MEMORANDUM

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

FROM:   Eastern Research Group, Inc.

DATE:    November 2011

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

Revised November 2011

1.0 INTRODUCTION

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

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

November 17, 2010 cutoff for consideration in the promulgation of the March, 2011 Major

Source Boiler and Process Heater NESHAP (76 FR 15608) are discussed in this memorandum.  A

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

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

and New Data in the EPA ICR Databases” in the docket.1 No data corrections or additions

received after November 7, 2011 were processed into the EPA ICR databases in order to finalize

regulatory impacts analyses in the proposed reconsideration of the promulgated rule.

This memorandum is separated into the following sections:

1.0 Introduction

2.0 Summary of Data Corrections and Additions

3.0 Outstanding Data Corrections

4.0 References

Appendix A: Summary of Changes to Dioxin/Furan Emissions Data
Appendix B: New Facilities Identified from ICF Inventory

Appendix C: Summary of Data Corrections and Additions from Reconsideration

Petitions

Appendix D: Units Reclassified as Major Source Boilers from CISWI

Appendix E: Summary of Fuel Analysis Corrections Identified by ORCR

Appendix F: Summary of Late Test Report Request and Review
2.0 SUMMARY OF DATA CORRECTIONS AND ADDITIONS

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

EPA ICR databases since the promulgation of the March, 2011 rule.  The system of change

codes used to flag and denote changes to or additions of data into the EPA ICR databases is

described in the memorandum, “Handling and Process of Corrections and New Data in the EPA

ICR Databases” in the docket.1 Only data corrections or new data received after the November

17, 2010 cutoff for consideration in the promulgated rule are discussed in this section.

2.1 Review of Top Performer Test Reports

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

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

methods used to develop MACT floor emission limits is provided in another memorandum.2

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

particulate matter (PM), hydrogen chloride (HCl), carbon monoxide (CO), and toxic‐equivalent

dioxins/furans (TEQ D/F).  As a result of the test report review, several facilities were found to

have incorrectly calculated and reported emission values.  It was also found that several tests

did not follow the required test method protocol, and should thus be disregarded from future

analyses.  A detailed analysis of the test report review and a summary of the required

corrections to the reported emissions data are provided in another memorandum.3

2.2 Review of Dioxin/Furan Emissions Data Non‐Detect Flags

As a result of the top performer test report review conducted by EPA, it was found that

several of the top performers had not properly flagged test run emission values for specific

dioxin/furan congeners as non‐detect.  The flags for the test data from these top performers

were corrected in the EPA ICR databases.  Corrections to the non‐detect status were required

for seven top performers.  Since there was such a large number of top performers that required

corrections, dioxin/furan emissions for units that were not top performers were investigated.  If

a particular unit’s dioxin/furan test data showed that the majority (greater than 50 percent) of
congener test run values were reported as measured emissions above a detection limit, it was

assumed that it was possible that the facility erroneously misreported non‐detect flags for that

test.  Test reports for all units that reported dioxin/furan emissions data could not be

investigated due to a lack of available time for the analysis.  ERG reviewed test reports for 25

boilers or process heaters that reported dioxin/furan emissions data.  Corrections to the non‐

detect flags were required for 15 of those 25 units.  For one of those 15 units, it was found that

the detection levels for 5 congeners spread across the three test runs were calculated and

reported incorrectly; the correct values were calculated and used to replace the reported

emissions data.  A list of the changes to the dioxin/furan emissions data that resulted from this

analysis can be found in Appendix A.  A summary of the analysis of reported dioxin/furan

emissions data that led to the discovery of misreported non‐detect flags is provided in another

memorandum.4

2.3 Data Requests from Potential New Major Source Facilities

ICF International (ICF) developed an inventory of potential major source facilities with

boilers or process heaters in operation.  This inventory was generated using the EPA ICR

databases from the proposed Major Source Boiler and Process Heater NESHAP (75 FR 32005) as

a starting point and expanded using other sources.  This inventory was submitted to EPA in

early 2011.  A cross‐reference check was done on the ICF inventory and the inventory of major

source boilers and process heaters developed for the promulgated rule in order to identify any

potential major source facilities that were not in the EPA ICR databases.  A total of 94 facilities

were identified in the ICF inventory as potential new facilities for the EPA ICR databases.

