3 0 100 MEC-P 0.8 0 NS Mercury INC 341C2 18.5 44 0 100 MEC-P 0.9 100 NS Mercury INC 216C5 NA NA NA NA NC 1.0 0 NS Mercury INC 503C1 NA NA NA NA NC 1.2 0 NS Mercury INC 341C1 9.0 100 0 100 MEC-EU 1.3 100 NS Mercury INC 354C1 1,861.7 0 0 100 NMEC 1.4 50 NS Mercury INC 725C1 NA NA NA NA NC 1.7 100 NS Mercury INC 353C1 NA NA NA NA NC 2.5 0 NS Mercury INC 209C1 234.1 0 100 0 NMEC 2.5 75 NS Mercury INC 705C1 0.1 100 0 100 NMEC 2.8 33 NS Mercury INC 500C1 106.1 99 0 100 NMEC 2.9 100 NS Mercury INC 209C2 253.8 0 100 0 NMEC 3.1 50 NS Mercury INC 347C2 NA NA NA NA NC 3.4 100 NS Mercury INC 334C2 37.8 45 0 100 MEC-EU 4.0 0 NS Mercury INC 347C1 NA NA NA NA NC 4.1 75 NS Mercury INC 221C1 8.5 67 0 100 MEC-EU 4.3 0 NS Mercury INC 330C1 0.1 100 0 0 MEC-EU 4.6 100 NS Mercury INC 700C1 9.4 100 2 73 MEC-EU 4.7 0 NS Mercury INC 807C3 0.7 33 0 100 MEC-EU 5.3 33 NS Mercury INC 330C2 0.2 80 0 21 MEC-EU 5.8 50 NS Mercury INC 342C1 NA NA NA NA NC 6.2 0 NS Mercury INC 353C2 NA NA NA NA NC 6.5 0 NS Mercury INC 340C1 182.6 45 0 100 NMEC 7.6 0 NS Mercury INC 334C1 296.9 0 70 30 NMEC 9.9 0 NS Mercury INC 807C1 14.3 0 0 100 MEC-EU 10.7 0 NS Mercury INC 340C2 135.7 31 0 100 NMEC 12.3 0 NS Mercury INC 347C3 NA NA NA NA NC 16.1 0 NS Mercury INC 807C2 1.8 0 0 100 NMEC 17.9 0 NS Mercury INC 221C4 15.4 100 0 100 MEC-EU 19.2 0 NS Mercury INC 705C2 9.3 100 0 100 NMEC 19.3 0 NS Mercury INC 400C1 27,680.5 0 100 0 NMEC 19.4 100 NS Mercury INC 325C7 52.1 0 0 100 NMEC 25.2 0 NS Mercury INC 325C6 95.8 0 0 100 NMEC 27.1 0 NS Mercury INC 221C2 30.2 57 0 100 MEC-EU 27.2 0 NS Mercury INC 338C1 NA NA NA NA NC 27.7 0 NS Mercury INC 325C5 263.1 0 0 100 NMEC 30.1 0 NS Mercury INC 214C3 3,357.9 0 0 100 NMEC 31.7 0 NS



### 2-13

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution Mercury INC 331C1 NA NA NA NA NC 38.8 0 NS Mercury INC 503C2 NA NA NA NA NC 42.9 0 NS Mercury INC 325C4 60.1 0 0 100 NMEC 44.4 0 NS Mercury INC 216C6 NA NA NA NA NC 44.6 67 NS Mercury INC 902C1 32.3 0 0 100 MEC-EU 47.7 0 NS Mercury INC 214C2 70,348.9 0 0 100 NMEC 48.8 0 NS Mercury INC 325C8 NA NA NA NA NC 69.3 0 NS Mercury INC 338C2 NA NA NA NA NC 89.6 0 NS Mercury INC 806C2 NA NA NA NA NC 117.8 0 NS Mercury INC 806C1 NA NA NA NA NC 172.6 0 NS Mercury INC 325C3 NA NA NA NA NC 177.8 0 NS Mercury INC 337C1 69.7 25 0 100 NMEC 188.1 0 NS Mercury INC 216C3 NA NA NA NA NC 261.0 0 NS Mercury INC 327C2 75.6 13 0 100 NMEC 394.5 0 NS Mercury INC 214C1 NA NA NA NA NC 481.6 0 NS Mercury INC 327C3 123.3 3 0 100 NMEC 1,121.5 0 NS Mercury INC 504C1 2,146.1 40 58 2 NMEC 1,322.7 40 NS Mercury INC 327C1 477.4 9 0 100 NMEC 1,360.7 0 NS Mercury LWAK 313C1 49.9 22 0 35 MEC-P 0.4 100 NS Mercury LWAK 225C1 14.0 0 0 21 MEC-P 4.6 0 NS Mercury LWAK 312C1 42.8 72 0 28 MEC-P 8.8 100 NS Mercury LWAK 310C1 38.4 72 0 28 MEC-EU 15.2 0 NS Mercury LWAK 311C1 58.0 60 0 40 NMEC 15.2 100 NS Mercury LWAK 224C1 28.6 0 0 33 MEC-EU 15.8 0 NS Mercury LWAK 227C1 63.6 100 0 15 MEC-EU 17.0 0 NS Mercury LWAK 314C1 115.1 13 0 51 NMEC 22.2 0 NS Mercury LWAK 223C1 45.7 0 0 37 MEC-EU 31.7 0 NS Mercury LWAK 307C1 2,419.8 0 95 1 NMEC 421.8 0 NS Mercury LWAK 307C3 2,065.2 0 95 1 NMEC 471.8 0 NS Mercury LWAK 307C4 2,295.4 0 95 1 NMEC 493.4 0 NS Mercury LWAK 307C2 2,217.4 0 96 1 NMEC 561.3 0 NS

SVM CK 320C1 35,653.6 0 0 94 MEC-P 3.6 0 0 SVM CK 316C2 77,748.9 0 61 24 MEC-P 5.6 0 0 SVM CK 316C1 95,860.8 0 71 16 MEC-P 6.2 0 0 SVM CK 30142 79,473.3 2 95 1 MEC-P 8.6 100 0 SVM CK 321C1 227,155.4 0 0 91 NMEC 11.4 0 0 SVM CK 303C1 13,035.9 0 00 MEC-EU 12.9 0 0 SVM CK 30152 79,473.3 2 95 1 MEC-EU 14.8 100 0 SVM CK 306C1 61,753.0 0 70 6 MEC-EU 16.6 0 0 SVM CK 315C2 164,643.8 0 72 23 NMEC 18.3 78 0 SVM CK 315C1 171,614.3 0 72 23 NMEC 21.1 72 0 SVM CK 317C1 48,622.4 0 88 0 MEC-EU 28.3 100 0 SVM CK 317C3 5,701.1 1 00 MEC-EU 28.8 100 0 SVM CK 317C2 56,230.0 0 73 2 MEC-EU 28.9 100 0 SVM CK 403C1 128,894.9 1 76 23 NMEC 29.7 91 0 SVM CK 303C3 35,633.3 0 3 70 MEC-EU 32.5 0 0 SVM CK 404C1 63,093.1 4 4 92 NMEC 57.4 100 0 SVM CK 200C1 32,707.1 18 55 27 NMEC 62.0 95 0 SVM CK 208C2 22,120.4 8 69 1 NMEC 86.9 0 0 SVM CK 308C1 58,155.3 0 47 0 NMEC 93.2 0 0 SVM CK 208C1 35,692.5 1 81 4 NMEC 98.0 0 0 SVM CK 202C2 214,452.0 0 84 3 NMEC 109.1 0 0 SVM CK 318C2 123,342.7 0 92 0 NMEC 140.1 0 0 SVM CK 322C1 140,893.6 0 14 84 NMEC 150.8 0 0



### 2-14

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution SVM CK 207C2 54,835.3 1 83 6 NMEC 257.9 0 0 SVM CK 206C1 170,002.5 0 89 8 NMEC 272.9 0 0 SVM CK 401C1 80,892.8 1 0 86 NMEC 381.5 76 0 SVM CK 204C1 216,633.7 1 89 9 NMEC 505.4 0 0 SVM CK 207C1 90,579.4 0 86 4 NMEC 506.9 0 0 SVM CK 203C1 162,344.6 0 98 0 NMEC 528.3 0 0 SVM CK 309C1 119,654.5 0 68 0 NMEC 543.1 0 0 SVM CK 304C1 142,852.2 1 80 17 NMEC 599.3 0 0 SVM CK 406C1 138,740.7 10 73 16 NMEC 661.7 100 0 SVM CK 319C1 24,613.1 3 0 89 NMEC 677.8 0 0 SVM CK 335C1 80,258.0 0 94 0 NMEC 752.5 33 0 SVM CK 402C1 210,733.1 0 93 6 NMEC 814.8 100 0 SVM CK 305C3 72,776.5 0 90 0 NMEC 897.3 34 0 SVM CK 201C1 178,734.7 4 87 9 NMEC 924.5 75 0 SVM CK 323C1 151,036.2 0 14 82 NMEC 972.7 0 0 SVM CK 205C1 143,721.6 0 86 11 NMEC 1,169.4 0 0 SVM CK 405C1 84,185.0 0 0 92 NMEC 1,169.9 79 0 SVM CK 305C1 161,791.3 0 94 0 NMEC 1,321.7 100 0 SVM CK 302C1 370,797.0 0 100 0 NMEC 1,529.0 0 0 SVM CK 401C5 152,359.7 0 0 95 NMEC 1,966.2 1 0 SVM CK 300C2 458,435.5 0 99 0 NMEC 2,345.3 0 0 SVM CK 402C4 50,808.1 0 31 57 NMEC 6,047.0 0 0 SVM INC 325C3 NA NA NA NA NC 1.5 0 0 SVM INC 712C1 0.2 50 0 100 NMEC 2.2 33 78 SVM INC 354C1 48,776.5 0 0 100 MEC-P 2.5 56 0 SVM INC 712C2 0.8 42 0 100 NMEC 2.6 67 77 SVM INC 222C5 NA NA NA NA NC 3.2 0 23 SVM INC 500C1 168.5 54 0 100 MEC-P 3.6 0 0 SVM INC 347C4 NA NA NA NA NC 4.0 75 0 SVM INC 325C8 NA NA NA NA NC 4.9 36 0 SVM INC 340C1 5,795.5 4 0 100 MEC-P 5.7 22 0 SVM INC 209C2 188,532.5 0 100 0 NMEC 6.9 0 0 SVM INC 341C2 494.7 100 0 100 MEC-EU 10.4 100 0 SVM INC 209C1 129,450.2 0 100 0 NMEC 10.7 0 0 SVM INC 353C1 NA NA NA NA NC 11.1 84 0 SVM INC 347C1 NA NA NA NA NC 11.8 16 0 SVM INC 347C3 NA NA NA NA NC 12.9 10 0 SVM INC 221C2 4,666.0 25 0 100 NMEC 13.2 17 0 SVM INC 340C2 3,785.9 7 0 100 MEC-EU 13.3 0 0 SVM INC 347C2 NA NA NA NA NC 13.6 0 0 SVM INC 341C1 439.3 100 0 100 MEC-EU 17.3 73 0 SVM INC 342C1 NA NA NA NA NC 20.7 0 0 SVM INC 348C1 904.3 0 86 14 MEC-EU 22.1 0 82 SVM INC 221C3 2,077.3 2 0 100 NMEC 22.5 0 0 SVM INC 229C1 89.0 100 0 100 MEC-EU 23.4 100 85 SVM INC 327C2 3,798.5 1 0 100 MEC-EU 23.4 55 0 SVM INC 902C1 240.1 0 0 100 NMEC 23.9 2 0 SVM INC 344C2 NA NA NA NA NC 24.1 0 15 SVM INC 327C1 11,147.7 4 0 100 MEC-EU 24.6 0 0 SVM INC 229C3 0.6 0 0 100 NMEC 25.1 100 85 SVM INC 338C1 NA NA NA NA NC 27.5 100 0 SVM INC 221C5 1,290.0 5 0 100 NMEC 28.9 0 0 SVM INC 229C2 124.9 100 0 100 MEC-EU 31.2 100 86 SVM INC 338C2 NA NA NA NA NC 31.4 100 0



