HWC
Data
Base
Report
U.
S.
Environmental
Protection
Agency
Office
of
Solid
Waste
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
July
2002
ii
Acknowledgment
This
document
was
prepared
by
EPA's
Office
of
Solid
Waste,
Hazardous
Waste
Minimization
and
Management
Division.
EERGC
Corporation
provided
technical
support
under
EPA
Contract
No.
68­
W­
01­
024.
iii
Contents
Acknowledgment
Acronyms
Tables
1.0
Introduction
2.0
Data
Format
3.0
Data
Summary
Sheets
4.0
Individual
Source
Data
Sheets
4.1
Source
Description
Sheet
4.2
Condition
Description
Sheet
4.3
Emissions
Data
Sheet
4.4
Feedstream
Data
Sheet
4.5
Process
Data
Sheet
4.6
PCDD/
PCDF
Sheet
4.7
Source
Summary
Sheets
Appendices
I
Quality
Assurance
and
Quality
Control
II
Response
to
Comments
on
Phase
II
June
2000
NODA
III
Acronyms
Used
in
Data
Summary
Sheets
iv
Acronyms
APCD
Air
pollution
control
device
APCS
Air
pollution
control
system
BH
Baghouse
BIF
Boiler
and
Industrial
Furnace
CAA
Clean
Air
Act
CO
Carbon
monoxide
CoC
Certification
of
Compliance
D/
F
Polychlorinated
dioxins
and
furans
DRE
Destruction
and
removal
efficiency
ESP
Electrostatic
precipitator
HAF
Halogen
Acid
Furnace
HAP
Hazardous
air
pollutant
HC
Hydrocarbons
HWC
Hazardous
waste
combustor
LVM
Low
volatile
metals
(As,
Cd,
Cr)
MACT
Maximum
achievable
control
technology
MHRA
Maximum
hourly
rolling
average
MTEC
Maximum
theoretical
emissions
concentration
PCDD/
PCDF
Polychlorinated
dioxin
and
furans
PIC
Products
of
incomplete
combustion
PM
Particulate
matter
POHC
Principal
organic
hazardous
constituents
RA
Rolling
average
RCRA
Resource
Conservation
and
Recovery
Act
SVM
Semivolatile
metals
(Pb,
Cd)
v
Tables
1
Phase
I
hazardous
waste
combustor
universe
2
Phase
II
hazardous
waste
combustor
universe
3
Data
Summary
Sheet
organization
1
1.0
Introduction
This
document
describes
the
format
and
content
of
the
data
bases
we
are
using
to
develop
MACT
standards
for
hazardous
waste
combustors:
hazardous
waste
burning
incinerators,
cement
kilns,
lightweight
aggregate
kilns,
industrial
and
commercial/
institutional
boilers
(including
process
heaters
that
meet
the
RCRA
definition
of
boiler),
and
hydrochloric
acid
production
furnaces.
The
MACT
standards
for
hazardous
waste
burning
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
will
replace
the
interim
standards
promulgated
for
these
sources
on
February
13
and
14,
2002
(67
FR
6792
and
67
FR
6968).
We
refer
to
the
standards
for
these
sources
as
"Phase
I"
standards,
and
the
standards
we
are
now
developing
for
these
sources
as
"replacement"
standards.

We
refer
to
the
MACT
standards
we
are
developing
for
hazardous
waste
burning
industrial
and
institutional/
commercial
boilers
and
hydrochloric
acid
production
furnaces
as
"Phase
II"
standards
because
the
MACT
standards
for
these
sources
were
originally
scheduled
to
be
promulgated
after
the
Phase
I
MACT
standards
were
finalized.
We
now
plan
to
promulgate
these
Phase
II
standards
on
the
same
schedule
as
the
replacement
Phase
I
standards.

For
this
rulemaking,
we
have
updated
the
data
bases
we
have
previously
published
for
Phase
I
and
Phase
II
sources.
The
Phase
I
data
base
is
comprised
of
the
data
base
used
to
support
the
current
MACT
standards
plus
additional
data
collected
in
early
2002
in
an
attempt
to
obtain
from
EPA
Regional
Offices
and
particular
States
any
test
reports
(both
new
and
old)
not
currently
in
the
data
base.
The
data
base
has
also
been
screened
to
delete
data
from
sources
no
longer
burning
hazardous
waste.

The
Phase
II
data
base
is
comprised
of
the
data
base
noticed
for
public
comment
on
June
27,
2000
(65
FR
39581).
That
data
base
has
been
revised
to
accommodate
comments
received
on
the
Notice
of
Data
Availability
(NODA)
and
to
delete
data
from
sources
no
longer
burning
hazardous
waste.
Our
response
to
comments
on
that
NODA
are
presented
in
Appendix
II.
Additionally,
we
have
picked
up
a
test
report
on
one
additional
HCl
Production
Furnace
during
the
Phase
I
data
collection
update,
ID
No.
2020,
and
have
added
this
to
the
data
set.
2
2.0
Data
Format
Each
hazardous
waste
combustion
unit
(i.
e.,
source)
is
assigned
a
3
or
4
digit
identification
number
(ID
No.).
Table
1
and
Table
2
list
the
set
of
Phase
I
and
Phase
II
hazardous
waste
combustors,
including
ID
No.,
unit
name,
facility
name,
location,
and
comments
regarding
the
operating
status
of
the
unit.

The
hazardous
waste
combustor
performance
data
are
presented
in
two
forms:
data
summary
sheets
and
individual
source
data
sheets.
The
format
and
contents
of
each
of
these
is
described
in
detail
in
the
following
sections
of
this
document.

The
"Data
Summary
Sheets"
are
a
series
of
36
Excel
(and
Lotus
compatible)
files,
each
containing
data
for
a
specific
HAP
(or
HAP
surrogate)
and
source
category.
See
Table
3
for
the
content,
organization,
and
titles
of
the
data
summary
files.
We
recommend
that
owners
and
operators
use
the
data
summary
sheets
as
a
starting
point
for
data
review
and
comment,
as
they
present
a
simple
summary
and
characterization
of
all
test
conditions
for
each
HAP
(except
for
CO/
HC
and
DRE)
and
source
category
combination.

The
"Individual
Source
Data
Sheets"
provide
detailed
supporting
data
and
calculations
used
to
develop
the
data
summary
sheets.
These
data
are
contained
in
an
Excel
workbook
for
each
source.
The
workbook
is
comprised
of
a
number
of
worksheets
as
discussed
below.
1
Although
we
intend
to
establish
MACT
standards
for
CO/
HC
and
DRE,
we
have
not
developed
data
summary
sheets
for
those
parameters.

2
Boilers
are
subdivided
into
Coal­
Fired
Boilers
and
Liquid
Fuel
Boilers.

3
3.0
Data
Summary
Sheets
The
data
summary
sheets
comprise
a
set
of
36
Excel
(and
Lotus
compatible)
spreadsheets.
Each
spreadsheet
contains
a
summary
of
data
for
each
different
HAP
(or
HAP
surrogate)
and
source
category.
There
are
individual
data
sheets,
grouped
separately,
for
6
HAPs
(PM,
PCDD/
PCDF,
Hg,
SVM,
LVM,
and
HCl/
Cl2),
1
and
for
each
of
the
6
source
categories
(incinerators,
cement
kilns,
lightweight
aggregate
kilns,
coal­
fired
boilers,
liquid
fuel
boilers,
and
HCl
production
furnaces).
2
See
Table
3
for
a
list
of
the
file
names
and
contents.
For
example,
the
summary
data
sheet
named
"inc_
svm.
xls"
contains
all
semi­
volatile
metals
data
from
incinerators;
sheet
"lwak_
hg.
xls"
contains
all
mercury
data
from
lightweight
aggregate
kilns;
etc.