In late June of 2011, EPA enacted a request for data from 52 of these 94 facilities with

jurisdiction provided under Section 114 of the Clean Air Act (CAA) where e‐mail contact

information could be identified.  Of these 52 facilities, 31 responded to the EPA data request.  

15 of the 31 facilities that responded identified themselves as an area source of hazardous air

pollutant (HAP) emissions.  Further, three facilities stated that they either had no applicable

combustion sources on‐site, or that all applicable combustion units on‐site had been

permanently decommissioned.  The remaining 14 facilities submitted unit‐level data for all
applicable boilers and process heaters currently in operation.  Six of these 14 facilities

submitted test reports for emissions testing conducted within the past five years; the emissions

data from these reports were entered into the EPA ICR databases.  A summary of facilities

identified from the ICF inventory that responded to the data request can be found in Appendix

B.

One facility (Hillman Power Company, Hillman, MI; Facility ID:  MIHillmanPower) was

determined to be an area source of HAP emissions after the major source inventory was

finalized for the proposed reconsideration of the rule.  This facility appears in the major source

inventory in the EPA ICR databases since time constraints disallowed the facility from being

removed.  However, the test data for this facility were removed from consideration in the

development of MACT floors.2

Given the apparent age of some of the ICF data sources, we plan to remove the 42

facilities where no contact information could be found to confirm the data because it is likely

that these facilities have been shutdown or had a chance in their HAP status.

2.4 Data Attachments with Petitions for Reconsideration

EPA received petitions for reconsideration of the promulgated rule.  Seven of these

petitions contained new data or corrections to existing data in the ICR databases.  Two of the

petitions were submitted by specific facilities and contained new emissions testing data specific

to the facility.  The remaining five petitions with data were submitted by organizations and

contained new data or data corrections for several facilities.  A summary of the data additions

and corrections received in the petitions for reconsideration of the promulgated rule can be

found in Appendix C.

2.5 Classification Changes for Commercial and Industrial Solid Waste Incinerators

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

March, 2011 Emission Guidelines for Commercial and Industrial Solid Waste Incineration Units

(CISWI) (76 FR 15704) in order to determine if any units should be re‐classified as industrial or

commercial boilers or process heaters.  This review showed that 14 units previously classified as
CISWI units should now be classified as major source boilers.  All 14 of these units were

reclassified on the basis of one of the following changes listed below:

1. Anthracite Culm no longer classified as solid waste per the promulgated Identification of

Non‐Hazardous Secondary Materials that are Solid Waste (76 FR 15456).

2. Construction and demolition (C&D) or other biomass waste that is sufficiently processed

prior to combustion is a fuel.

3. Tire derived fuel (TDF) is classified as a fuel regardless of whether or not the metals are

removed from the TDF prior to combustion.

4. Non‐traditional fuels (i.e., sludge) are generated on‐site as process byproducts.

The Biomass Power Association (BPA) reported additional emissions testing data for 8 of

these 14 units.  These additional emissions testing data have been processed in the EPA ICR

databases.  A list of the units previously subject to CISWI that were reclassified as major source

boilers and the reason each unit was reclassified is provided in Appendix D.

2.6 Requests for Corrections to Reported Fuel Analysis Data

The U.S. EPA Office of Resource Conservation and Recovery (ORCR) conducted a cursory

review of reported fuel analysis data in the EPA ICR databases.  Reported data for nine facilities

were determined to be questionable or erroneously reported, and ERG attempted to receive

clarification on the reported data from all nine facilities.  Six of the nine facilities responded and

confirmed that changes were necessary to the reported fuel analysis data.  Since all six of the

facilities which responded confirmed changes were necessary, it was assumed that changes

were also needed for the remaining three facilities that did not respond.  A summary of the

facilities from which clarifications were requested and a summary of the resulting changes to

the reported fuel analysis data are provided in Appendix E.