### 2-15

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution SVM INC 327C3 10,365.5 4 0 100 MEC-EU 37.3 0 0 SVM INC 725C1 NA NA NA NA NC 37.4 13 0 SVM INC 349C3 532,412.1 0 0 100 NMEC 39.8 0 12 SVM INC 824C1 375.0 4 0 100 NMEC 41.5 0 0 SVM INC 221C4 443.1 37 0 100 NMEC 43.5 0 0 SVM INC 504C1 14,632.0 40 46 14 NMEC 44.0 18 0 SVM INC 807C3 48,240.5 39 41 59 NMEC 56.5 0 0 SVM INC 325C7 10,715.7 0 0 100 MEC-EU 57.6 0 0 SVM INC 229C5 0.9 0 0 100 NMEC 62.9 100 90 SVM INC 229C6 0.5 0 0 100 NMEC 68.8 100 90 SVM INC 346C1 NA NA NA NA NC 89.3 0 0 SVM INC 325C4 4,884.1 0 0 100 NMEC 91.1 0 0 SVM INC 337C1 45,855.7 0 0 100 MEC-EU 93.8 48 0 SVM INC 221C1 162.6 29 0 100 MEC-EU 100.9 0 0 SVM INC 216C3 NA NA NA NA NC 102.5 0 0 SVM INC 705C1 0.3 34 0 100 NMEC 116.3 0 0 SVM INC 214C1 NA NA NA NA NC 200.7 7 0 SVM INC 353C2 NA NA NA NA NC 210.2 0 0 SVM INC 325C6 5,805.1 0 0 100 NMEC 224.9 0 0 SVM INC 359C4 NA NA NA NA NC 227.2 1 0 SVM INC 330C2 357.7 0 0 33 NMEC 244.0 0 0 SVM INC 325C5 4,360.1 0 0 100 NMEC 245.2 0 0 SVM INC 807C1 174,719.8 4 8 92 NMEC 261.5 0 0 SVM INC 705C2 152.8 0 0 100 NMEC 301.1 0 0 SVM INC 807C2 230,683.1 5 10 90 NMEC 311.6 0 0 SVM INC 359C5 NA NA NA NA NC 331.9 0 0 SVM INC 330C1 108.4 0 00 NMEC 418.0 0 0 SVM INC 806C2 NA NA NA NA NC 460.5 0 0 SVM INC 324C1 3,849.3 0 0 100 NMEC 537.0 0 0 SVM INC 806C1 NA NA NA NA NC 590.9 0 0 SVM INC 400C1 2,538,984.8 0 62 NMEC 656.3 6 0 SVM INC 214C2 151,644.3 0 0 100 NMEC 689.3 0 0 SVM INC 503C1 302,755.9 0 0 100 NMEC 720.6 0 0 SVM INC 216C7 NA NA NA NA NC 826.4 0 0 SVM INC 324C4 13,446.0 0 0 100 NMEC 837.7 0 0 SVM INC 809C1 20,803.1 0 0 100 NMEC 864.6 0 0 SVM INC 810C1 56,371.0 0 0 100 NMEC 881.8 0 0 SVM INC 503C2 68,334.4 0 0 100 NMEC 910.7 0 0 SVM INC 359C6 NA NA NA NA NC 992.6 1 0 SVM INC 214C3 343,542.0 0 0 100 NMEC 999.7 0 0 SVM INC 216C5 NA NA NA NA NC 1,020.7 0 0 SVM INC 216C6 NA NA NA NA NC 1,044.6 0 0 SVM INC 915C1 NA NA NA NA NC 1,283.6 0 0 SVM INC 502C1 NA NA NA NA NC 1,508.9 100 89 SVM INC 334C2 566.1 20 0 100 NMEC 1,705.8 0 0 SVM INC 810C2 653,522.8 0 0 100 NMEC 1,776.7 0 0 SVM INC 324C2 3,282.9 0 0 100 NMEC 3,040.5 0 0 SVM INC 331C1 NA NA NA NA NC 3,465.5 0 0 SVM INC 334C1 122,028.5 0 14 86 NMEC 7,963.8 0 0 SVM INC 324C3 228.7 0 0 100 NMEC 8,261.8 0 0 SVM INC 809C2 205,716.7 0 0 100 NMEC 19,769.5 0 0 SVM INC 700C1 222,056.8 0 7 93 NMEC 29,350.3 0 0 SVM INC 905C1 13,398.2 1 99 1 NMEC 29,762.5 0 94 SVM LWAK 225C1 277,211.2 0 0 97 MEC-P 1.1 22 0



### 2-16

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution SVM LWAK 307C4 70,856.3 0 73 3 MEC-P 3.9 0 0 SVM LWAK 224C1 22,808.6 0 0 65 MEC-P 4.0 0 0 SVM LWAK 307C3 75,129.6 0 64 12 NMEC 4.2 0 0 SVM LWAK 223C1 751,196.6 0 0 97 NMEC 5.2 15 0 SVM LWAK 307C2 67,879.8 0 74 1 MEC-EU 7.5 0 0 SVM LWAK 307C1 73,305.8 0 74 1 NMEC 10.2 0 0 SVM LWAK 227C1 999,463.7 0 03 NMEC 31.0 0 0 SVM LWAK 312C1 459,621.6 0 100 0 NMEC 403.2 0 0 SVM LWAK 310C1 6,028.5 8 50 NMEC 495.4 0 0 SVM LWAK 311C1 381,753.3 0 98 0 NMEC 515.9 23 0 SVM LWAK 313C1 701,322.0 0 98 0 NMEC 663.2 0 0 SVM LWAK 314C1 706,422.1 0 97 0 NMEC 1,667.1 0 0 TCl CK 204C2 1,742,478.8 0 0 93 MEC-P 0.1 100 0 TCl CK 304C2 NA NA NA NA NC 0.4 2 0 TCl CK 30141 1,462,098.2 3 65 15 MEC-P 0.4 0 0 TCl CK 403C1 2,057,846.9 21 0 78 MEC-P 0.7 1 0 TCl CK 30151 1,462,098.2 3 65 15 MEC-EU 0.7 0 0 TCl CK 403C2 2,696,105.5 21 22 57 NMEC 0.9 0 0 TCl CK 315C1 684,170.8 0 0 69 MEC-EU 1.4 4 0 TCl CK 202C1 1,062,500.4 0 0 25 MEC-EU 1.7 59 0 TCl CK 303C1 226,256.9 0 00 MEC-EU 2.0 0 0 TCl CK 315C2 636,172.8 0 0 61 MEC-EU 2.7 2 0 TCl CK 317C1 292,532.1 0 37 5 MEC-EU 2.9 2 0 TCl CK 306C1 771,595.2 0 0 96 MEC-EU 2.9 12 0 TCl CK 405C1 2,484,312.1 34 0 66 NMEC 3.2 25 0 TCl CK 317C2 612,614.4 0 40 2 MEC-EU 3.7 3 0 TCl CK 208C1 633,861.1 27 0 67 MEC-EU 4.5 0 0 TCl CK 207C1 965,856.8 18 0 76 MEC-EU 4.9 0 0 TCl CK 308C1 1,002,525.1 0 0 78 MEC-EU 5.6 0 0 TCl CK 320C1 444,012.7 0 0 75 MEC-EU 5.9 0 3 TCl CK 317C3 196,062.0 0 00 MEC-EU 7.0 1 0 TCl CK 321C1 1,658,457.7 0 0 70 MEC-EU 9.5 0 0 TCl CK 302C1 2,380,025.6 0 0 93 NMEC 10.2 0 0 TCl CK 401C5 2,399,051.9 21 24 53 NMEC 10.4 0 0 TCl CK 205C1 610,896.6 27 0 62 MEC-EU 16.6 2 0 TCl CK 200C1 3,258,074.9 0 1 99 NMEC 18.2 0 0 TCl CK 201C1 3,052,481.2 0 1 98 NMEC 20.1 0 0 TCl CK 402C1 3,298,287.4 12 0 84 NMEC 21.6 1 0 TCl CK 402C4 3,429,472.1 0 58 24 NMEC 22.0 0 0 TCl CK 316C2 816,673.0 0 0 53 MEC-EU 22.2 0 0 TCl CK 322C1 3,065,543.7 0 0 97 NMEC 22.6 0 0 TCl CK 319C2 974,869.9 0 0 94 NMEC 27.1 2 0 TCl CK 305C3 598,282.2 0 0 78 MEC-EU 28.4 0 0 TCl CK 202C2 1,998,943.1 0 0 47 MEC-EU 31.1 2 0 TCl CK 300C1 2,247,132.9 0 0 99 NMEC 33.8 0 0 TCl CK 316C1 1,095,120.5 0 0 64 MEC-EU 35.1 0 0 TCl CK 309C1 1,089,309.8 0 0 94 MEC-EU 35.7 0 2 TCl CK 303C2 1,518,538.0 0 0 79 MEC-EU 36.0 0 0 TCl CK 401C1 4,234,415.2 0 0 86 NMEC 36.2 1 0 TCl CK 319C8 404,984.8 0 0 100 MEC-EU 42.4 0 0 TCl CK 319C7 NA NA NA NA NC 42.5 0 3 TCl CK 406C1 1,738,244.5 52 0 47 MEC-EU 42.8 0 0 TCl CK 318C2 NA NA NA NA NC 50.6 0 0 TCl CK 319C4 1,514,611.3 0 0 98 NMEC 51.1 1 0