The
spreadsheets
all
have
the
same
general
arrangement
and
format.
Each
row
contains
information
related
to
a
specific
test
condition.
Test
conditions
are
grouped
together
for
each
source,
and
within
each
source
are
ordered
by
date,
starting
at
the
top
with
the
most
recent.

For
each
test
condition,
information
includes,
moving
across
columns
from
left
to
right:


Source
ID
and
condition
ID
number
­­
First
3
or
4
numbers
represent
the
HWC
unit
number,
and
the
following
identifies
the
test
condition
number
(e.
g.,
C1,
C2).


Facility
name

Facility
location

Test
condition
date

APCS
–
Air
pollution
control
system,
acronyms
defined
in
Appendix
III.


Comment
field
­­
Various
notes
and
acronyms
which
refer
to
special
considerations
for
the
specific
test
condition.


Condition
description
­­
Description
of
the
purpose
of
the
test
condition.


Stack
gas
emissions
data
­­
Individual
run
values,
condition
average,
and
non­
detect
status.
3
All
analytes
in
feedstreams
or
emissions
reported
as
not
detected
are
presented
in
the
data
summary
sheets
at
½
the
reported
detection
limit.

4
A
compliance
test
is
either
a
Certification
of
Compliance
(CoC)
test
or
a
Trial
Burn
(TB)
test.

5
A
risk
burn
is
an
emissions
test
used
to
conduct
a
site­
specific
risk
assessment.
Risk
burns
are
often
conducted
under
normal
operating
conditions.

6
For
example,
munitions
furnaces
often
conducted
a
series
of
trial
burns
over
a
period
of
years
to
identify
operating
conditions
specific
to
the
types
of
waste
munitions
that
were
generated
and
needed
to
be
incinerated.
We
classified
all
of
those
trial
burns
under
the
same
campaign,
and
identified
the
worst­
case
emissions
data
for
each
pollutant
from
among
all
of
those
tests.
This
is
appropriate
because
the
waste
munitions
with
the
worst­
case
emissions
may
require
incineration
in
the
future,
and
the
emissions
from
those
munitions
are
representative
of
emissions
the
source
may
emit.

4

Feed
rate
data
­­
Shown
for
ash
(except
for
kilns),
chlorine,
and
metals.
Expressed
as
feedrate
MTECs,
as
described
in
Section
4,
showing
condition
averages
for
contributions
from
hazardous
waste,
spikes,
and
other
feedrates.
Total
feedrates
for
individual
runs
are
also
provided
as
well
as
an
indication
of
values
reported
as
not
detected
(ND).
3

SRE
­­
System
removal
efficiency,
calculated
from
the
feedrate
MTECs
and
stack
gas
emissions.


Test
Type
­­
Various
identifiers
are
used
to
identify
the
purpose
of
testing,
including:
compliance
testing
(CT)
4
,
risk
burn
(RB)
5
,
normal
operating
conditions
(N),
annual
/
biannual
performance
testing
(ann
PT,
biann
PT),
baseline
no
waste
testing
(B),
research
testing
(RT),
evaluation
testing
(Eval),
mini­
burn
testing
(MB).


Campaign
­­
The
Phase
I
data
base
includes
data
from
old
and
new
emissions
tests.
Often,
sources
conducted
a
series
of
tests
under
the
same
testing
"campaign".
Such
tests
are
numbered
and
grouped
together
for
purposes
of
classifying
each
test
as
Worst­
Case
Vs
Normal,
as
discussed
below.
Where
we
determined,
however,
that
a
source
conducted
tests
under
different
modes
of
operations
but
at
different
times
6
,
we
also
classified
those
tests
under
the
same
campaign.
This
is
appropriate
because
such
tests
do
not
supersede
previous
compliance
test
operating
results,
but
rather
provide
additional
operating
flexibility
by
defining
operating
limits
for
specific,
alternative
operating
modes
(e.
g.,
waste
types).
7
That
is,
for
Phase
I
sources
where
the
data
base
is
comprised
of
old
and
new
data.
The
Phase
II
data
base
is
comprised
only
of
the
most
recent
compliance
test
data.
Because
the
Phase
II
data
are
all
from
the
most
recent
campaign
available
to
us,
we
have
not
classified
the
Phase
II
data
by
campaign.

8
For
PM,
the
definition
of
worst­
case
is
more
inclusive.
If
there
is
only
one
test
condition
in
the
test
campaign
that
the
test
report
refers
to
as
a
trial
burn
or
certification
of
compliance
test,
we
assume
that
test
condition
represents
worst­
case
PM
emissions
(unless
the
test
report
explicitly
states
otherwise)
even
if
the
test
report
does
not
explicitly
indicate
that
ash
was
spiked
or
the
APCS
was
detuned
during
the
test.
This
interpretation
is
appropriate
because
a
source
must
document
compliance
with
the
PM
standard
by
emissions
testing.
Sources
do
not
have
the
option
of
complying
with
an
ash
feedrate
option
(such
as
the
Tier
I
feedrate
limits
for
metals
and
chlorine)
in
lieu
of
emissions
testing.
If
there
is
more
than
one
test
in
the
test
campaign
that
the
test
report
refers
to
as
a
trial
burn
or
certification
of
compliance
test,
we
assume
that
the
test
condition
with
the
highest
PM
emissions
represents
worst­
case
(unless
the
test
report
explicitly
states
otherwise),
even
if
the
test
report
does
not
explicitly
indicate
that
ash
was
spiked
during
the
test.

9
USEPA,
"Guidance
on
Metals
and
Hydrogen
Chloride
Controls
for
Hazardous
Waste
Incinerators",
December
29,
1988
(Volume
IV
of
the
Hazardous
Waste
Incineration
Guidance
Series).

5

Worst
Case
Vs
Normal
­­
Various
identifiers
used
to
classify
emissions
for
each
test
condition
for
each
pollutant
within
a
test
campaign
7
for
purposes
of
assessing
emissions
variability.
These
include:

­
N
(normal)
­­
Test
condition
is
run
under
conditions
which
are
most
representative
of
normal
operations
for
the
HAP
in
question.
For
example,
the
HAP
is
not
intentionally
spiked,
operating
limits
are
not
being
determined
for
the
HAP
during
the
test
condition,
the
waste
feed
composition
and
other
process
operating
conditions
reflect
normal
operations.

­
WC
(worst
case)
­­
Test
condition
within
each
test
campaign
with
the
highest
emissions
of
the
pollutant
and
where
the
test
condition
meets
any
of
these
criteria:
8
(1)
a
test
condition
where
the
feedrate
of
the
pollutant
(i.
e.,
metal,
chlorine,
or
ash)
is
maximized
by
spiking
or
other
means
(e.
g.,
feeding
waste
with
atypically
high
concentrations
of
the
pollutant)
or
where
the
emission
control
device
is
detuned;
or
(2)
a
test
condition
that
a
boiler
or
industrial
furnace
used
to
demonstrate
compliance
under
Tier
III
of
the
BIF
rule
for
the
pollutant,
or
that
an
incinerator
used
to
comply
with
Tier
III
of
the
risk
assessment
guidance
9
;
or
(3)
a
normal
or
"in
between"
test
condition
with
higher
emissions
than
a
test
condition
that
otherwise
would
have
been
classified
as
worst
case.
Test
conditions
meeting
10
For
example,
in
some
cases
lead
emissions
reflected
non­
spiked
normal
conditions,
and
cadmium
emissions
reflected
worst
case
spiked
emissions.
Note
that
we
classified
LVM
data
as
worst
case
when
beryllium
was
the
only
LVM
metal
that
reflected
normal
emissions
(and
where
arsenic
and
chromium
reflected
worst
case).
This
is
because
beryllium
emissions
are
virtually
always
substantially
lower
than
either
arsenic
or
chromium
emissions,
and
thus,
do
not
contribute
substantially
to
LVM
emissions.

