1 MEMORANDUM

Date: November 2011 To: Brian Shrager, US EPA From: Eastern Research Group, Inc. Subject: Summary of Test Repo rt Data Review from Best Pe rforming Units at Industrial, Commercial, and Institutional Boilers and Pro cess Heaters National Emission Standards for Hazardous Air Pollutants – Major Source This memorandum describes the procedures us ed to review test reports from best performing units in each subcategory for consistency in reporting stack test and laboratory data. The memorandum is organized as follows:

1.0 Introduction 2.0 Particulate Matter Data Review 3.0 Mercury Data Review 4.0 Dioxin/Furan Data Review 5.0 HCl Data Review 6.0 References

Appendix A: Particulate Matter Data Review Appendix B: Mercury Data Review Appendix C: Dioxin/Fu ran Data Review Appendix D: HCl Data Review

1.0 INTRODUCTION With a large pool of emission data and with stack tests performed ove r a period of twenty years a more thorough look at th e data was undertaken. Petitione rs were concerned about the2 quality of the data, specifically that the test s were not always representative of a boiler’s characteristics, that ICR stack test protocol s were not followed, and that a wide range in variability was seen in the boiler data. See the emissions database for all boiler data available. 1 Although some test reports were available to conduc t an audit, they had no t been properly vetted at the time of the March 2011 promulgation for the NESHAP at Industrial, Commercial, and Institutional Boilers and Process Heaters (Boile r MACT). Additionally, after promulgation of the Boiler MACT in March 2011, a nd in support of the reconsider ation, EPA requested industry to submit additional test reports from best pe rformers identified in the March 2011 promulgation in order to conduct a more complete review. The review focused on screening the reports of best performing boilers which were used in MACT floor calculations for the March 2011 promulgation since these reports are the most likel y to have an impact on the emission limits for the reconsiderat ion proposal. For each pollutant, the applicable EPA te st method (e.g. Method 5 or Method 29) was examined and main points from the protocol were se lected to create a review template specific to each. In addition, reports were reviewed at a test run level to ensure each run was properly reported. If revisions were necessary individua l test runs could be updated on a case by case basis. This memorandum discusses the results for PM, mercury, dioxin/furan, and HCl test reports reviews. A related test report review was also performed for CO and is presented in a separate memorandum. 2

2.0 PARTICULATE MA TTER DATA REVIEW Stack test reports for best performing boilers for filterable particulate matter were reviewed for consistency in reporting the measured mass values from the particulate on the filter and in the rinse. According to Method 5 the filterab le particulate matter weight is recorded twice; the mass of particulate matter which is caught in the filter and the mass of the particulate matter which is measured in the rinse. The filter mass and rinse mass are added together to calculate the total mass of particulate matter. When reporting the mass values in the stack test reports which were then used to complete the Boiler survey, however, there were inconsistencies in what was reported. Three major changes were implemented to correct for low PM values:3 1. The total filterable PM mass was adjusted to remove negative filter weights. When reporting data, some facilities reported the filter weight as a negative value and actually subtracted this value from th e rinse weight when providing the total particulate matter. When this occurred, th e filter value was changed to zero and the total particulate matter would then be equal to just the rinse weight. This was done because the vast majority of the PM tests di d not subtract a negative filter weight and this adjustment put all of the review ed test results on the same basis. 2. The total filterable PM mass was adjusted to correct values which were less than 1 mg. In cases where the total PM was reported to be less than 1 mg, this value was adjusted to 1 mg. This is per guidan ce provided in 64 FR 53028 which stated that EPA conducted a systematic laboratory study to define what is the method detection limit (MDL) for Method 5 and determined th e Method to have a calculated MDL of 1 mg. 3. The total filterable PM mass was adjusted for weights reported as “<” an amount which were not included in the total. Fo r example, a report would provide a filter mass of <0.3 mg and rinse ma ss of 4.0 mg, and would then show the total mass as 4.0 mg. In instances where a “<” value wa s reported, the total particulate mass was corrected to include both weight values.

Two additional miscellaneous corrections were also made as a result of the review of the remaining best performing PM tests:

1. The total filterable PM mass was corrected due to an over-subtrac tion of the blank. When determining the rinse weight Met hod 10 allows subtraction of .001% of the mass of the acetone used. Fo r one boiler’s test report, however, when correcting for the acetone too large a value was subtracted from the result which biased it low. In this instance, 3.0 mg was added to the total ma ss to correct. 2. The total filterable PM mass was corrected to adjust for a discrepancy between the summary page and the laboratory data sheets in the report. In this instance the calculated value shown in the laboratory data was used. In addition to correcting data, whether or not a stack test followed Method 10 protocol was determined. Based on this, data from one facility was removed from the PM analysis.4 For each test run that was corrected, we used the sample volume, O 2 concentration in the sample, and the F-factor which we re provided in the test report to update the lb/mmBtu values. For sites where an F-factor was not available we us ed a ratio of the old mg of the PM catch to the corrected PM catch to adjust the old lb/mmBtu value proportionally. In total, there were 147 test reports reviewed for consistency in PM data. Not all best performing boilers had test reports available, bu t a majority of the units were covered. See Appendix A-1 for the PM test report review template with results for all reviewed test reports and Appendix A-2 for results on test reports where PM data was modified or removed.