### 2-17

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution TCl CK 318C1 900,677.7 0 82 0 MEC-EU 51.3 0 0 TCl CK 404C2 2,654,836.3 23 19 58 NMEC 56.8 0 0 TCl CK 309C2 1,072,723.4 0 0 94 MEC-EU 57.0 1 0 TCl CK 323C1 3,546,560.8 2 0 98 NMEC 71.9 0 0 TCl CK 404C1 2,123,539.7 23 0 77 NMEC 76.6 0 0 TCl CK 206C1 1,083,502.9 6 0 91 MEC-EU 81.2 0 0 TCl CK 203C1 1,342,501.0 0 0 99 MEC-EU 117.2 0 0 TCl CK 335C1 805,239.2 0 0 77 MEC-EU 121.9 0 0 TCl CK 305C1 4,389,885.2 0 0 64 MEC-EU 157.2 0 0 TCl CK 319C6 824,518.1 0 0 100 MEC-EU 220.8 0 0 TCl INC 347C2 NA NA NA NA NC 0.1 100 4 TCl INC 358C2 11,104,454.0 0 0 100 MEC-P 0.2 100 10 TCl INC 338C1 NA NA NA NA NC 0.2 85 0 TCl INC 342C2 4,360,000.0 0 0 100 MEC-P 0.3 0 13 TCl INC 706C3 17,288,058.0 0 0 100 MEC-P 0.3 100 16 TCl INC 338C2 NA NA NA NA NC 0.3 100 0 TCl INC 808C2 20,900,959.4 0 0 100 NMEC 0.3 0 9 TCl INC 706C1 15,581,600.7 0 0 100 MEC-EU 0.4 33 16 TCl INC 354C3 14,130,722.0 0 0 100 MEC-EU 0.4 0 0 TCl INC 222C1 NA NA NA NA NC 0.4 35 0 TCl INC 337C2 95,948.7 0 0 100 NMEC 0.4 100 17 TCl INC 728C1 18,261,591.2 0 0 100 NMEC 0.4 33 12 TCl INC 347C1 NA NA NA NA NC 0.5 100 7 TCl INC 600C1 30,545,151.4 0 0 100 NMEC 0.6 0 18 TCl INC 707C7 NA NA NA NA NC 0.6 0 16 TCl INC 358C3 42,204,909.6 0 0 100 NMEC 0.6 0 16 TCl INC 327C2 NA NA NA NA NC 0.6 37 0 TCl INC 808C1 25,837,359.1 0 0 100 NMEC 0.7 0 16 TCl INC 711C1 908,974.0 0 0 100 MEC-EU 0.8 0 13 TCl INC 346C1 NA NA NA NA NC 0.9 100 14 TCl INC 348C1 98,473,465.6 0 0 100 NMEC 0.9 7 0 TCl INC 711C2 170,321.7 0 0 100 MEC-EU 0.9 0 15 TCl INC 706C2 17,331,118.8 0 0 100 MEC-EU 1.0 33 13 TCl INC 708C3 55,155,746.1 0 0 100 NMEC 1.0 0 17 TCl INC 214C3 50,478,083.6 0 0 100 NMEC 1.0 0 15 TCl INC 344C2 NA NA NA NA NC 1.1 100 12 TCl INC 711C3 777,612.5 0 0 100 MEC-EU 1.1 0 15 TCl INC 701C2 NA NA NA NA NC 1.1 0 16 TCl INC 344C1 NA NA NA NA NC 1.3 100 15 TCl INC 354C4 NA NA NA NA NC 1.3 0 0 TCl INC 708C2 62,228,319.6 0 0 100 NMEC 1.4 0 16 TCl INC 500C4 15,362,888.1 0 0 100 MEC-EU 1.4 0 14 TCl INC 325C4 11,923,572.6 0 0 100 MEC-EU 1.4 0 15 TCl INC 708C1 87,164,119.5 0 0 100 NMEC 1.4 0 13 TCl INC 807C1 3,293,720.2 0 50 50 NMEC 1.6 0 0 TCl INC 327C3 NA NA NA NA NC 1.7 16 0 TCl INC 707C1 NA NA NA NA NC 1.7 0 13 TCl INC 347C3 NA NA NA NA NC 1.8 50 10 TCl INC 359C2 22,364,553.3 0 0 100 NMEC 1.8 0 14 TCl INC 341C2 2,615,611.0 0 0 100 NMEC 1.8 0 14 TCl INC 600C2 49,075,983.5 0 0 100 NMEC 1.8 0 14 TCl INC 325C8 NA NA NA NA NC 1.8 0 12 TCl INC 222C6 28,393,411.3 0 8 92 NMEC 1.9 6 0 TCl INC 222C3 NA NA NA NA NC 1.9 2 0



### 2-18

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution TCl INC 214C1 24,175,528.8 0 32 68 NMEC 1.9 100 14 TCl INC 500C3 18,514,615.4 0 0 100 NMEC 2.2 0 0 TCl INC 359C3 16,029,222.6 0 0 100 MEC-EU 2.3 0 12 TCl INC 214C2 28,215,744.7 0 0 100 NMEC 2.3 0 13 TCl INC 354C2 31,068,928.3 0 0 11 MEC-EU 2.4 0 0 TCl INC 824C1 4,913,814.1 0 0 100 MEC-EU 2.4 0 13 TCl INC 209C4 11,315,783.9 0 0 100 MEC-EU 2.8 67 12 TCl INC 707A2 7,753,464.2 0 0 100 MEC-EU 2.9 0 12 TCl INC 807C2 4,269,177.4 0 57 43 NMEC 3.2 0 0 TCl INC 325C5 1,707,069.5 0 0 100 MEC-EU 3.4 0 11 TCl INC 807C3 4,213,072.9 0 57 43 NMEC 3.5 0 0 TCl INC 359C1 22,538,919.7 0 0 100 NMEC 3.5 0 12 TCl INC 222C2 NA NA NA NA NC 4.0 0 0 TCl INC 825C1 34,472,305.6 0 0 100 NMEC 4.0 0 12 TCl INC 700C2 1,742,179.7 0 99 1 MEC-EU 4.2 2 0 TCl INC 359C4 7,185,540.1 0 0 100 MEC-EU 4.3 0 10 TCl INC 358C1 46,794,611.7 0 0 100 NMEC 4.3 25 12 TCl INC 209C7 33,641,223.7 0 47 53 NMEC 4.3 0 10 TCl INC 209C8 48,143,128.8 0 35 65 NMEC 4.4 0 11 TCl INC 707C8 NA NA NA NA NC 4.6 0 11 TCl INC 902C1 39,190,185.7 0 1 99 NMEC 4.6 0 10 TCl INC 209C5 27,181,752.5 0 47 53 NMEC 4.7 0 10 TCl INC 347C4 NA NA NA NA NC 4.9 0 9 TCl INC 504C1 69,833.5 22 0 56 MEC-EU 5.1 20 9 TCl INC 229C3 193,037,453.4 0 0 100 NMEC 5.5 0 9 TCl INC 359C5 7,315,821.2 0 0 100 MEC-EU 5.6 0 9 TCl INC 209C6 36,491,648.0 0 63 37 NMEC 5.8 0 9 TCl INC 714C4 4,646,659.8 0 0 100 MEC-EU 6.2 0 9 TCl INC 325C6 3,274,320.7 0 0 100 MEC-EU 6.4 0 11 TCl INC 341C1 892,336.7 0 0 100 NMEC 6.8 0 11 TCl INC 707A1 NA NA NA NA NC 7.2 0 8 TCl INC 701C3 NA NA NA NA NC 7.2 0 8 TCl INC 357C1 10,464,373.6 0 0 100 MEC-EU 7.5 33 8 TCl INC 707C9 8,170,922.6 0 17 83 MEC-EU 7.6 0 8 TCl INC 354C1 40,177,202.8 0 09 MEC-EU 7.7 0 0 TCl INC 707C2 6,481,359.2 0 18 82 MEC-EU 7.9 0 8 TCl INC 329C1 19,977,309.6 0 32 68 NMEC 8.3 11 0 TCl INC 358C4 43,931,296.8 0 0 100 NMEC 9.1 0 7 TCl INC 705C2 NA NA NA NA NC 9.2 0 7 TCl INC 327C1 NA NA NA NA NC 9.7 0 0 TCl INC 216C7 NA NA NA NA NC 9.7 0 7 TCl INC 216C2 NA NA NA NA NC 10.4 0 7 TCl INC 221C3 NA NA NA NA NC 11.4 33 0 TCl INC 339C1 35,605,365.5 0 0 100 NMEC 11.5 0 48 TCl INC 707C4 9,026,493.2 0 5 95 MEC-EU 11.8 0 6 TCl INC 705C1 NA NA NA NA NC 12.3 0 7 TCl INC 334C1 4,175,240.1 0 0 100 MEC-EU 13.0 0 6 TCl INC 707C3 10,850,269.1 0 17 83 MEC-EU 13.0 0 7 TCl INC 340C1 4,449,624.4 0 0 100 MEC-EU 14.0 0 6 TCl INC 221C2 NA NA NA NA NC 14.7 50 0 TCl INC 210C1 19,891,897.3 0 0 100 NMEC 15.7 2 0 TCl INC 221C1 NA NA NA NA NC 16.5 50 0 TCl INC 209C1 38,599,501.3 0 0 100 NMEC 16.6 0 0 TCl INC 502C1 9,622,636.2 0 0 100 MEC-EU 19.7 0 9