11
An
emission
control
system
comprised
of
an
initial
wet
control
device
followed
by
an
ESP
or
BH
would
qualify
as
a
wet
system.
The
initial
wet
device
would
quench
the
gas
temperature
to
minimize
D/
F
formation.
Conversely,
an
emission
control
system
comprised
of
an
initial
dry
control
device
followed
by
a
wet
device
(e.
g.,
for
HCl
control)
would
not
be
classified
as
a
wet
APCS
for
purposes
of
this
subcategorization.
D/
F
may
be
formed
in
the
dry
control
device
before
the
temperature
of
the
gas
is
quenched
in
the
wet
device
below
the
optimum
range
for
D/
F
formation.

6
the
third
criterion
are
classified
WC
HE
(i.
e.,
worst­
case,
highest
emissions)
to
clarify
that
the
test
condition
is
worst­
case
because
it
has
the
highest
emissions
for
the
test
campaign
for
the
pollutant
even
though
its
operating
conditions
would
not
have
suggested
that
emissions
would
be
worst­
case.

­
IB
(In­
between)
­­
The
test
condition
would
have
met
the
definition
of
worst
case
except
that
there
was
another
condition
with
higher
emissions.
Test
conditions
are
also
classified
as
IB
if
the
SVM
and
LVM
emissions
represented
a
mixture
of
worst
case
and
normal
emissions.
10
­
U
(unknown)
­­
Available
information
is
insufficient
to
determine
if
the
test
condition
is
normal,
worst­
case,
or
in­
between.
We
provide
a
comment
for
each
U
classification
under
the
Worst
Case
Vs
Normal
column
indicating
the
information
needed
to
classify
the
test
condition.
We
encourage
owners
and
operators
to
provide
information
and
documentation
so
that
the
test
condition
can
be
properly
classified.

­
NA
(not
applicable)
­­
It
is
not
appropriate
to
classify
the
test
condition
for
the
pollutant
as
worst­
case
vs
normal.
We
provide
a
comment
for
each
NA
classification
indicating
the
reason
for
the
classification.
Reasons
include:

­­
D/
F
for
sources
with
wet
or
no
APCS
11
:
We
cannot
objectively
define
worst­
case
operating
conditions
because
all
hazardous
waste
combustors
are
required
to
operate
under
good
combustion
conditions
which
will
control
combustion­
generated
D/
F
formation,
and
D/
F
formation
in
the
emission
control
device
is
precluded
because:
1)
APCS
temperature
is
inherently
controlled
in
wet
systems;
and
2)
particulate
matter
is
7
continuously
flushed
from
a
wet
control
device
rather
than
being
held
on
a
surface
(e.
g.,
of
an
ESP
plate
or
BH
bag)
where
particle
surface
reactions
can
form
D/
F.

­­
D/
F
for
coal­
fired
boilers:
All
hazardous
waste
coal­
fired
boilers
are
equipped
with
an
ESP
or
BH.
We
cannot
objectively
define
worst­
case
operating
conditions
because
factors
(e.
g.,
sulfur
in
the
coal)
other
than
gas
temperature
at
the
inlet
to
the
ESP
or
BH
appear
to
have
the
dominant
effect
on
D/
F
emissions.

­­
Tests
conducted
prior
to
modifications
of
the
combustion
system
and/
or
APCS
retrofits.
Emissions
data
prior
to
these
changes
may
not
be
representative
of
current
operations.

­­
Miniburns,
research
tests,
demonstration
tests:
These
types
of
tests
are
generally
used
to
determine
emissions
under
modes
of
operation
that
are
not
representative
of
current
operations.
Thus,
emissions
during
these
tests
are
not
likely
to
be
worst­
case
or
normal.

­­
Baseline
tests:
Emissions
when
not
burning
hazardous
waste
are
not
relevant
to
establishing
a
MACT
standard
for
hazardous
waste
combustors.

­­
Tests
where
not
all
metals
in
the
SVM
or
LVM
group
were
measured:
SVM
and
LVM
emissions
cannot
be
classified
as
worst­
case
or
normal
if
emissions
data
are
not
available
from
the
test
for
both
lead
and
cadmium
for
SVM,
and
for
arsenic,
beryllium,
and
chromium
for
LVM.
Note
that,
for
some
source
categories
where
there
are
substantial
emissions
data
for
only
lead
or
only
chromium
during
a
test
condition,
we
classified
the
leadonly
or
chromium­
only
data
by
worst­
case
vs
normal.
Note
that
we
did
not
apply
the
NA
classification
to
LVM
emissions
data
if
only
beryllium
emissions
data
were
missing.
This
is
because
beryllium
emissions
are
virtually
always
substantially
lower
than
either
arsenic
or
chromium
emissions,
and
thus,
do
not
contribute
substantially
to
LVM
emissions.

­­
PM
run
exceeding
the
RCRA
emission
standard:
If
a
PM
run
failed
the
0.08
gr/
dscf
RCRA
standard,
the
test
failed
to
demonstrate
compliance
with
the
RCRA
standards.
Thus,
the
test
could
not
be
used
to
establish
operating
limits,
and
the
emissions
are
not
representative
of
emissions
when
operating
within
allowable
limits
established
under
a
successful
compliance
test.
12
See
USEPA,
"Technical
Implementation
Document
for
EPA's
Boiler
and
Industrial
Furnace
Regulations",
March
1992,
p.
5­
14.

8

Spiking
­­
Indicates
whether
spiking
of
ash,
chlorine,
or
metal
feedstreams
was
used.
"N"
indicates
no,
"Y"
is
yes,
"U"
is
unknown,
"UL"
is
unlikely,
and
"L"
is
likely.


Tier
Status
­­
The
Tier
compliance
status
(Tier
I
vs
Tier
III)
is
identified
for
the
individual
metals
and
chlorine.


Others
descriptors
for
cement
kilns
­­

Kiln
type
Wet
vs
dry
Long
vs
short
Bypass
In­
line
raw
mill

Others
descriptors
for
boilers
­­

Commercial
vs
on­
site
waste
handling
Mixed
radioactive
waste
Sootblowing
practices
Description
of
practices:
­
RX:
If
the
source
blew
soot
during
the
test,
the
sootblowing
run
is
identified
(e.
g.,
R3)
­
No:
If
the
source
does
not
blow
soot
during
normal
operations
­
U
or
Unk:
If
available
data
is
insufficient
to
determine
sootblowing
operations
Sootblow
corrected
average:
Yes
or
No,
indicating
whether
the
source
used
the
time­
weighted
average
provided
by
the
BIF
guidance
document
to
calculate
average
emissions.
12
Coal
type
Identify
the
type
of
coal
used
(bituminous,
lignite,
sub­
bituminous,
etc.)


Other
descriptors
for
incinerators
­­

Incinerator
type
(rotary
kiln,
hearth,
fluidized
bed,
liquid
injection)
Waste
heat
recovery
boiler
Commercial
vs
on­
site
Waste
type
(solid,
liquid,
sludge),
9
Mixed
radioactive
waste
DoD
chem
demil
units
DoD
munitions
popping
furnaces,
propellants
furnaces
°
Other
descriptors
for
HCl
production
furnaces
Waste
heat
recovery
boiler
(WHB
included
in
APCS
description)
10
4.0
Individual
Source
Data
Sheets
Detailed
data
on
each
source
are
compiled
in
Microsoft
Excel
spreadsheets.
The
sheets
are
very
similar
in
format
to
those
used
for
the
June
27,
2000
Phase
II
data
base
NODA
(65
FR
39581).
Each
individual
source
has
its
own
workbook
file,
and
is
assigned
a
unique
ID
number.
The
Excel
files
are
named
according
to
the
source's
ID
number.

Each
file
has
a
series
of
worksheets
which
contain
a
compilation
of
the
data
corresponding
to
each
worksheet
topic.
These
include:
(1)
source
description
("
source");
(2)
condition
description
("
cond");
(3)
stack
gas
emissions
("
emiss");
(4)
feedstreams
("
feed");
(5)
process
data
("
process");
(6)
PCDD/
PCDF
("
df");
(7)
stack
gas
emission
and
feedrate
summary
("
summ
1");
and
(8)
source
description
summary
("
summ
2").
Contents
of
the
worksheets
are
described
below.