3.0 MERCURY DATA REVIEW Stack test reports for mercury best performi ng boilers were reviewed for consistency in reporting mercury fractions. According to Me thod 29, five fractions of mercury shall be recorded, and this request was specified in the phase II ICR test program for the Boiler MACT. However, not all laboratories reported each frac tion in the stack test report. When conducting the review, first, the mass of each Hg fraction avai lable in the laboratory section was recorded. The sum of the five fractions from the laborator y section was then compared to the total Hg value provided in the report. If there was a la rge discrepancy between the two values the Hg value was further investigated, otherwise it was determined to be correct. If the Hg fractions were not in agreement one of two actions was taken:

1. The Hg value was revised using the sum of th e five reported fractions, or the sum of the reported fractions and th e detection limits for certain fractions, when appropriate. The Hg values were updated by taking a ratio of the revised computed sum of all five fractions and the reported sum in the test reports, see equation 1. This update was made for 52 test runs at 19 boilers. ܪ݃ ோ௘௩ ൌ ܪ݃ ோ௘௣ כ ு௚ ௙௥௔௖௧௜௢௡ ೃ೐ೡ ு௚ ௙௥௔௖௧௜௢௡ ೃ೐೛ (Equation 1)

Where: Hg Rev = Revised Hg value to be used in floor calculations (lb/mmBtu) Hg Rep = Hg value provided in st ack test report (lb/mmBtu)5 Hg fraction Rev = Sum of five Hg mercury fracti ons from laborator y section review (μg) Hg fraction Rep = Sum of the Hg fractions provi ded in stack test report (μg)

2. Where insufficient laboratory data was av ailable to calculate a sum of all five fractions and it could not be determined if proper Method 29 protocol was followed, the boiler’s Hg data was removed from th e MACT floor rankings. With Method 29 requiring five mercury fractions, in order to create a representative MACT floor it was necessary to ensure five fractions were reported. If data were based on fewer fractions the resultant Hg emissions could be biased low. Mercury data was removed for 38 test runs at 13 boilers. Before revising or removing Hg values, one final check was performed. In some cases, although the laboratory data review indicated that certain mercury data were based on less than five fractions, we did not edit the data because separate notes were provided in ERT or a later data submittal provided explanation or correction of the data that was not reflected in the laboratory section of the test reports. In total, 52 test reports were reviewed for mercury. See Appendix B for the mercury review template with results and the rationale for each mercury data point which was revised or removed.

4.0 DIOXIN/FURAN DATA REVIEW Stack test reports for dioxin/f uran best performing boilers we re reviewed for accuracy of individual congener values and individual congener non-detect flags. According to EPA Method 23, the nanogram (ng) and sample volume in cubic meters (dscm) for each dioxin/furan congener is to be recorded and the corresponding ng/dscm value ca lculated. Each congener also shall be appropriately flagged if data is non-detect . Upon review of the dataset, it was found that several dioxin/furan data were incorrectly reporte d or calculated, so for this review an in depth look at the test report data was conducted. Fo r each report, the individual congener values and non-detect flags were extracted from the laborator y data into a spreadsheet. Then, the nanogram values from the laboratory section of the test report were used to calculate ng/dscm @ 7% O 2 values. The calculated di oxin/furan values were then compared to the values in the database to determine which congeners were incorrect. If there was a large discrepancy between the6 calculated value and the database value then the database value was replaced with the calculated value. In the laboratory section of the test re port, each congener non-detect value flag was also reviewed and compared to the database flag. Wher e differences were present in the database flag and the flag from the review, the database flag was replaced with the flag from the review. Test reports from 18 best performers from the March 2011 promulgation were reviewed for dioxin/furan data. Dioxin/furan congener values were revised for 4 boilers and non-detect flags were updated for 10 boilers. See Appendix C for the dioxin/furan review template with results. Additional review of dioxin/furan congener data we re made as a result of a separate analysis. Those edits are discusse d in another memorandum. 3

5.0 HCL DATA REVIEW Stack test reports for HCl were reviewed for reported mass values, detection limits, and method protocol checks. Based on the test re port review, no major errors were found which would warrant the removal of data although some c oncerns with certain reports were noted in the review. It is noted that alt hough test reports were provided for many of the best performing units for HCl, there was a lack of detailed laboratory da ta available to conduct a complete review of all the details of each test. In one instance (WAGraysHarborPaper, No. 6 Boiler (EU2)), the results were reported separately for two portions of the gas stream and the database was corrected to reflect the total emissions from both the duct and stack portions. One of the tests for FLUSSugarCorp, Boiler No. 4 will be investigated further before promulga tion of the final rule. All of the reviewed HCl data was used for MACT floor cal culations. In total, 65 boilers were reviewed for HCl. See Appendix D for the HCl review template with findings during the review.7 6.0 REFERENCES

1. Emissions Database for Boilers and Proces s Heaters Containing Stack Test, CEM, & Fuel Analysis Date Reported under ICR No. 2286.01 & ICR No. 2286.03 (version 6) 2. Eastern Research Group, Inc.. Incorpor ating Measurement Error in Reported Carbon Monoxide (CO) Data – Updated for Reconsideration Proposal. November 2011. 3. Eastern Research Group, Inc.. Analysis of Dioxin/Furan Data and Minimum Detection Levels from Industrial, Commercial, and Inst itutional Boilers and Pr ocess Heaters National Emission Standards for hazardous Air Pollu tants – Major Sources. November 2011.