### 2-19

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution TCl INC 334C2 9,386,817.8 0 50 50 MEC-EU 21.7 0 5 TCl INC 340C2 2,369,008.7 0 0 100 MEC-EU 22.4 0 5 TCl INC 701C1 NA NA NA NA NC 26.1 0 6 TCl INC 713C1 122,090.6 33 0 67 MEC-EU 26.9 0 6 TCl INC 500C1 2,705,629.5 0 0 100 MEC-EU 28.9 0 0 TCl INC 700C1 3,191,282.5 0 0 100 MEC-EU 29.6 0 0 TCl INC 714C3 6,375,485.3 0 0 100 MEC-EU 32.0 0 6 TCl INC 359C6 6,266,641.5 0 0 100 MEC-EU 32.6 0 6 TCl INC 221C4 NA NA NA NA NC 34.2 0 0 TCl INC 209C3 10,366,609.0 0 0 100 MEC-EU 35.3 0 6 TCl INC 211C1 25,495,956.0 0 0 100 NMEC 37.7 0 0 TCl INC 325C7 8,710,859.1 0 0 100 MEC-EU 39.3 0 9 TCl INC 221C5 NA NA NA NA NC 39.7 0 0 TCl INC 906C2 4,816,362.1 0 0 100 MEC-EU 44.1 0 7 TCl INC 806C1 NA NA NA NA NC 45.3 0 8 TCl INC 333C1 8,571,833.3 0 95 5 NMEC 48.6 0 0 TCl INC 806C2 1,403.4 0 0 19 MEC-EU 52.2 0 8 TCl INC 210C2 18,072,742.0 0 0 100 NMEC 54.1 0 0 TCl INC 229C6 217,450,435.4 0 0 100 NMEC 54.4 0 8 TCl INC 330C1 26,461,321.0 0 00 NMEC 55.8 2 6 TCl INC 333C2 13,116,961.7 0 93 7 NMEC 59.0 0 0 TCl INC 332C1 38,443,972.6 0 0 100 NMEC 64.8 0 0 TCl INC 714C2 7,340,293.1 0 0 100 MEC-EU 70.3 0 10 TCl INC 714C1 10,384,011.5 0 0 100 MEC-EU 70.4 0 10 TCl INC 725C1 NA NA NA NA NC 75.2 0 0 TCl INC 229C5 257,945,460.5 0 0 100 NMEC 96.8 0 11 TCl INC 337C1 NA NA NA NA NC 99.3 0 89 TCl INC 229C1 154,205,029.7 0 0 100 NMEC 102.0 0 11 TCl INC 805C1 3,469,660.1 0 0 100 MEC-EU 106.5 100 89 TCl INC 209C2 40,448,982.5 0 0 100 NMEC 106.5 0 0 TCl INC 212C1 33,089,898.4 0 0 100 NMEC 133.9 0 0 TCl INC 906C1 62,174,232.2 0 0 100 NMEC 134.3 0 13 TCl INC 714C5 12,664,653.2 0 0 100 NMEC 135.6 0 12 TCl INC 500C2 12,563,190.2 0 0 100 NMEC 139.3 0 0 TCl INC 906C3 52,669,224.0 0 0 100 NMEC 159.4 0 12 TCl INC 229C4 185,712,877.3 0 0 100 NMEC 159.8 0 13 TCl INC 324C4 273,973.5 0 0 100 NMEC 163.2 0 10 TCl INC 704C1 94,465,585.0 0 0 100 NMEC 163.7 0 12 TCl INC 725C2 NA NA NA NA NC 164.7 0 0 TCl INC 906C5 79,390,184.4 0 0 100 NMEC 188.3 0 14 TCl INC 324C3 231,127.5 0 0 100 NMEC 192.6 0 12 TCl INC 324C1 297,188.1 0 0 100 NMEC 200.9 0 13 TCl INC 704C2 114,017,434.8 0 0 100 NMEC 214.3 0 15 TCl INC 324C2 168,886.2 0 0 100 NMEC 215.1 0 13 TCl INC 229C2 196,384,497.5 0 0 100 NMEC 218.1 0 15 TCl INC 914C1 17,715,965.7 0 13 87 NMEC 227.1 0 84 TCl INC 906C4 65,669,151.4 0 0 100 NMEC 252.7 0 15 TCl INC 703C1 541,312.9 0 71 29 NMEC 325.5 0 17 TCl INC 710C3 45,181,479.0 0 0 100 NMEC 346.8 0 0 TCl INC 710C1 65,244,148.6 0 0 100 NMEC 355.5 0 0 TCl INC 703C2 487,048.9 0 67 33 NMEC 378.1 0 17 TCl INC 710C2 49,100,826.8 0 0 100 NMEC 439.6 0 0 TCl INC 784C1 NA NA NA NA NC 1,012.3 0 14 TCl INC 784C2 NA NA NA NA NC 1,067.9 0 15



### 2-20

### TABLE 2-1. CONTRIBUTION OF SPIKING, FULL DETECTION LIMIT FOR ND DATA, AND SUBSTITUTION TO MTECs AND EMISSIONS

Substance System Type Condition ID Avg MTEC (ug/dscm 7%O2) Avg % ND MTEC Avg % Spike Avg % Waste MACT Status Avg Emission*,** Avg % ND Emission Avg % Substitution TCl LWAK 307C3 7,699,495.9 0 25 75 MEC-P 13.3 0 0 TCl LWAK 307C2 13,945,545.4 0 47 53 MEC-P 26.0 0 0 TCl LWAK 224C1 858,424.6 0 0 99 NMEC 28.8 0 0 TCl LWAK 307C4 12,158,726.1 0 39 61 MEC-P 30.9 0 0 TCl LWAK 307C1 3,309,745.9 0 0 100 MEC-P 41.7 0 0 TCl LWAK 225C1 844,132.9 0 0 99 MEC-P 641.1 0 0 TCl LWAK 314C1 1,874,347.1 18 0 82 MEC-P 853.2 0 0 TCl LWAK 310C1 1,038,724.2 27 0 73 MEC-EU 1,199.1 0 0 TCl LWAK 312C1 2,219,364.7 14 0 86 NMEC 1,241.2 0 0 TCl LWAK 311C1 1,244,108.4 29 0 71 MEC-EU 1,258.4 0 0 TCl LWAK 227C1 1,142,440.9 0 0 47 MEC-EU 1,347.1 0 0 TCl LWAK 313C1 2,382,537.9 12 0 88 NMEC 1,509.0 0 0 TCl LWAK 223C1 2,407,090.7 0 0 100 NMEC 2,079.5 0 0

Acronyms: (*): Sorted by emission (**): ug/dscm @ 7% O2for LVM, SVM, and Mercury; ppmv @ 7% O2for TCl Avg: Average MTEC: Maximum Theoretical Emission Concentration NA: Not Available NC: Not Considered (because it has no MTEC) NS: No Substitution MEC-P: MACT Emission Control Technology Pool MEC-EU: MACT Emission Control Technology Expanded Universe NMEC: non-MACT Emission Control Technology



### 2-21TABLE 2-2. AVERAGE AND MEDIAN CONTRIBUTIONS OF FULL DETECTION LIMIT ND DATA ANDSUBSTITUTION TO EMISSIONS OF HAPSSubstance System Emission Emissions ND Emissions (%) Substituted Emissions (%)Type Units Average Median Count Average Median Count Average Median CountLVM CK ug/dscm7%O2 64.09 23.47 45 47.4 37.3 45 8.0 0.0 45LVM INC ug/dscm7%O2 1853.71 57.73 88 24.6 4.6 88 9.0 0.0 88LVM LWAK ug/dscm7%O2 98.95 59.61 13 12.4 1.7 13 0.0 0.0 13Mercury CK ug/dscm7%O2 173.89 39.00 47 39.1 23.2 47 0.0 0.0 0Mercury INC ug/dscm7%O2 295.30 12.74 79 25.5 0.0 79 0.0 0.0 0Mercury LWAK ug/dscm7%O2 464.67 47.78 28 22.8 0.0 28 0.0 0.0 0SVM CK ug/dscm7%O2 575.78 150.83 45 34.1 0.0 45 0.0 0.0 45SVM INC ug/dscm7%O2 1464.26 89.34 85 18.1 0.0 85 10.7 0.0 85SVM LWAK ug/dscm7%O2 293.22 10.23 13 4.7 0.0 13 0.0 0.0 13TCl CK ppmv7%O2 33.27 21.77 52 4.3 0.0 52 0.2 0.0 52TCl INC ppmv7%O2 59.46 7.36 152 11.4 0.0 152 9.8 9.1 152TCl LWAK ppmv7%O2 789.95 853.21 13 0.0 0.0 13 0.0 0.0 13TABLE 2-3. AVERAGE AND MEDIAN CONTRIBUTIONS OF SPIKING AND FULL DETECTION LIMIT ND NATA TO MTECs OF HAP'sSubstance System MTEC (ug/dscm 7%O2) % Spike % ND MTEC % ND Fuel % ND Raw Material % ND Spike % ND WasteType Average Median Average Median Average Median Average Median Average Median Average Median Average MedianHg CK 7499.04 134.21 5.68 0.00 43.19 29.14 28.85 0.00 74.36 100.00 0.00 0.00 11.89 0.00Hg INC 2921.63 52.13 11.61 0.00 33.52 12.61 13.51 0.00 0.00 0.00 2.70 0.00 28.45 4.81Hg LWAK 727.22 58.01 29.39 0.00 26.07 0.00 0.00 0.00 35.90 0.00 0.00 0.00 7.69 0.00LVM CK 137981.17 93974.42 56.86 62.37 8.52 3.18 15.14 2.80 27.21 12.80 0.19 0.00 9.04 0.02LVM INC 121202.71 6237.85 15.64 0.00 16.84 2.83 8.58 0.00 0.00 0.00 7.02 0.00 18.30 1.32LVM LWAK 102521.82 106283.40 28.12 32.61 0.91 0.00 0.00 0.00 1.00 0.00 0.59 0.00 5.23 0.00SVM CK 117527.48 90579.44 59.40 73.06 1.36 0.24 12.00 0.57 17.29 4.75 0.01 0.00 0.76 0.00SVM INC 108887.52 4665.96 9.05 0.00 14.23 0.02 4.03 0.00 0.00 0.00 0.00 0.00 15.85 0.00SVM LWAK 353307.63 277211.18 52.60 72.92 0.65 0.00 0.00 0.00 13.58 0.00 5.41 0.00 0.00 0.00TCl CK 1623683.67 1342500.98 8.45 0.00 5.98 0.00 13.35 0.00 29.08 0.00 0.30 0.00 0.01 0.00TCl INC 32014712.72 15805411.68 8.71 0.00 0.51 0.00 1.13 0.00 0.00 0.00 0.00 0.00 0.02 0.00TCl LWAK 3932668.05 2219364.75 8.60 0.00 7.69 0.00 0.00 0.00 38.46 0.00 0.00 0.00 0.00 0.00TABLE 2-4. 50th AND 90th EMISSION PERCENTILES ASSUMING ND DATA AT FULL AND AT 1/2 DETECTION LIMITS (USING AVERAGE RANKBASED EMISSION SUBSTITUTION)SubstanceSystem TypeUnitsEmiss Conc (ND @ Full Det Limit) Emiss Conc (ND @ 1/2 Det Limit)50th Percentile 90th Percentile 50th Percentile 90th PercentileHg CK ug/dscm 7%O230.30 282.27 24.54 252.52Hg INC ug/dscm 7%O29.94 186.54 8.64 182.49Hg LWAKug/dscm 7%O237.09 663.44 31.97 717.67LVM CK ug/dscm 7%O228.91 152.91 21.17 98.28LVM INC ug/dscm 7%O263.72 659.97 54.39 599.52LVM LWAKug/dscm 7%O254.51 218.35 50.84 209.21SVM CK ug/dscm 7%O2138.63 1607.98 108.90 1398.50SVM INC ug/dscm 7%O2104.48 2036.09 93.56 2032.06SVM LWAKug/dscm 7%O227.95 621.83 27.24 613.18TCl CK ppmv 7%O211.16 103.12 10.87 106.96TCl INC ppmv 7%O28.06 139.10 7.42 145.07TCl LWAKppmv 7%O2203.06 3369.76 203.06 3369.76

# SECTION 3

SUBSTITUTION METHODOLOGY FOR LVM, SVM, AND TCl

Toxic metals of interest for EPA/OSW were divided into three major groups based on the volatility of metals. Selection of and justification for the metals volatility groupings are discussed in detail in the last section of this report. The three volatility groups are: low-volatility metals (LVM) including Sb, As, Be, and Cr; semi-volatility metals (SVM) including Cd and Pb; and high-volatility metals represented by Hg. Chlorine and HCl emissions were also grouped to represent total chlorine (TCl) emissions. The emission of LVM or SVM for a given run is defined as the sum of emissions for all metals in the LVM or SVM group. TCl emission, however, is the sum of HCl concentration and twice the reported Cl2 

# concentration corresponding to total chloride (Cl) emission concentration.

Substitution of data became necessary in calculating emissions for the above metals and chlorine groups when a facility did not measure all of the elements in a particular group during a given run in a trial burn. For example, a facility may have measured only Sb, As, and Cr during a trial burn run but not Be. In such a case, before the LVM is calculated, an estimate of the Be emission was obtained based on the ranking of emissions of the other measured metals in the LVM group on a run basis. This procedure was performed by considering available LVM data from all source categories and ranking each metal according to its emissions. Then, the average rank of the LVM metals for the condition where Be data was not available was calculated and assumed to be the rank of the Be missing data. The Be concentration which corresponds to this average rank was then identified and substituted for the missing Be measurement. Therefore, as long as at least one element in any group was measured for a given run, the emissions of other missing elements were substituted for based on the average rank of the measured elements in the same group. More details on the substitution methodology and procedure are presented in theTechnical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies

. It is important to note here that the average rank based substitution was performed only for elements with missing emissions data in a particular group.