Multiple
test
conditions
at
the
same
source,
either
performed
within
the
same
campaign
or
during
another
test
campaign,
are
incorporated
into
the
same
source
file.
When
appropriate,
cell
information
common
to
multiple
worksheets
is
linked
to
improve
data
quality
and
facilitate
revisions.

The
structure
of
these
data
sheets
is
tailored
to
facilitate
review
and
enhance
the
accuracy
of
the
data.
The
key
measure
of
this
review­
friendliness
is
the
convention
of
designing
the
spreadsheets
for
data
entry
to
be
consistent
with
the
data
as
found
in
the
test
report,
thus
allowing
a
direct
comparison
of
the
as­
reported
data
with
the
entered
data.
This
involved
dividing
the
emissions
and
feedstream
sheets
into
two
portions.
In
most
cases,
as­
reported
data
are
entered
"verbatim"
in
the
first
section.
Next,
calculations
are
made
as
appropriate
to
convert
the
asreported
emissions
data
into
common
units
(e.
g.,
gas
concentrations
corrected
to
7%
O2
),
which
are
presented
in
the
second
section.
Customized
programming,
apparent
in
the
cell
formulas,
shows
the
calculations
that
are
made
to
convert
the
data
to
common
units.

For
many
of
the
combustors,
data
on
the
emissions,
feed,
and
process
information,
are
divided
between
two
sheets
(e.
g.,
"feed
1"
and
"feed
2").
Recently
collected
data
are
included
in
the
first
sheet,
which
includes
a
"1"
in
the
sheet
title.
Sheets
with
a
"2"
in
the
title
contain
previously
collected
testing
information
that
has
been
released
and
used
by
EPA
in
previous
activities.

Also,
for
much
of
the
previously
collected
data
in
the
"2"
sheets
it
was
not
feasible
to
present
the
information
in
a
"verbatim"
form.
Instead,
data
are
provided
directly
in
standardized
units
(e.
g.,
ug/
dscm
@
7%
oxygen).
However,
the
stack
gas
sampling
train
flowrates
and
oxygen
levels
that
were
used
for
unit
conversions
are
provided
in
the
sheets
in
all
cases,
making
it
simple
for
the
reviewer
to
re­
convert
the
data
to
any
other
desired
units
(e.
g.,
lb/
hr,
grams/
min,
etc.)
for
comparison
purposes.
11
4.1
Source
Description
Sheet
The
first
sheet
contains
descriptive
information
on
the
source
type,
ID
Nos.,
source
design,
fuel
types,
etc.
It
includes:

ID
No.
­­
Unique
ID
No.
that
identifies
each
different
hazardous
waste
burning
unit
(i.
e.,
source)
which
has
been
tested;
identical
or
sister
units
which
have
not
been
tested
are
not
assigned
an
ID
No.

EPA
ID
No.
­­
9
digit
code
assigned
to
each
facility
site
by
EPA.

Facility
Name
­­
Name
of
the
company
which
operates
the
source.

Facility
Location
­­
City
and
state
of
facility.

Facility
Name
or
ID
No.
­­
Name
of
the
source
as
identified
internally
by
the
facility.

Sister
Units
­­
Sources
for
which
"data­
in­
lieu"
of
testing
is
used
to
document
compliance.
Sisters
units
have
been
determined
by
regulatory
officials
to
be
either
identical
or
essentially
similar
in
expected
performance
so
that
testing
of
both
units
is
unnecessary.

Combustor
Class
and
Type
­­
Generic
class
and
type
of
combustor,
for
example,
incinerator,
boiler,
cement
kiln,
etc.

Combustor
Characteristics
­­
Distinguishing
features
of
combustor
and
firing
set­
up,
including
design,
manufacturer,
model,
thermal
ratings,
etc.

Soot
Blowing
­­
Identifies
whether
soot
blowing
is
used,
as
well
as
the
duration
and
frequency.

APCS
–
Generic
type
of
air
pollution
control
system;
for
example,
ESP,
FF,
SDA
(spray
dryer
absorber),
WS
(wet
scrubber),
VS
(venturi
scrubber).

APCS
Characteristics
­­
Distinguishing
features
of
the
APCS,
including
manufacturer,
model,
and
design
characteristics
of
performance
indicators
(such
as
pressure
drop
for
VS,
fabric
type
and
air
to
cloth
ratio
for
FF,
number
of
fields
for
ESP,
etc.).

Hazardous
Waste
­­
Generic
form
of
hazardous
waste
that
is
burned
as
indicated
in
the
test
report
–
liquid,
solid,
sludge.
12
Hazardous
Waste
Characteristics
­­
Distinguishing
features
of
waste,
including
waste
constituents,
waste
codes,
waste
types,
waste
origin,
etc.

Supplemental
Fuel
­­
Auxiliary
fuel
(including
non­
hazardous
waste)
co­
fired
with
hazardous
waste.
Typically
natural
gas.
May
also
include
coal,
fuel
oil,
process
gas,
or
any
other
non­
hazardous
waste
fuels.

Stack
Characteristics
­­
Presented
in
terms
of
dispersion
modeling
at
stack
exit.

Diameter
­­
Diameter,
or
equivalent
diameter
if
non­
circular
(ft).

Height
­­
Elevation
above
grade
level
(ft).

Gas
Velocity
­­
Average
gas
velocity
(ft/
sec).

Gas
Temperature
­­
Average
gas
temperature
(
o
F).

Permitting
Status
­­
Includes
Tier
I,
II,
or
III
permitting
status,
identification
of
low
waste
risk
exemption
units,
etc.

4.2
Condition
Description
The
condition
description
sheet
serves
as
a
bibliographic
reference
to
all
compliance
test
and/
or
risk
burn
test
reports
from
which
the
data
are
taken:

Report
Name/
Date
­­
Title
and
date
of
report.

Report
Preparer
­­
Company
responsible
for
writing
test
report.

Testing
Firm
­­
Company
responsible
for
performing
sampling/
testing.

This
is
followed
by
a
description
of
each
of
the
test
conditions
from
the
test
reports.
For
each
test
condition,
the
following
information
is
provided:

Number
­­
Test
condition
number
that
is
assigned.

Testing
Dates
­­
Date(
s)
of
the
test
condition.

Condition
Description
­­
Description
of
why
the
test
was
performed
(typically
a
CoC,
trial
burn,
or
risk
burn),
and
under
what
test
conditions
(for
example
maximum
feedrates,
minimum
combustion
chamber
temperature,
etc.).
13
Content
­­
Summarizes
the
technical
scope
of
the
test,
including
what
emissions
measurements
and
feedstream
analyses
were
conducted.

4.3
Emissions
Data
Sheet
This
sheet
summarizes
the
stack
gas
emission
results
for
the
individual
sources.
Information
for
each
test
condition
is
presented
in
order
of
assigned
condition
number.

For
each
test
condition,
data
are
entered
on
an
individual
run
basis,
typically
three
runs
per
test
condition.
Data
are
first
entered
with
the
same
units
of
measure
as
presented
in
the
test
report.
This
can
include
various
different
stack
gas
concentration
units
(ppmv,
mg/
dscm,
sometimes
corrected
to
7%
O2
),
as
well
as
mass
emissions
rates
(lb/
hr,
g/
hr,
g/
sec,
etc.).

The
second
column
of
the
sheet
shows
the
units
of
the
data.
The
third
column
specifies
whether
the
gas
concentration
data
are
corrected
to
7%
O2
(with
either
a
"y"
or
"n").

The
next
columns
show
the
data
by
run.
Non­
detect
measurements
are
indicated
by
an
"nd"
which
is
added
to
the
column
immediately
to
the
left
of
each
of
the
run
data.

