
 From:
hec ybanez <hybanez@gmail.com>
 To:
Steve Fruh/RTP/USEPA/US@EPA, Keith Barnett/RTP/USEPA/US@EPA
 Date:
03/22/2010 11:07 AM
 Subject:
hg varability



I have attached an excel file that shows how to incorporate variability of intra-quarry and fossil fuels.  In these spreadsheets I add variances for each not the absolute varability as was used for the "Franken-Limit".  Please email the new UPL equation and any references.
 
if you have any questions please contact me.
 
 
With regard to a 1, 2, 3 floors.  I think we should recalled, when limestone concentration of all 89 kilns is evaluated it clearly shows 3 normally distributed populations.  I understand why EPA does not like the concept of three normally distributed populations and the establishment of three MACT floors.  However, if EPA desires to create two MACT floors to avoid the elimination of the highest emitting plants, EPA would only be sacrificing lower emitting plants for higher emitting plants.  The only viable option is a single floor or three separate floors.
 
Let's consider the following example where the lower MACT floor is 45 lb Hg per Million tons of kiln feed.  Additionally, for each sources we add the intra-quarry variability of 45% RSD to determine the standard deviation encountered within a given quarry and we assume that all the mercury is coming from the limestone.  The table below provides and possible outcome of the two MACT floor.  Plants highlighted in yellow would not meet the lower floor even with a 70% reduction with other no incoming mercury from any other sources other than limestone.
  

                            Random number kiln code
                            lb/MM ton of kiln feed
                   Intra-quarry   Using the 45%  (Stdev)
                    upper  (includes one Stdev from mean)
                        lb/MM ton of kiln feed (Upper)
 
 
 
                                     1609
                                   1.61E+03
                                    725.99
                                    2339.29
                                                                    701.7868966
                               UPPER FLOOR KILNS
                                     1629
                                   9.85E+02
                                    443.37
                                    1428.65
                                                                    428.5941671
                                                                               
                                     1581
                                   1.61E+02
                                     72.33
                                    233.05
                                                                    69.91521772
Even with a 70% Reduction and limestone being the only source of Hg the Kiln is still above the lower floor
                                     1200
                                   1.35E+02
                                     60.53
                                    195.03
                                                                    58.50835326
                                                                               
                                     1218
                                   1.35E+02
                                     60.53
                                    195.03
                                                                    58.50835326
                                                                               
                                     1239
                                   1.04E+02
                                     46.74
                                    150.60
                                                                    45.18138394
                                                                               
                                     1448
                                   9.26E+01
                                     41.67
                                    134.28
                                                                    40.28315897
 
 
 
 