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# However, this substitution methodology was not performed for missing feed rate data when calculating feed rates (or MTEC concentrations) for the above groups. Therefore, a missing feed rate for any element in a group was assumed to be zero, and if all feed rates for all elements within a group were missing, the feed rate of the group for that run was considered not reported and there was no MTEC for that run. Furthermore, the emission results from such runs were not included in the MACT analysis.

Substitution of data became essential because in many facilities only a few of the elements in a given group were measured, and if the analyses were to be conducted only on groups with measured data for all elements, there would have been insufficient data in some cases to perform the various tasks of the program. An example of this is TCl emissions from INCs where most facilities measured only HCl emissions because they were not required to measure Cl2

# emissions. Table 2-1 shows that most TCl conditions have substitution due to missing Cl2

# measurements. However, because Cl2

# concentrations are typically much lower than HCl concentrations, Table 2-2 shows that less than 10% of the TCl emissions from INCs is attributable to substitution.

The main concern regarding data substitution is the impact of the methodology on the results from the various tasks in the program. Tables 2-1 and 2-2 provide information on the percentages of data attributable to emission data substitution for all HAPs and combustion sources. Table 2-1 provides these percentages on a condition basis while Table 2-2 provides averages and medians for the three HAP groups and source categories. The impact of the substitution methodology on the various tasks of the program is discussed below.

3.1 MACT ANALYSIS

Details of the MACT procedure and analysis for all HAPs and source categories are presented and discussed in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. A brief description of the MACT analysis is also presented in Section 2.1 of this report. Similar to ND emission data consideration, the impact of emissions substitution on determining the MACT pool facilities (the lowest 6% condition emissions) was not considered. In most cases, however, Table 2-1 shows that the substitution percentages for MACT pool facilities are zero. Only a few cases (5 out of 33 conditions) have substitutions ranging from 10% to 16% and one condition (LVM from a cement kiln)

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# has a substitution of 33%. Moreover, conditions with high substitution percentages were excluded from the MACT EU. This was performed to guarantee that when the MACT floor limit is determined (based on the worst emitting facility in the MACT EU), a facility with a high percentage of data substitution will not be the determining MACT floor level facility. It is important to note here that substitution of data may impact only HAPs made of groups of elements including LVM, SVM, and TCl. Mercury data, on the other hand, had no substitution and, therefore, mercury MACT analysis is not impacted by substitution.

As indicated earlier, substitution for missing feed rate MTECs of individual elements within the LVM and SVM groups was not performed using the average rank based methodology used for emissions but by substituting zero for missing feed rate data. Substitution of zero for feed rate MTECs of LVM and SVM was not considered in the determination of the MACT-defining HW MTECs for these groups. This has the potential impact of decreasing the value of the MACT-defining HW MTEC and, consequently, decreasing the number of facilities in the MACT EU. There was no substitution necessary to obtain TCl feed rate MTECs since trial burns reported feed rates of total chlorine in various feed streams and not individual Cl2

# and HCl feed rates. Therefore, for TCl there is no impact of feed substitution on the TCl MACT analysis.

3.2 NATIONAL EMISSIONS AND COST ESTIMATES

The methodology and procedure for estimating national emissions of HAPs from combustion sources and national cost for meeting the proposed floor and beyond the floor limits are explained in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. The potential impact of emission data substitution on national emissions and cost estimates can be assessed from Table 2-2. This table shows that uncertainty attributable to data substitution may not be significant in general. For example, uncertainty due to substitution for LVM from CKs and INCs, and SVM and TCl from INCs may be up to approximately 10% (based on the average for emissions substitution shown in Table 2-2). Moreover, there is no significant substitution for LVM from LWAKs, and SVM and TCl from CKs and LWAKs.

3.3 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS

The 50th and 90th emission percentile results for metals and other HAPs are

1-3

# provided in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. A brief description of this analysis is also provided in Section 2.3 of this report. The contribution of emission data substitution on the 50th and 90th emission percentiles may be qualitatively assessed from Table 2-1 (ranked according to emissions). This table shows that, in general, the conditions with substituted data occur over a wide range of emissions for most HAPs and, therefore, there is a potential substitution impact on 50th and 90th percentiles. To confirm this and to thoroughly explore the impact of the current average ranking substitution methodology on the 50th and 90th emission percentiles, a comprehensive quantitative assessment was performed using run data to determine 50th and 90th percentiles for all HAPs and source categories based on substituting zero for missing emissions data. This 50th and 90th percentile analysis was also performed assuming log-normal distribution for emissions. The results from this analysis are summarized in Table 3-1. This table shows the substance, combustion source, 50th and 90th percentiles for average ranking substitution, and 50th and 90th percentiles for zero substitution. Results in Table 3-1 indicate:

The 50th and 90th percentiles either remained unchanged or decreased when zero was substituted for missing emission data for all HAPs and source categories. The most significant change occurred for LVM, SVM, and TCl from INCs where the 50th and 90th emission percentiles decreased by approximately 11% and 9%, 19% and 8%, and 12% and 14%, respectively, when the zero substitution methodology was used. There was no significant impact of emission data substitution on determining the 50th and 90th emission percentiles for LVM, SVM, and TCl from CKs and LWAKs.

3.4 EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”)

The methodology, procedure, and results for the “bar charts” are presented in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. A brief description of the “bar charts” analysis is also presented in Section 2.4 of this report. Since the distribution of HAP feed rates in various feed streams was the basis for determining emissions distribution of HAPs, the potential impact of the substitution methodology for feed rate MTECs on the bar

1-4

# charts results have to be assessed. As indicated earlier in this report, zero was substituted for missing feed rate data when calculating LVM and SVM feed rate MTECs, but there was no substitution required to calculate TCl feed rate MTECs since total chlorine measurements were reported in trial burns. Therefore, the zero substitution methodology for missing feed rate data may potentially impact the bar chart results for LVM and SVM only, but not for TCl or mercury. Substituting zero for missing feed rate data may potentially decrease the true feed rate MTECs for LVM and SVM in any given feed stream where they were fed but not measured (or reported) and, consequently, may change the emissions distribution for LVM or SVM.

As an example of this potential impact, suppose that a facility has waste and raw material feed streams and that the four metals in the LVM group were fed and measured in the waste stream, while only two out of the four metals in the LVM group were measured in the raw material feed stream (although the four metals were present). Substitution of zero for the two missing metals feed rates, in this case, will underestimate the true value of the feed rate MTEC for LVM in the raw material feed stream and, consequently, increase the ratio of emissions due to LVM in the waste relative to LVM in the raw material shown in the bar charts (an example bar chart for LVM from CKs is shown in Figure 3-1). On the other hand, if only two metals were measured in the waste and raw material, and if the true feed rate of LVM and the two measured metals are similar for both feed streams, then zero substitution may not have an impact on the emissions distribution.

1-5MEC : Uses MACT, NMEC : Does not use MACTTP : Adjusted based on control technology, MP : Adjusted based on MTEC levelBL : Baseline, ND : Contribution of raw material to feed was below detection levelFigure 3-1. Contribution of feed streams to stack emissions of LVM for cement kilns.Non MACT 

### ND, MEC, 320C1 MEC, 316C2 MEC, 204C1 MEC, 308C1 MEC, 309C1 ND, MEC, 208C1 MEC, 303C3 ND, MEC, 335C1 MEC, 316C1 ND, MEC, 321C1 ND, MEC, 208C2 MEC, 318C2 MEC, 305C3 MEC, 317C1 BL, MEC, 317C3 MEC, 317C2 BL, MEC, 303C1 MEC, 202C2 ND, MEC, 207C2 ND, MEC, 207C1 MEC, 319C1

NMEC-MP, 315C1 NMEC-MP, 315C2 NMEC-MP, 306C1 NMEC-MP, 206C1 NMEC-MP, 205C1 ND, NMEC-MP, 322C1 NMEC-MP, 300C2 ND, NMEC-MP, 302C1 ND, NMEC-T&MP, 203C1 ND, NMEC-T&MP, 200C1 ND, NMEC-T&MP, 403C1 ND, NMEC-T&MP, 201C1 NMEC-T&MP, 305C1 NMEC, 301C2 ND, NMEC-T&MP, 402C1 ND, NMEC-T&MP, 404C1 ND, NMEC-T&MP, 405C1 ND, NMEC-TP, 401C1 NMEC, 401C5 ND, NMEC-T&MP, 406C1 NMEC-MP, 304C1 ND, NMEC-MP, 323C1 NMEC, 402C4010203040506070 

### LVM Emissions (μg/dscm @ 7% O2

### )Raw MaterialFuelWasteSubst FuelMACTTABLE 3-1. 50th AND 90th EMISSION PERCENTILES ASSUMING AVERAGE RANK BASED AND ZERO EMISSION SUBSTITUTIONS (USING ND DATA @FULL DETECTION LIMIT)SubstanceSystem TypeUnitsEmiss Conc (Avg Rank Substitution) Emiss Conc (0-Substitution)50th Percentile 90th Percentile 50th Percentile 90th PercentileLVM CK ug/dscm 7%O228.91 152.91 26.50 149.67LVM INC ug/dscm 7%O263.72 659.97 56.12 598.98LVM LWAKug/dscm 7%O254.51 218.35 54.51 218.35SVM CK ug/dscm 7%O2138.63 1607.98 138.63 1607.98SVM INC ug/dscm 7%O2104.48 2036.09 85.23 1877.00SVM LWAKug/dscm 7%O227.95 621.83 27.95 621.83TCl CK ppmv 7%O211.16 103.12 11.15 103.00TCl INC ppmv 7%O28.06 139.10 7.02 120.92TCl LWAKppmv 7%O2203.06 3369.76 203.06 3369.76

# SECTION 4

METAL AND CHLORINE SPIKING

According to the boiler and industrial furnace (BIF) Rule and the EPA’s Metals Guidance, metals emissions from BIFs and incinerators burning hazardous wastes are required to be tested in trial burns according to three tiers. Tier I assumes all of the metal fed to the incinerator or the BIF is emitted to the atmosphere and does not provide credit for the amount of metal captured in the system (in bottom ash and collected air pollution control equipment ash). For Tier I, a facility can set its feed rate limit for each metal according to the safe emission limits established by the BIF rule or the Metals Guidance which are based on general conservative EPA risk analysis. A facility can also conduct site specific risk assessment and modify the EPA risk limits according to their site. A facility can then choose to comply with adjusted Tier I (or Tier IA) limits to set maximum feed rates.