When
data
are
presented
in
non­
standard
units
(mass
rates
or
non­
standard
concentrations),
conversion
calculations
are
made
as
necessary
to
transform
all
emissions
to
common
units
of
concentrations
­­
PM
in
gr/
dscf;
HCl,
Cl2
,
and
total
chlorine
in
ppmv;
CO
and
HC
in
ppmv;
and
metals
in
ug/
dscm
­­
all
corrected
to
7%
O2
.

Note
the
following
issues
for
each
of
the
pollutant
types.


PM
­­
Usually
reported
and
entered
as
front­
half
capture
data,
as
per
EPA
Method
5.
Sometimes
both
front­
half
and
total
capture
are
reported.
This
is
noted
and
entered.
Soot
blowing
corrected
average
is
entered
in
the
average
column
when
soot
blowing
is
used
and
the
soot
blowing
correction
procedure
is
used
by
the
source
to
calculate
a
corrected
daily
emission
average.
Also
soot
blowing
corrected
averages
are
used
for
metals
as
appropriately
reported.


HCl
and
Cl2
­­
HCl
and
Cl2
gas
concentration
data
are
entered.
Total
chlorine
is
calculated
as
HCl
+
2*
Cl2
,
where
both
are
in
ppmv.


CO,
HC
–
Both
test
run
averages
("
RA")
and
maximum
hourly
rolling
averages
("
MHRA")
are
entered
as
available.
HC
is
reported
as
propane.
14

Metals
­­
Data
for
CAA
and
BIF
metals
emission
values
are
entered
as
available.
The
Cd
and
Pb
concentrations
are
added
together
for
calculating
the
SVM
concentration
and
the
As,
Be,
and
Cr
concentrations
are
summed
for
calculating
the
LVM
concentration.
For
treatment
of
non­
detected
values,
the
procedure
is
to:
(1)
use
"nd"
to
identify
the
metal
in
question
with
a
non­
detect
in
the
column
beside
the
data
entry
as
discussed
above,
and
(2)
apply
the
full
value
of
the
detection
limit
up
to
the
point
of
the
SVM
and
LVM
calculation.
At
this
point,
the
non­
detect
value(
s)
is
divided
by
2
(use
of
"one­
half"
of
the
detection
limit).
This
is
in
contrast
to
an
alternate
convention
where
the
detection
limit
is
assumed
to
be
the
full
measured
concentration
for
non­
detected
results.


Principal
Organic
Hazardous
Constituent
(POHC)
and
DRE
­­
For
each
POHC
type
tested
in
trial
burns,
the
DRE
%
is
entered,
and
usually
the
POHC
feedrate
and/
or
POHC
emission
rate
are
entered
as
well.


Sampling
train
information
­­
Stack
gas
flowrate
(dscfm),
oxygen
(%
dry
volume),
moisture
(%),
and
gas
temperature
(
o
F)
are
provided
for
each
of
the
different
manual
isokinetic
sampling
methods.
These
are
used
for
normalization
of
stack
gas
emissions
and
calculation
of
feedrate
Maximum
Theoretical
Emission
Concentrations
(MTEC),
as
discussed
in
the
next
section
below.

4.4
Feedstream
Data
Sheet
This
sheet
summarizes
the
characteristics
of
all
feedstreams
to
the
system
during
each
test
condition.
As
available,
contributions
from
all
the
different
feedstreams
are
shown,
including
different
hazardous
waste
streams,
spiking
streams,
non­
hazardous
waste
streams,
and
any
other
auxiliary
fuel
or
feedstreams
such
as
process
gases,
natural
gas,
fuel
oil,
or
coal.

The
characteristics
of
each
different
feedstream
are
shown
in
separate
columns.
Information
for
each
test
condition
is
presented
in
order
of
assigned
condition
number.

Characteristics
include
total
feedstream
feedrate,
as
well
as
ash,
chlorine,
and
metals
content,
and
feedstream
thermal
and
physical
properties
­­
such
as
heating
value,
viscosity,
and
density
­­
as
available.

Firing
rates
(in
million
Btu/
hr)
are
calculated
based
on
feedrates
and
heating
value.
Total
firing
rates
are
also
estimated
using
a
conventional
"F­
factor"
approach
(as
commonly
done
for
conversation
of
stack
gas
concentration
measurements
to
emissions
factors
for
compliance
purposes
for
fuel
fired
boilers).
An
F­
factor
of
9,000
dscf
(at
0%
O2
)
/
MMBtu
heat
input
is
used.
Estimated
firing
rates
are
compared
with
firing
rates
based
on
reported
feedstreams.
Heat
input
from
non­
waste
feedstreams
that
are
not
accounted
for
in
the
test
report
are
determined
based
on
the
difference
between
estimated
and
reported
firing
rate
levels.
15
Maximum
theoretical
emissions
concentrations
(MTECs)
are
calculated
for
ash,
chlorine,
and
metals
for
each
different
feedstream.
As
the
name
implies,
MTECs
represent
emission
levels
on
the
assumption
that
feed
constituents
are
completely
discharged
in
the
stack
exhaust
without
any
loss
or
partitioning
within
the
combustor
system.
MTECs
are
calculated
by
dividing
the
constituent
mass
feed
rate
by
the
stack
gas
flowrate,
as
measured
by
a
manual
method
sampling
system,
to
produce
normal
units
of
concentration,
corrected
to
7%
O2
.
In
cases
where
multiple
stack
gas
flowrates
are
simultaneously
measured
during
the
same
condition
from
more
than
one
stack
gas
sampling
train,
the
flow
rate
from
the
sampling
train
that
is
conducted
during
the
longest
time
duration
is
used
to
calculate
the
MTECs.
Note
that
this
convention
has
little
impact
on
the
value
of
the
MTECs
because
the
stack
gas
flowrates
from
different
trains
over
the
same
test
condition
are
very
similar.
Consistent
with
the
stack
gas
treatment,
non­
detects
are
treated
at
half
the
detection
limit.

Tier
I
feedrates
limits
(for
metals
and
chlorine
as
appropriate)
are
also
tabulated
at
the
bottom
of
the
feedstream
sheet
where
found
in
the
test
reports.

4.5
Process
Data
Sheet
This
sheet
includes
a
listing
of
all
the
reported
non­
feedrate
related
process
operating
data
for
each
test
condition.
The
process
data
normally
include
permit
operating
parameters,
such
as
combustion
temperature,
steam
production
rates,
production
rates,
and
APCS
operating
data

such
as
for
baghouses:
inlet
temperature
and
pressure
drop;
for
ESPs:
inlet
temperature
and
power
input;
and
for
scrubbers:
pressure
drop,
pH,
L/
G
ratio,
and
some
measure
of
blowdown.
Individual
run
and/
or
condition
averages
are
presented,
and
sometimes
maximum
(or
minimum)
hourly
rolling
averages
are
shown.

4.6
PCDD/
PCDF
Sheets
A
separate
sheet
is
used
to
present
the
PCDD/
PCDF
emission
data
due
to
the
relative
complexity
involved
in
processing
data
on
25
individual
congeners/
isomers
and
calculating
the
normal
units
in
toxic
equivalents
(TEQs)
and
total
PCDD/
PCDF.
The
TEQ
and
total
PCDD/
PCDF
values
are
calculated
from
raw
test
report
data
from
the
analytical
and
sampling
results
by
individual
run,
as
available.
TEQ
values
are
calculated
by
run
using
the
International
(I­
TEQ)
risk­
weighting
system
for
each
congener
and
isomer.
Total
PCDD/
PCDF
values
are
also
determined
without
the
TEQ
risk­
weighting
factors
as
available.
Any
individual
congener/
isomer
non­
detect
values
are
treated
at
half
of
the
detection
limit.
Separate
sheets
are
used
for
each
different
test
condition
for
which
PCDD/
PCDF
data
are
available.