2.7 Late Test Report Request and Review

Late in the proposed reconsideration timeline, test reports were requested from the

top‐performing 20 percent of each regulated subcategory.  These additional test reports for

units outside the top‐performing 12 percent for each subcategory were requested in order to
improve the universe of available test reports for units in the EPA ICR databases that reported

emissions testing data.  Test reports were not requested for units in the top 20 percent for

which a test report had previously been obtained.  A total of 94 additional test reports were

requested, of which 75 were received.  A list of the additional test reports requested and

whether or not the test report was received is provided in Appendix F.

A portion of the test reports received from units in the solid fuel subcategory were

reviewed for mercury emissions, after identifying some errors in some of the other higher

ranked tests. Time constraints did not allow the test reports for any other subcategory to be

reviewed but these 75 reports will be docketed and available for review in the process of

finalizing this rule.  The test reports were reviewed in order to determine if the stack testing

and sampling procedures appropriately followed method protocol.  Incorrect method protocol

involved the following, among other findings:

 Use of an unauthorized stack testing method;

 Improper impinger setup;

 Failure to analyze samples from all stack sampling fractions by the laboratory; or,

 Assigning a sample mass of zero to any sample fractions found to be non‐detect.

Because this review was conducted late in the proposal timeline, time constraints only

allowed revisions to the development of MACT floors.  Fifteen separate three‐run Hg tests were

found to have failed to use proper method protocol; these tests were removed from

consideration in the MACT floor analysis and flagged as such in the EPA ICR databases.  

However, the time constraints did not allow these tests to be removed from consideration in

the development of baseline emission factors.  The EPA ICR databases have been flagged to

show that the tests were removed from consideration in the development of MACT floors, but

that time constraints did not allow revisions of baseline emission factors.  The development of

MACT floors and baseline emission factors are discussed in other memoranda.2,5 A summary of

the resultant Hg emissions tests flagged as a result of this late test report review is provided in

Appendix F.

2.8 Other Data Corrections and Additions
Data corrections and additions were received after the November 17, 2010 cutoff for

consideration in the promulgation of the March, 2011 Major Source Boiler and Process Heater

NESHAP (76 FR 15608).  A summary of these previously‐outstanding data corrections are

provided in another memorandum1

.  These data corrections and additions have since been

processed in the EPA ICR databases.

3.0 OUTSTANDING DATA CORRECTIONS

November 7, 2011 was used as the cutoff for data submittals to be processed into the

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

are no outstanding data corrections to report. However, although the edits were processed in

the database, not all of the analyses are based on the latest corrections, as noted in Section 2.7.
4.0 REFERENCES

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

Databases.  January 2011.

2. Eastern Research Group, Inc.  Revised MACT Floor Analysis (November 2011) for the

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

Standards for Hazardous Air Pollutants – Major Source.  November 2011.

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

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

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

2011.

4. Eastern Research Group, Inc.  Analysis of Dioxin/Furan Data and Minimum Detection

Levels from Industrial, Commercial, and Institutional Boilers and Process Heaters

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

2011.

5. Eastern Research Group, Inc.  Revised November 2011 Development of Baseline

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

Institutional Facilities.  November 2011.
APPENDIX A

Summary of Changes to Dioxin/Furan Emissions Data

(See Excel Spreadsheet)
APPENDIX B

New Facilities Identified from ICF Inventor

(See Excel Spreadsheet)
APPENDIX C

Summary of Data Corrections and Additions from Reconsideration Petitions

(See Excel Spreadsheet)
APPENDIX D

Units Reclassified as Major Source Boilers from CISWI

(See Excel Spreadsheet)
APPENDIX E

Summary of Fuel Analysis Corrections Identified by ORCR

(See Excel Spreadsheet)
APPENDIX F

Summary of Late Test Report Request and Review

(See Excel Spreadsheet)