For metals with desired feed rates higher than EPA’s Tier I or Tier IA limits, a facility has to comply with either Tier II or Tier III. Both of these tiers require a facility to demonstrate that emissions of metals are below established EPA limits by conducting a trial burn and measuring metals emissions at the stack. Additionally, the trial burn must be conducted at maximum desired metals feed rates (which in most cases requires metal spiking) and the system must operate at conditions which maximize metals emissions. Tier II emission limits are based on general conservative EPA risk limits, while Tier III limits are based on site specific risk assessment. Both Tier II and III allow credit for the portion of metals captured in the system.

As indicated above, Tier II and III metals are tested at maximum desired feed rates which are typically achieved by spiking the metals during a trial burn. Under normal operating conditions, however, the feed rates of metals are generally below the spiked feed rates and are often much below them. The analyses performed in this program are based on trial burn data where, particularly for CKs and LWAKs, facilities spiked Tier II and III metals. Thus, the spiking practice may have an impact on the results from the various analyses performed. The average percentage attributable to spiking of HAPs per condition for all source categories is shown in Table 2-1. This

1-1

# table also shows the percentage of each HAP attributable to waste feed. The percentage of spiking for HAPs was obtained from the reports by identifying feed streams where HAPs were spiked and relating that to the total feed rate of each HAP for a given run. This section explores the possible impacts of HAPs spiking on the results from the various analyses performed in this program.

4.1 MACT ANALYSIS

Details of the MACT procedure and analysis for all HAPs and source categories are presented and discussed in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. A brief description of the MACT analysis is also presented in Section 2.1 of this report. The percentage attributable to spiking of HAPs per condition for each source category, shown in Table 2-1, was not considered in the selection of MACT pool facilities nor in the selection of the MACT EU. As Table 2-1 shows, spiking percentages dominate most of the conditions for LVM and SVM from CKs and LWAKs. The information available from reports appear to indicate that LVM and SVM spiking in incinerators was not as significant as for CKs and LWAKs. Additionally, spiking information shows that most of the facilities for all three source categories did not spike Hg or chlorine. For chlorine, since many wastes, particularly liquid wastes, have high chlorine concentrations, there is no reason to spike chlorine.

It is difficult to make a conclusive statement on how spiking may have impacted the MACT results. However, in general, if facilities did not spike metals and chlorine during trial burns, there is a possibility that the MACT pool facilities and corresponding MACT-defining HW MTECs may be different, which consequently may change the definition of MACT, MACT EU facilities, and correspondingly MACT floor levels. Although at first glance one may conclude that the use of data from spiked conditions may result in inflated floor levels (i.e., the use of non-spiked data resulting in lower MACT floor levels), it is difficult to generalize whether the MACT floor level will be higher or lower if non-spiked data were used. This is illustrated in the discussion below where spiking impact on specific HAPs and source category is discussed based on Table 2-1 results.

4.1.1 LVM

Table 2-1 indicates that 54% and 81% of the feed rates in two out of the three MACT pool facilities for LVM from CKs are attributable to spiking, and that mostMACT EU and non-MACT facilities also have high spiking percentages. The nonspiked facilities are not generally the lowest emitting facilities even if their feed rates

1-2

# were low (e.g., the low feed rate baseline 303C1 for LVM from CKs has a higher than median emission level). This uniform distribution of spiking across all stack gas emission levels makes it difficult to conclude how the MACT results would change if facilities did not spike LVM metals. For example, if the MACT analysis were performed with the LVM percentage attributable to spiking removed from both the feed rates and the emissions, both the MACT pool defining facilities and the MACT EU may change. MACT definition may change in two ways: removing spiking from feed rates may reduce the MACT-defining HW MTEC, and removing spiking from emissions may put another technology in the MACT pool. The MACT EU may change similarly: although removing spiking from emissions can only lower emissions from an individual facility, removing spiking from feed rates may include new (possibly higher emitting) facilities, as may include new technologies in the MACT definition.

It is interesting to note that the current highest emitting MACT EU facility for LVM from CKs (319C1, which sets the floor limit) has 0% spiking, which makes it tempting to conclude that spiking does not impact the floor. However, if the MACT analysis were performed again using non-spiked data, there is no guarantee that the same facility (319C1) would remain the determining MACT floor facility. This discussion for LVM from CKs can be generalized to also include LVM from INCs and LWAKs.

4.1.2 SVM

The above discussion for LVM from CKs can be generalized to also include SVM from CKs, INCs, and LWAKs.

4.1.3 Mercury

For CKs, the spiking of Hg occurs significantly (>6% of the total) in only two facilities. These two facilities are not MACT pool facilities (i.e., the MACT pool facilities did not spike Hg) and, thus, the current MACT EU for Hg is based on facilities that did not spike Hg. Therefore, unless the emissions from these two facilities decrease sufficiently to become part of the lowest 6% emitting facilities if the MACT analysis were performed without spiking, the MACT standards for Hg from CKs are not likely to change. A similar conclusion can be drawn for the Hg standards for INCs and LWAKs.

4.1.4 TCl

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# Although, relative to LVM and SVM, not many CK and INC facilities spiked chlorine, the spiked facilities are distributed across all emission levels. Therefore, the possible impacts of considering only non-spiked data on the MACT standards for TCl from CKs and LWAKs are similar to those discussed earlier for LVM and SVM for all source categories. For LWAKs, some of the TCl MACT pool facilities have contributions from spiking while all of the MACT EU and the non-MACT facilities did not spike chlorine. Thus, if only non-spiked feed rates and emissions are to be considered, the technologies will remain the same and the MACT-defining HW MTEC may become lower. The consequence of this scenario is to possibly include fewer MACT EU facilities and, thus, potentially decrease the MACT floor level.

4.2 NATIONAL EMISSIONS AND COST ESTIMATES

The methodology and procedure for estimating national emissions of HAPs from combustion sources and national cost for meeting the proposed floor and beyond the floor limits are explained in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. The potential impact of metals and chlorine spiking on national emissions and cost estimates can be assessed from Table 2-3. This table shows that approximately over 50% of the national emissions estimate for LVM from CKs and SVM from CKs and LWAKs, and approximately 29% for Hg from LWAKs may be attributable to the fact that metals in these groups were spiked during trial burns. Since national emissions are roughly proportional to average emissions, this means that the national emissions estimate for these cases may be an overestimate of emissions under normal operating conditions. Other average spiking percentages in Table 2-3 are lower and range between approximately 5% to 15% for Hg from CKs and INCs, and for LVM and SVM from INCs; and are on the order of 8% for TCl from all source categories.

Since national emissions estimates for HAPs and source categories were used to calculate emission reduction requirements and subsequently to estimate national costs for meeting the proposed standards, similar qualitative conclusions to the above can be drawn regarding the impact of spiking on national cost estimates.

4.3 50th AND 90th EMISSION PERCENTILES USED FOR RISK ANALYSIS

The 50th and 90th emission percentile results for metals and other HAPs are provided in the Technical Support Document for HWC MACT Standards, Volume V: Engineering Costs. A brief description of this analysis is also provided in Section 2.3

1-4

# of this report. Based on the distribution of spiking percentages and their magnitudes, as shown in Table 2-1, for Hg and TCl from all source categories, and possibly for LVM and SVM from INCs, the changes in the 50th and 90th emission percentiles due to considering only non-spiked feed rates and emissions is likely to be insignificant. However, it is very likely that the 50th / 90th emission percentiles for LVM and SVM from CKs and LWAKs may be different if only non-spiked feed rates and emissions were considered in the analysis.

4.4 EMISSION DISTRIBUTION BASED ON WASTE, FUEL, AND RAW MATERIAL FEED (“BAR CHARTS”)

The methodology, procedure, and results for the “bar charts” are presented in the Technical Support Document for HWC MACT Standards, Volume III: Selection of MACT Standards and Technologies. Additionally, the “bar charts” procedure was summarized and examples were shown in Section 2.4 and 3.4 of this report. The contribution of hazardous waste feed for these bar charts included the contribution of both the HAP feed in the waste and in the spike streams. Therefore, the obvious conclusion is that the ratio of emissions due to hazardous waste feed relative to emissions attributable to other feed streams for conditions with considerable contribution of spiking may be an overestimate of the ratio under normal operating conditions. As shown in Table 2-1, results for LVM and SVM from CKs and LWAKs will be impacted the most, while the impact on the results for Hg and TCl from all source categories, and possibly for LVM and SVM from INCs, may be minor.

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# SECTION 5

SUPPORT FOR SELECTION OF METALS VOLATILITY GROUPS

Analyses of metals data for the various tasks of the program were performed for three major groups of metals which represent the toxic metals of concern. These are the low-volatility metals (LVM) group including Sb, As, Be, and Cr; the semi-volatility metals (SVM) group encompassing Cd and Pb; and the high-volatility metals group represented by Hg. These groups were segregated by volatility behavior such that metals within each group have similar volatilities. These metals volatility groupings chosen for the proposed rule were primarily based on metals partitioning and enrichment data from cement kilns as well as on metals penetration ranking from all combustion systems as will be discussed later in this section.

The list of hazardous constituents under the Resource Conservation and Recovery Act (RCRA), Appendix VIII of §261, includes 12 metals of concern (Sb, As, Be, Cd, Cr, Pb, Hg, Ni, Se, Ag, Tl, and Ba) while the list in Section 112(b) of the Clean Air Act Amendment of 1990 (CAAA) includes 11 metals of concern (Sb, As, Be, Cd, Cr, Pb, Hg, Ni, Se, Co, and Mn). Between these two hazardous constituents lists, there are a total of 14 toxic metals that are classified to potentially pose a hazard to human health. The rationale for choosing only 7 out of 14 metals for the proposed rule (Sb, As, Be, Cd, Cr, Pb, and Hg) is based upon two points: first, these metals are common to both RCRA and CAAA lists and, second, they have sufficient data from trial burns for MACT and other analyses to be performed. Therefore, the reasons for not including the other 7 metals are:

Ba, Ag, and Tl are RCRA metals but are not on the CAAA HAPs list, Co and Mn are CAAA metals but are not RCRA metals, and although Se and Ni are common to both RCRA and CAAA HAPs lists, they do not have enough data from trial burns to perform the various analyses of this

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# program.