4.7
Source
Summary
Sheets
16
For
many
of
the
files,
two
source
summary
worksheets
are
also
included
at
the
end:
the
emissions
and
feedrate
data
summary
sheet,
and
the
source
description
summary
sheet.
The
emissions
and
feedrate
data
summary
sheet
provides
a
succinct
rundown
of
the
information
contained
in
the
source
and
emissions
sheets.
These
sheets
do
not
provide
any
additional,
unique
information
not
contained
in
the
previous
worksheets.
Table
1.
Phase
I
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
Company
City
State
EPA
Region
Unit
Name
Comments
A10
OINC
NJD002373579
Air
Products
And
Chemicals
Inc
Paulsboro
NJ
2
Interim
status
725
OINC
NJD001707944
Asahi
Glass
(ZENECA,
ICI)
Bayonne
NJ
2
LV­
3
Inc
824
OINC
NJD980753875
Ausimont
(Pennwalt
Corp)
Thorofare
NJ
2
Isotron
142
OINC
NJ3210020704
US
Army
Armament
R&
D
Command
Picatinny
NJ
2
New
facility,
permitted,
soon
to
be
online
915
OINC
NYD980592497
Eastman
Kodak
Rochester
NY
2
Building
218
CHI
3016
OINC
NYD980592497
Eastman
Kodak
Rochester
NY
2
B­
95
Multiple
Hearth
825
OINC
NYD002080034
General
Electric
Co.
Waterford
NY
2
Rotary
Kiln
Inc
3020
OINC
NYD002080034
General
Electric
Co.
Waterford
NY
2
Fixed
Box
No.
2
712
OINC
NYD002014595
Nepera
Harriman
NY
2
A43
OINC
NYD002103216
Occidental
(Durez)
Niagara
Falls
NY
2
3022
CINC
NYD000632372
Safety
Kleen
(BDT
Inc,
Laidlaw)
Clarence
NY
2
307
LWAK
NYD080469935
Thermalkem
(Norlite)
Cohoes
NY
2
Kiln
No.
1
479
LWAK
NYD080469935
Thermalkem
(Norlite)
Cohoes
NY
2
Kiln
No.
2
Data
in­
lieu
(#
307)

728
OINC
PRD091024786
Eli
Lilly
And
Company
Mayaquez
PR
2
Brule
Multiple
units
at
this
site?

3021
OINC
PRD090028101
Merck
Sharp
&
Dohme
Quimica
Barceloneta
PR
2
rotary
kiln
OINC
PRD090028101
Merck
Sharp
&
Dohme
Quimica
Barceloneta
PR
2
t­
thermal
liquid
inj
3018
OINC
PRD090021056
Squibb
Manufacturing,
Inc.
Humacao
PR
2
caloric
#1
3019
OINC
PRD090021056
Squibb
Manufacturing,
Inc.
Humacao
PR
2
caloric
#2
OINC
PRD090613357
Chemsource
(SK&
F)
Guayama
PR
2
Shutdown,
but
planning
to
restart
in
FY
2003
700
OINC
DED003930807
Dupont
Wilmington
DE
3
454
OINC
MDD003071875
FMC
Agricultural
Chemical
Group
Baltimore
MD
3
207
CK
PAD002389559
Keystone
Cement
Company
Bath
PA
3
Kiln
No.
1
208
CK
PAD002389559
Keystone
Cement
Company
Bath
PA
3
Kiln
No.
2
468
OINC
PAD980550412
Lonza
(Smithkline)
Conshohocken
PA
3
Liquid
Incinerator
OINC
PAD003043353
Merck
&
Co
Inc
­
Cherokee
Plant
Riverside
PA
3
Old
unit
closing;
new
unit
under
construction
465
OINC
VAD065385296
Honeywell
(Allied
Fibers)
Hopewell
VA
3
Liq
Waste
Incinerator
349
OINC
VA1210020730
Radford
Army
Ammunition
Plant
Radford
VA
3
Unit
6A
349a
OINC
VA1210020730
Radford
Army
Ammunition
Plant
Radford
VA
3
Data
in­
lieu
(#
349)

476
LWAK
VAD042755082
Solite
Arvonia
VA
3
Kiln
No.
6
313
LWAK
VAD042755082
Solite
Arvonia
VA
3
Kiln
No.
7
314
LWAK
VAD042755082
Solite
Arvonia
VA
3
Kiln
No.
8
474
LWAK
VAD046970521
Solite
Cascade
VA
3
Kiln
No.
3
311
LWAK
VAD046970521
Solite
Cascade
VA
3
Kiln
No.
2
312
LWAK
VAD046970521
Solite
Cascade
VA
3
Kiln
No.
4
336
LWAK
VAD046970521
Solite
Cascade
VA
3
Kiln
No.
1
340
OINC
WVD056866312
Bayer
(Miles,
Inc.)
New
Martinsville
WV
3
Fluidized
Bed
3007
OINC
WVD004341491
Cytec
Industries
Willow
Island
WV
3
Page
1
of
5
Table
1.
Phase
I
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
Company
City
State
EPA
Region
Unit
Name
Comments
3006
OINC
WVD004325353
Crompton
Corp
(OSI
Specialties,
Inc.)
Sisterville
WV
3
B12
OINC
AL3210020027
Anniston
Army
Depot
Anniston
AL
4
construction
certification,
first
test
planned
1/
02
490
OINC
ALD001221902
CIBA­
Geigy
Corporation
McIntosh
AL
4
HW
Inc
No.
2
705
OINC
ALD001221902
CIBA­
Geigy
Corporation
McIntosh
AL
4
Muli­
purpose
Inc
A56
OINC
GAD039046800
Monsanto
(Searle)
Augusta
GA
4
A27
OINC
KYD006370159
Elf
Atochem
North
America,
Inc.
Calvert
City
KY
4
359
CINC
KYD006373922
Elf
Atochem
Carrollton
KY
4
210
CINC
KYD088438817
LWD,
Inc.
Calvert
City
KY
4
Unit
No.
3
211
CINC
KYD088438817
LWD,
Inc.
Calvert
City
KY
4
Unit
No.
1
212
CINC
KYD088438817
LWD,
Inc.
Calvert
City
KY
4
Unit
No.
2
904
OINC
MSD033417031
First
Chemical
Corporation
Pascagoula
MS
4
203
CK
MSD077655876
Holnam
Inc.
Artesia
MS
4
Kiln
No.
1
708
OINC
NCD047373766
Catalytica
Phar
(Burroughs
Wellcome)
Greenville
NC
4
McGill
No.
2
Inc
4
units
McGill
1,
McGill
2,
Prenco,
NAO
341
OINC
NCD065655599
Glaxo
Welcome
R.
T.
P.
NC
4
200
CK
SCD003351699
Giant
Cement
Company
Harleyville
SC
4
Kiln
No.
4
201
CK
SCD003351699
Giant
Cement
Company
Harleyville
SC
4
Kiln
No.
5
680
CK
SCD003351699
Giant
Cement
Company
Harleyville
SC
4
Kiln
No.
3
data
in­
lieu
(#
200)

681
CK
SCD003351699
Giant
Cement
Company
Harleyville
SC
4
Kiln
No.
2
data
in­
lieu
(#
200)

205
CK
SCD003368891
Holnam
Inc.
Holly
Hill
SC
4
Kiln
No.
1
206
CK
SCD003368891
Holnam
Inc.
Holly
Hill
SC
4
Kiln
No.
2
809
OINC
TND003376928
Tennessee
Eastman
Co.
Kingsport
TN
4
No.
1
Rotary
Kiln
Major
recent
system
upgrades
810
OINC
TND003376928
Tennessee
Eastman
Co.
Kingsport
TN
4
Liquid
Chem
Destructor
Major
recent
system
upgrades
357
OINC
TN0890090004
US
Department
Of
Energy
Oak
Ridge
TN
4
K­
25
TSCA
905
OINC
TND007024664
Velsicol
Chemical
Corporation
Memphis
TN
4
May
close
to
meet
MACT
460
OINC
ILD065237851
Akzo
Chemie
America
Morris
IL
5
3017
OINC
ILD005083316
Mcwhorter
Inc
(Cargill)
Carpentersville
IL
5
333
CINC
ILD098642424
ONYX
Trade
Waste
Incineration
Sauget
IL
5
Unit
No.
4
612
CINC
ILD098642424
ONYX
Trade
Waste
Incineration
Sauget
IL
5
Unit
No.
3
806
OINC
IND000810861
Amoco
Oil
Co.
Whiting
IN
5
Fluidized
Bed
OINC
IND006050967
Eli
Lilly
And
Company
Lafayette
IN
5
Trane
T49
Might
close
to
meet
MACT
OINC
IND006050967
Eli
Lilly
And
Company
Lafayette
IN
5
New
unit
planned
OINC
IND072040348
Eli
Lilly
And
Company
Clinton
IN
5
Trane
TO3/
TO4
300
CK
IND005081542
ESSROC
Corporation
Logansport
IN
5
Kiln
No.
1
491
CK
IND005081542
ESSROC
Corporation
Logansport
IN
5
Kiln
No.
2
Data
in­
lieu
(
#
300)

3030
CK
IND006419212
Lone
Star
Industries,
Inc.
Greencastle
IN
5
Kiln
No.
1
354
OINC
MID000724724
Dow
Chemical
Co.
Midland
MI
5
Unit
830
Consolidating
with
353;
retrofit
APCS
to
meet
MA
342
OINC
MID000820381
Pharmacia
&
Upjohn
Co.
Kalamazoo
MI
5
Interim
status
Page
2
of
5
Table
1.
Phase
I
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
Company
City
State
EPA
Region
Unit
Name
Comments
3014
OINC
MND006172969
3M
Cottage
Grove
MN
5
3013
OINC
OHD046202602
Aztec
Peroxides
Inc
Elyria
OH
5
302
CK
OHD987048733
Lafarge
Paulding
OH
5
Kiln
No.
1
302a
CK
OHD987048733
Lafarge
Paulding
OH
5
Kiln
No.
2
Data
in­
lieu
(#
302)

A36
OINC
OHD004172623
Lubrizol
Corporation
Painesville
OH
5
Interim
status;
no
test;
maybe
in
2002
495
OINC
OHD004304689
PPG
Industries,
Inc.
Circleville
OH
5
Energy
Recovery
Unit
331
CINC
OHD048415665
Ross
Incineration
Services
Grafton
OH
5
APCD
upgrade
being
done
222
CINC
OHD980613541
Waste
Technologies
Industries
East
Liverpool
OH
5
3009
CINC
WID990829475
Waste
Research
And
Reclamation
Eau
Claire
WI
5
484
OINC
ARD089234884
Arkansas
Eastman
Batesville
AR
6
No.
2
Incinerator
APCD
upgrades
will
be
done
to
meet
MACT
228
CK
ARD981512270
Ash
Grove
Cement
Company
Foreman
AR
6
Kiln
No.
2
403
CK
ARD981512270
Ash
Grove
Cement
Company
Foreman
AR
6
Kiln
No.
1
404
CK
ARD981512270
Ash
Grove
Cement
Company
Foreman
AR
6
Kiln
No.
3
486
CINC
ARD069748192
ENSCO
El
Dorado
AR
6
MWP­
2000
Kiln
No.
3
APCD
upgrades
will
be
done
to
meet
MACT
487
CINC
ARD069748192
ENSCO
El
Dorado
AR
6
Fixed
Base
Inc
Kiln
No.
1
anAPCD
upgrades
will
be
done
to
meet
MACT
3000
CINC
ARD006354161
Reynolds
Aluminum
Gum
Springs
AR
6
C10
CINC
TXD982562787
American
Envirotech
Channelview
TX
6
Permitted,
not
yet
constructed,
no
data
506
OINC
TXD008081697
BASF
Corporation
Freeport
TX
6
Incinerator
No.
IN­
701
TXD008081697
BASF
Corporation
Freeport
TX
6
IN­
4701
New
unit,
data
soon
B32
OINC
TXD058260977
Bayer
(Miles
Corp.)
Baytown
TX
6
Permitted,
not
yet
constructed,
no
data
603
CINC
TXD000838896
Chemical
Waste
Management
Port
Arthur
TX
6
600
OINC
TXD008092793
Dow
Chemical
Co.
Freeport
TX
6
B­
33
rotary
kiln
3024
OINC
TXD000017756
Dow
Chemical
Co.
La
Porte
TX
6
H­
2000
TTU
707
OINC
TXD008079212
Dupont
La
Porte
TX
6
Central
Scrubbed
Inc
338
OINC
TXD008079642
Dupont
Sabrine
River
Orange
TX
6
rotary
kiln
OINC
TXD086981172
Fina
Oil
and
Chem
Deer
Park
TX
6
3026
OINC
TXD078432457
Hoechst
Celanese
Corp.
Pasadena
TX
6
MN­
108
3027
OINC
TXD078432457
Hoechst
Celanese
Corp.
Pasadena
TX
6
MN­
460
A62
OINC
TXD008076853
Hunstman
(Texaco
Chemical
Co)
Conroe
TX
6
Old
unit
no
longer
oper;
new
unit
being
construct
614
OINC
TXD982286932
Occidental
Chemical
Corp.
Gregory
TX
6
VCM
Inc
CC­
IN­
1
2
units
3028
OINC
TXD981911209
Occidental
Chemical
VCM
Deer
Park
TX
6
NCIN3
OINC
TXD981911209
Occidental
Chemical
VCM
Deer
Park
TX
6
NCIN2
Data
in­
lieu
(#
3028)

221
CINC
TXD055141378
Safety
Kleen
(Rollins)
Deer
Park
TX
6
Res
(TX)
Incinerator
Train
II
not
most
representative
configuration
488
CINC
TXD055141378
Safety
Kleen
(Rollins)
Deer
Park
TX
6
Res
(TX)
Incinerator
Train
I
not
most
representative
configuration
489
CINC
TXD055141378
Safety
Kleen
(Rollins)
Deer
Park
TX
6
Incinerator
Train
II
/
RRR
not
most
representative
configuration
609
CINC
TXD055141378
Safety
Kleen
(Rollins)
Deer
Park
TX
6
Incinerator
I/
II/
RRR
492
OINC
TXD007330202
Texas
Eastman
Longview
TX
6
FBC
Inc
Page
3
of
5
Table
1.
Phase
I
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
Company
City
State
EPA
Region
Unit
Name
Comments
613
OINC
TXD007330202
Texas
Eastman
Longview
TX
6
rotary
kiln
318
CK
TXD0007349327
Texas
Industries,
Inc.
Midlothian
TX
6
Kiln
No.
1
4
kilns
at
TXI;
only
2
can
burn
at
a
time
473
CK
TXD0007349327
Texas
Industries,
Inc.
Midlothian
TX
6
Kiln
No.
2
3025
OINC
TXD000461533
Union
Carbide
Corporation
Texas
City
TX
6
VA­
5
604
OINC
LAD040776809
BASF
Corporation
Geismer
LA
6
Aniline
Plant
808
OINC
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
I­
200
(not
I­
300)