Factors associated with not including some of the above metals in either the RCRA or CAAA lists include lack of health and toxicity data, lack of risk data, or lack of emissions data.

Choosing the number of volatility groups and the metals to include in each group may depend on the availability of metals measured data, the type of combustion systems tested, and the judgment of the researcher. For example, the European Union has established three groupings to control metals emissions from hazardous waste incineration units. One group includes only Hg, a second group consists of Cd and Tl, and the third group includes Sb, As, Cr, Co, Cu, Pb, Mn, Ni, Sn, and V. Comparing the European metals groupings to the 7 metals groupings for the proposed rule indicates that including Pb with low volatility metals in the European groupings is different from including Pb in the LVM group in the proposed rule. Additionally, Be is not grouped at all in the European rules while it is included in the LVM group in the proposed rule.

If the other 7 non-grouped metals (Se, Tl, Ag, Ba, Ni, Mn, and Co) were to be included in the three volatility groupings of the proposed rule, these metals (based on the data presented in Sections 5.1 and 5.2 below) would most likely fit in the three groups as follows:

Se would be grouped with Hg in the high volatility metals group, Tl would be grouped with Cd and Pb in the SVM group, and Ag, Ba, Ni, Mn, and Co would be grouped with Sb, As, Be, and Cr in the LVM group.
Note that including Mn and Co in the LVM group was not based on information from trial burns since these metals were not measured during these tests, but was based on theoretical predicted volatility. Also note that the above locations of the non-grouped metals are similar to their locations in the European groupings; i.e., the European groupings include Tl with the semi-volatile metals and include Co, Mn, and Ni in the low-volatility metals group.

The remainder of this section contains three subsections. The first two present support for selection of the proposed rule volatility groupings based on metals partitioning and enrichment analyses performed on CKs trial burn data as well as on metals penetration ranking analysis performed on data from all combustion devices. The third and last subsection presents average and median contributions of elements

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# to emissions and feed rates of LVM, SVM, and TCl based on the analysis performed on data from all source categories.

5.1 METALS PARTITIONING AND ENRICHMENT

Metals cannot be destroyed in a combustion system. Thus, they must exit the system by any of several pathways including the bottom ash (or clinker), collected air pollution control device (APCD) particulate matter, or stack emissions. In the combustion process, metals are subjected to high temperatures where, depending on the thermodynamic properties of the metals and on the local conditions, a portion of the metals may react and/or vaporize. They may also partition to the gas phase by solid particulate entrainment. Metals which partition to the gas by entrainment are typically relatively large (above 1 μm in diameter) and are effectively removed in most particulate control devices. Metals which vaporize are swept away with the combustion gas and, as the gas cools, they tend to condense and/or nucleate to form very fine (below 1 μm in diameter) particles which are in the size range that is least effectively removed in most particulate control devices. Thus, metals with similar volatility should behave similarly in an air pollution control system.

Based on the above discussion, partitioning of metals within a combustion system can be a primary indicator of metals volatility. The metals volatility groupings chosen for the proposed rule were primarily based on partitioning data from cement kilns as shown in Figure 5-1. They include:

Highly-volatile metals including mercury (Hg) which partition substantially to the stack and require adsorption or absorption flue gas cleaning devices, Semi-volatile metals including cadmium (Cd) and lead (Pb) which partition primarily to particulate matter (PM) captured in a PM control device which can effectively remove fine particulate matter, and Low-volatile metals including antimony (Sb), arsenic (As), beryllium (Be), and chromium (Cr) which partition primarily to the clinker (or bottom ash in an incinerator) and are controllable by a wide variety of PM control devices.

The partitioning analysis was limited to cement kilns because trial burn concentration measurements of metals from various feed and exit streams were not sufficiently available from other combustion systems (such as incinerators and LWAKs) to perform similar metals partitioning analysis. For the partitioning analysis, data which were reported below detection limits in CK trial burns were considered at full detection limit in all feed and exit streams.

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# Metals enrichment in a combustion system is another primary indicator of metals volatility during combustion of hazardous wastes. Metals enrichment is defined here as the ratio of metals concentration in the collected APCD ash (or dust in cement kilns) to the concentration of the same metals in the clinker (or the bottom ash for incinerators). Therefore, the calculation of metals enrichment requires measurements of metals in both the collected ash and the clinker (or bottom ash). Such information was only available from cement kilns and, therefore, the enrichment analysis of metals was also limited to cement kilns. This enrichment analysis was performed only using detected data (i.e., ND reported data were eliminated from the enrichment analysis).

Table 5-1 shows the average, maximum, and minimum metals enrichment results for each condition for cement kilns ranked from low to high according to average enrichments. Additionally, Table 5-2 summarizes the average and median enrichment of all measured conditions for each metal. The metals enrichment results in Table 5-2 are ranked by median enrichment and show that the median enrichments for Cr, Be, Sb, and As are on the order of one, while for Cd and Pb are on the order of 100. It is expected that low-volatile metals do not vaporize significantly during combustion and that their emissions and collected APCD ash/dust are primarily due to entrainment of particulate matter and, therefore, their concentrations in the clinker and the APCD dust should be similar. Consequently, their enrichment should be on the order of one. This is clearly illustrated in Table 5-2 supporting the selection of these four metals in the LVM group. In contrast, when a metal completely vaporizes in the combustion zone, it is expected that its concentration in the clinker would be depleted and its concentration in the collected ash would be enriched. This is also clearly illustrated in Table 5-2 for Cd and Pb which have enrichment factors on the order of 100, thus supporting their classification as semi-volatile metals (metals which vaporize during combustion but condense/nucleate entirely prior to the APCD).

Highly volatile metals are expected to vaporize completely in the combustion zone and remain mainly in the vapor phase even at the inlet to the particulate APCD. Therefore, in the absence of a vapor phase metal scrubbing APCD, highly volatile metals are emitted primarily as vapors; and the enrichment (as defined in this report) of these metals will not be high since the collected ash will not have significant concentration of these metals. This is the case for Hg which shows a median enrichment of 5 because it is mainly in the vapor phase as it passes the APCD and is emitted primarily in the vapor phase (see partitioning of Hg in Figure 5-1).

5.2 METALS PENETRATION RANKING

Although the selection of metals volatility groupings was based primarily on

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# partitioning and enrichment data from cement kilns, the above metals volatility groupings are justified for use on other hazardous waste combustors (HWCs) based on the analysis presented in Table 5-3 where emissions from each run from all types of devices were ranked according to penetration (1 - system removal efficiency -- SRE) and the rankings were averaged to develop a composite ranking of the relative penetrations (or inverse SREs) of metals. Note that this ranking corresponds exactly with the metals volatility groupings in that:

Hg, the high volatility metal, has the highest penetration; followed by Cd, (Tl - not grouped), and Pb, the semi-volatile metals; followed by Sb, (Ag and Ba - not grouped), Cr, As and Be, the low volatility metals.

In conclusion, based on metals partitioning and enrichment results from cement kilns as well as on metals penetration ranking from all combustion sources, it is clear that the choice of metals selection for the three metals volatility groupings presented in this report is reasonable, particularly for cement kilns. For low combustion temperature INCs and LWAKs, however, the line between SVM and LVM may be drawn differently than for higher temperature CKs. For example, the European rulesfor incinerators, discussed earlier, consider Pb a low-volatile metal instead of a semivolatile metal. This may be due to reduced Pb volatility during lower incineration temperatures.

5.3 CONTRIBUTION OF ELEMENTS TO EMISSIONS AND FEED RATES OF LVM, SVM, AND TCl GROUPS

Once the metals and chlorine groupings were established, the emissions and feed rates for the LVM, SVM, and TCl groups were calculated for each run based on emissions and feed rates of the various elements in each group. As discussed in earlier sections, LVM and SVM emissions were calculated by simply adding the contributions of the elements within each group. When emissions data were not available for any element within a group, average ranking based substitution was performed (as discussed in Section 3 of this report). LVM and SVM feed rates for each run were also calculated by adding the contributions of elements within each group, but when feed rate data were missing, zero was substituted. For TCl emissions, the same ranking based substitution methodology was used, but the TCl emission per run was calculated as the sum of HCl emission and twice the reported Cl2

# emission to obtain an emission concentration corresponding to total chloride (Cl) concentration. Feed rate substitution was not necessary to obtain TCl feed rates since total chlorine feed rates were reported in trial burns.

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# Based on the above groupings, the contribution of each element to emissions and feed rates of LVM, SVM, and TCl was calculated for each run and then averaged per condition for all source categories. The average and median contributions to emissions and feed rates based on all conditions were then calculated for all groups and source categories and are summarized in Tables 5-4 and 5-5, respectively. For each group and source category, Table 5-4 shows the average and median emissions of the group and also the average and median percentage contributions of the various elements to the emission of the group. Similarly, Table 5-5 shows the average and median feed rates of each group and the average and median percentage contributions of the various elements to the feed rate of the group. Table 5-4 indicates that:

Cr dominates the contribution to the LVM group emissions for all source categories (above 50% on average); Pb dominates the contribution to the SVM group (on average, above 80% for CKs and INCs, and 64% for LWAKs); and HCl dominates the contribution to the TCl group for all source categories (above 80% on average). Sb has a significant contribution to the LVM group emissions for all source categories (approximately 30% on average). Cd has a significant contribution to the SVM group emissions for LWAKs (36% on average).

Table 5-5 indicates that Cr also dominates the contribution to the LVM group feed rates for all source categories (above 50% on average), but the contribution of Sb to feed rates of the LVM group is not as significant (ranges between 8 % to 22% for all source categories) as its 30% average contribution to the LVM group emissions for all source categories. Similarly Table 5-5 shows that Pb is the dominant contributor to the SVM group feed rates (above 70% on average for all source categories), but Cd is not a significant contributor to the SVM group feed rates for LWAKs (only 9% on average) in comparison to its 36% average contribution to the SVM group emissions.

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### Hg Tl Cd Pb Sb Be As Ag Cr Ba 0 10 20 30 40 50 60 70 80 90 100Metals Partitioning (%) 

### Clinker Collected Ash Stack

Figure 5-1. Metals partitioning in cement kilns burning hazardous wastes. Volatility Ranking Low High

## TABLE 5-1. ENRICHMENT (CONCENTRATION RATIO OF FF/ESP ASH TO CLINKER) OF METALS IN CEMENT KILNS (DETECTED DATA ONLY)

Substance Cond ID Avg Enrichment Max Enrichment Min Enrichment Antimony 402C4 0.73 1.00 0.40 Antimony 315C1 0.78 0.81 0.73 Antimony 315C2 0.83 0.98 0.54 Antimony 319C1 0.91 0.91 0.91 Antimony 315C3 0.93 1.03 0.85 Antimony 205C1 1.00 1.06 0.97 Antimony 304C1 1.05 1.05 1.05 Antimony 206C1 1.10 1.34 0.84 Antimony 303C3 1.50 1.96 1.20 Antimony 403C1 1.50 1.50 1.50 Antimony 401C1 2.09 2.09 2.09 Antimony 300C2 8.23 16.34 3.81

Arsenic 300C2 0.44 0.62 0.28 Arsenic 303C3 0.61 0.66 0.58 Arsenic 304C1 0.81 0.81 0.81 Arsenic 402C1 0.83 1.00 0.64 Arsenic 303C1 0.88 1.08 0.60 Arsenic 205C1 0.93 1.01 0.86 Arsenic 402C4 1.00 1.14 0.85 Arsenic 315C3 1.10 1.14 1.03 Arsenic 315C1 1.15 1.23 1.09 Arsenic 401C5 1.19 1.53 0.99 Arsenic 315C2 1.21 1.49 0.96 Arsenic 319C1 1.21 1.21 1.21 Arsenic 306C1 1.23 1.67 0.94 Arsenic 206C1 1.40 1.50 1.31 Arsenic 403C1 1.49 1.60 1.25 Arsenic 405C1 1.69 2.45 1.43 Arsenic 404C1 1.78 2.11 1.25 Arsenic 406C1 3.26 3.26 3.26 Barium 401C1 0.51 0.66 0.36 Barium 304C1 0.56 0.56 0.56 Barium 401C5 0.60 0.72 0.53 Barium 303C1 0.67 0.77 0.62 Barium 402C1 0.68 0.86 0.59 Barium 319C1 0.68 0.68 0.68 Barium 402C4 0.73 0.82 0.67 Barium 303C3 0.73 0.80 0.62 Barium 406C1 0.74 0.89 0.65 Barium 300C2 0.79 1.04 0.41 Barium 315C1 0.80 0.82 0.76 Barium 315C2 0.81 0.85 0.79 Barium 315C3 0.82 0.83 0.81 Barium 206C1 0.96 1.09 0.74 Barium 306C1 1.10 1.19 1.00

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## TABLE 5-1. ENRICHMENT (CONCENTRATION RATIO OF FF/ESP ASH TO CLINKER) OF METALS IN CEMENT KILNS (DETECTED DATA ONLY)

Substance Cond ID Avg Enrichment Max Enrichment Min Enrichment

Barium 405C1 1.12 1.24 1.09 Barium 205C1 1.29 1.44 1.20 Barium 404C1 1.46 2.45 0.73 Barium 403C1 1.67 2.15 1.37 Beryllium 306C1 0.22 0.25 0.20 Beryllium 304C1 0.45 0.45 0.45 Beryllium 303C3 0.45 0.47 0.43 Beryllium 300C2 0.49 0.61 0.38 Beryllium 315C1 0.64 0.78 0.39 Beryllium 319C1 0.71 0.71 0.71 Beryllium 303C1 0.73 0.92 0.58 Beryllium 402C4 0.79 1.00 0.16 Beryllium 401C1 0.85 1.00 0.71 Beryllium 206C1 0.91 1.08 0.78 Beryllium 205C1 0.94 1.04 0.89 Beryllium 315C3 1.01 1.10 0.90 Beryllium 402C1 1.05 1.67 0.71 Beryllium 315C2 1.12 1.22 1.07 Beryllium 404C1 1.81 3.09 0.57 Beryllium 405C1 2.13 3.00 1.82 Beryllium 403C1 2.76 3.15 2.31 Beryllium 406C1 14.00 14.00 14.00 Cadmium 303C1 1.39 1.94 0.99 Cadmium 300C2 29.79 40.41 15.84 Cadmium 303C3 55.85 57.62 53.46 Cadmium 205C1 98.03 108.92 87.13 Cadmium 306C1 102.00 102.00 102.00 Cadmium 319C1 133.72 133.72 133.72 Cadmium 402C4 916.13 1222.22 342.31 Chromium 300C2 0.28 0.43 0.16 Chromium 303C1 0.31 0.38 0.25 Chromium 403C1 0.36 0.40 0.31 Chromium 401C1 0.38 0.52 0.30 Chromium 401C5 0.39 0.46 0.28 Chromium 306C1 0.43 0.50 0.36 Chromium 404C1 0.47 0.63 0.24 Chromium 402C1 0.53 0.53 0.51 Chromium 402C4 0.53 0.76 0.34 Chromium 304C1 0.58 0.58 0.58 Chromium 303C3 0.62 0.74 0.51 Chromium 206C1 0.70 0.85 0.55 Chromium 319C1 0.74 0.74 0.74 Chromium 406C1 0.78 1.38 0.56 Chromium 315C1 0.84 0.89 0.81 Chromium 315C3 0.85 0.98 0.74

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## TABLE 5-1. ENRICHMENT (CONCENTRATION RATIO OF FF/ESP ASH TO CLINKER) OF METALS IN CEMENT KILNS (DETECTED DATA ONLY)

Substance Cond ID Avg Enrichment Max Enrichment Min Enrichment Chromium 205C1 0.90 1.02 0.80 Chromium 315C2 0.91 0.93 0.88 Chromium 405C1 1.24 1.47 1.07 Lead 303C1 4.99 6.69 3.63 Lead 315C3 15.16 17.21 12.10 Lead 401C1 17.89 29.29 7.74 Lead 303C3 22.72 36.27 14.80 Lead 315C2 22.88 24.31 20.77 Lead 315C1 28.90 37.87 24.29 Lead 406C1 34.00 34.00 34.00 Lead 402C1 72.95 129.41 39.29 Lead 405C1 124.14 165.00 100.00 Lead 319C1 140.24 140.24 140.24 Lead 304C1 201.69 201.69 201.69 Lead 206C1 247.86 313.84 192.47 Lead 402C4 260.59 425.00 91.18 Lead 306C1 302.69 362.96 242.42 Lead 205C1 576.23 756.88 436.92 Lead 300C2 726.91 1101.46 429.60 Lead 401C5 1086.06 1444.44 647.06 Mercury 402C1 0.01 0.01 0.01 Mercury 406C1 5.00 5.00 5.00 Mercury 303C3 5.24 6.28 4.07 Mercury 402C4 8.63 10.50 7.00 Mercury 401C1 11.75 11.75 11.75 Nickel 206C1 0.57 0.72 0.42 Nickel 205C1 0.91 0.96 0.87 Silver 401C1 0.75 0.75 0.75 Silver 402C1 0.85 1.33 0.36 Silver 315C1 1.41 1.70 0.98 Silver 315C2 1.57 1.97 1.24 Silver 205C1 1.77 1.77 1.77 Silver 315C3 1.94 3.09 0.95 Silver 406C1 2.50 2.50 2.50 Silver 319C1 3.59 3.59 3.59 Silver 303C3 4.49 5.44 2.67 Silver 402C4 7.40 14.71 0.33 Silver 303C1 10.87 10.87 10.87 Silver 300C2 31.24 42.53 20.72 Thallium 402C4 1.11 1.33 1.00 Thallium 206C1 1.40 1.40 1.40 Thallium 315C1 1.42 1.42 1.42 Thallium 315C2 3.24 3.24 3.24 Thallium 303C1 129.30 129.30 129.30 Thallium 303C3 219.18 315.54 142.15

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## TABLE 5-2. AVERAGE AND MEDIAN ENRICHMENT FACTORS BASED ON ALL CONDITIONS FOR EACH METAL IN CEMENT KILNS (DETECTED DATA ONLY)

Substance Average Enrichment Median Enrichment

Chromium 0.62 0.58

Nickel 0.74 0.74

Barium 0.88 0.79
Beryllium 1.72 0.88
Antimony 1.72 1.03

Arsenic 1.23 1.17

Silver 5.70 2.22

Thallium 59.28 2.33
Mercury 6.12 5.24

Cadmium 190.99 98.03

Lead 228.58 124.14

5-11TABLE 5-3. PENETRATION RELATIVE RANKING OF METALS FOR ALL COMBUSTION SYSTEMSHg Cd Tl Pb Sb Ag Ba Cr As Be Avg Rank # ComparisonsHg78% 80% 80% 83% 90% 85% 79% 85% 90% 83% 1067Cd22% 52% 61% 61% 66% 68% 68% 75% 87% 62% 1402Tl20% 48% 59% 55% 47% 70% 66% 60% 78% 56% 540Pb20% 39% 41% 50% 61% 65% 63% 64% 84% 54% 1416Sb17% 39% 45% 50% 46% 61% 66% 57% 67% 50% 838Ag10% 34% 53% 39% 54% 56% 55% 54% 74% 48% 571Ba15% 32% 30% 35% 39% 44% 50% 62% 73% 42% 1006Cr21% 32% 34% 37% 34% 45% 50% 56% 54% 40% 1359As15% 25% 40% 36% 43% 46% 38% 44% 47% 37% 1027Be10% 13% 22% 16% 33% 26% 27% 46% 53% 27% 794TABLE 5-4. AVERAGE AND MEDIAN CONTRIBUTIONS OF ELEMENTS TO EMISSIONS OF LVM, SVM, AND TClSystem Type >>Cement Kilns IncineratorsLWA KilnsSubstanceAverageMedianAverageMedianAverageMedian

LVM (ug/dscm @ 7%O 2 ) 64.09 23.47 1853.71 57.73 98.95 59.61Sb (%) 2 9 2 0 3 1 2 1 3 0 1 8As (%) 1 4 9 1 4 9 1 2 1 1Be (%) 3 1 3 1 2 1Cr (%) 5 4 5 7 5 1 5 4 5 6 6 4

SVM (ug/dscm @ 7%O 2 ) 575.78 150.83 1464.26 89.34 293.22 10.23Cd (%) 1 8 1 2 1 7 1 3 3 6 3 1Pb (%) 8 2 8 8 8 3 8 7 6 4 6 9

TCl (ppmv @ 7%O 2 ) 33.27 21.77 59.46 7.36 789.95 853.21HCl (%) 8 9 9 6 8 0 8 8 9 3 9 8Cl (%) 1 1 4 2 0 1 2 7 2TABLE 5-5. AVERAGE AND MEDIAN CONTRIBUTIONS OF METALS TO FEED RATES OF LVM AND SVMSystem Type >>Cement Kilns IncineratorsLWA KilnsSubstanceAverageMedianAverageMedianAverageMedian

LVM Feedrate (lb/hr) 44.93 33.97 6.86 0.28 4.67 4.12Sb (%) 1 4 6 2 2 1 3 8 5As (%) 1 6 1 4 2 0 1 4 2 6 2 4Be (%) 1 1 4 1 3 2Cr (%) 6 9 7 4 5 5 5 7 6 3 5 9

SVM Feedrate (lb/hr) 38.20 27.15 11.66 0.28 14.63 12.50Cd (%) 1 3 8 3 0 1 1 9 8Pb (%) 8 7 9 2 7 0 8 9 9 1 9 2