3002
OINC
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
R­
70
solvents/
methane
714
OINC
LAR00001833
Lyondell
Westlake
LA
6
480
OINC
LAD053783445
Novartis
(CIBA­
Geigy
Corporation)
St.
Gabriel
LA
6
Multi­
purpose
Inc
706
OINC
LAD053783445
Novartis
(CIBA­
Geigy
Corporation)
St.
Gabriel
LA
6
Liq
inj
inc
Not
operating
since
1996,
but
not
closed
467
OINC
LAD008086506
PPG
Inc
Westlake
(Lake
LA
6
Unit
1
3001
OINC
LAD008086506
PPG
Inc
Westlake
(Lake
LA
6
Unit
2
610
OINC
LAD980622104
Shell
Oil
Co
Norco
LA
6
NCIN­
1
611
OINC
LAD980622104
Shell
Oil
Co
Norco
LA
6
NCIN­
2
CK
KSD031203318
Ash
Grove
Cement
Company
Chanute
KS
7
New
replacement
kiln,
testing
in
12/
01
322
CK
KSD007148034
Lafarge
Fredonia
KS
7
Kiln
No.
1
Full
RCRA
Part
B
permit
323
CK
KSD007148034
Lafarge
Fredonia
KS
7
Kiln
No.
2
Full
RCRA
Part
B
permit
319
CK
MOD054018288
Continental
Cement
Company
Hannibal
MO
7
Kiln
No.
1
Full
RCRA
Part
B
permit
204
CK
MOD029729688
Holnam
Inc.
Clarksville
MO
7
Kiln
No.
1
Full
RCRA
Part
B
permit
303
CK
MO981127319
Lone
Star
Industries,
Inc.
Cape
Girardeau
MO
7
Kiln
No.
1
Full
RCRA
Part
B
permit
3012
OINC
KS0213820467
Kansas
Army
Ammunition
Plant
Parsons
KS
7
477
OINC
MOD050226075
American
Cyanamid
Hannibal
MO
7
Prowl
Unit
B
John
Zink
478
OINC
MOD050226075
American
Cyanamid
Hannibal
MO
7
Prowl
Unit
C
T­
Thermal
805
OINC
MOD050226075
American
Cyanamid
Hannibal
MO
7
Unit
D
Trane/
Brule
463
OINC
MOD056389828
Bayer
(Miles,
Mobay)
Kansas
City
MO
7
Thermal
Oxidizer
3011
CINC
MOD9857988164I
C
I
Explosives
USA
Incorporated
Joplin
MO
7
rotary
kiln
3015
CINC
MOD9857988164I
C
I
Explosives
USA
Incorporated
Joplin
MO
7
car
bottom
furnace
503
OINC
MO4213820489
Lake
City
Army
Ammunition
Plant
Independence
MO
7
Building
97
3010
OINC
NED981723513
Clean
Harbors
(Ecova
Corp.)
Kimball
NE
7
3008
OINC
UT3213820894
Tooele
Army
Depot
North
Tooele
UT
8
popping
furnace
OINC
UT5210090002
Deseret
Army
Depot
CAMDS
Tooele
UT
8
CAMDS
Liq
Inj
3004
OINC
UT5210090002
Deseret
Army
Depot
CAMDS
Tooele
UT
8
CAMDS
MPF
3003
OINC
UT5210090002
Deseret
Army
Depot
CAMDS
Tooele
UT
8
CAMDS
DFS
3005
OINC
UT5210090002
Deseret
Army
Depot
TOCDF
Tooele
UT
8
TOCDF
Liq
Inc
No.
2
493
OINC
UT5210090002
Deseret
Army
Depot
TOCDF
Tooele
UT
8
TOCDF
Liq
Inc
No.
1
494
OINC
UT5210090002
Deseret
Army
Depot
TOCDF
Tooele
UT
8
TOCDF
Metal
Parts
Furnace
Page
4
of
5
Table
1.
Phase
I
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
Company
City
State
EPA
Region
Unit
Name
Comments
347
OINC
UT5210090002
Deseret
Army
Depot
TOCDF
Tooele
UT
8
TOCDF
Deactivation
Furnace
System
327
CINC
UTD981552177
Safety
Kleen
(Aptus)
Aragonite
UT
8
344
OINC
TT0570090011
Department
Of
The
Army
Johnston
Atoll
TT
9
LIC
346
OINC
TT0570090011
Department
Of
The
Army
Johnston
Atoll
TT
9
DFS
470
OINC
TT0570090011
Department
Of
The
Army
Johnston
Atoll
TT
9
Metal
Parts
Furnace
OINC
OR6213820917
USA
Umatilla
Chemical
Depot
Hermiston
OR
10
Chem
demil
inc.
Being
built
Page
5
of
5
Table
2.
Phase
II
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
No.
Facility
Name
City
State
Region
Unit
ID
Name/
No.

729
Process
Heater
CTD001159730
Dow
Chemical
U.
S.
A.
Allyn's
Point
FGales
Ferry
CT
1
Boiler
Unit
A
Boiler
MAD001039767
Bostik
Findley
Middleton
MA
1
SW
Boiler
766
Process
Heater
NYD066832023
General
Electric
Plastics
Selkirk
NY
2
A/
P
Hot
Oil
Heater
Boiler
NJD001317064
Merck
&
Co.,
Inc
Rahway
NJ
2
Boiler
3
Boiler
NJD001317064
Merck
&
Co.,
Inc
Rahway
NJ
2
Boiler
9
2008
Boiler
PAD002312791
Sun
Company,
Inc.
(R
&
M)
FrankforPhiladelphia
PA
3
Boiler
No.
2
2008a
Boiler
PAD002312791
Sun
Company,
Inc.
(R
&
M)
FrankforPhiladelphia
PA
3
Boiler
No.
1
739
Boiler
PAD002292068
Rohm
and
Haas
Company
Bristol
PA
3
Boiler
No.
7
739a
Boiler
PAD002292068
Rohm
and
Haas
Company
Bristol
PA
3
Boiler
No.
6
739b
Boiler
PAD002292068
Rohm
and
Haas
Company
Bristol
PA
3
Boiler
No.
8
819
Boiler
WVD005005509
Rhone­
Poulenc
AG
Company
Charleston
WV
3
Boiler
No.
3
819a
Boiler
WVD005005509
Rhone­
Poulenc
AG
Company
Charleston
WV
3
Boiler
No.
4
908
Boiler
WVD005005483
Union
Carbide
Corporation
South
Charleston
WV
3
Boiler
25
754
Boiler
GAD051011609
DSM
Chemicals
North
America,
Inc.
Augusta
GA
4
H­
002
Boiler
776
Boiler
GAD981237118
Monsanto
(Nutrasweet
Kelco
Co.)
Augusta
GA
4
Boiler
1
­
WHRU
1
777
Boiler
GAD981237118
Monsanto
(Nutrasweet
Kelco
Co.)
Augusta
GA
4
Boiler
2
­
WHRU
2
741
Boiler
KYD006390017
Rohm
and
Haas
Company
Louisville
KY
4
Unit
No.
100
1000
Boiler
NCD042091975
Mallinckrodt
Inc.
Raleigh
NC
4
Boiler
No.
2
778
Boiler
NCD042091975
Mallinckrodt
Inc.
Raleigh
NC
4
Boiler
No.
1
2006
Boiler
SCD980500052
3V
Inc.
Georgetown
SC
4
Unit
No.
1
(or
No.
2?)

763
Boiler
SCD043384072
Albermarle
Corp.
Orangeburg
SC
4
Unit
No.
4
1011
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
20
1011a
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
18
1011b
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
19
1012
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
22
1012a
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
21
719
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
24
719a
Boiler
TND003376928
Eastman
Chemicals
Co.
­
Tennesse
Kingsport
TN
4
Boiler
No.
23
901
Boiler
TND982109142
Diversified
Scientific
Services,
Inc.
Kingston
TN
4
DSSI
Mixed
Waste
Industrial
Boiler
System
730
Process
Heater
OHD039128913
Dow
Chemical
Co.
Hanging
Rock
Pl
Ironton
OH
5
Unit
R­
1
730a
Process
Heater
OHD039128913
Dow
Chemical
Co.
Hanging
Rock
Pl
Ironton
OH
5
Unit
R­
3
735
Boiler
IND000807107
Reilly
Industries,
Inc.
Indianapolis
IN
5
Boiler
70K
737
Boiler
IND000807107
Reilly
Industries,
Inc.
Indianapolis
IN
5
Boiler
30K
738
Boiler
IND000807107
Reilly
Industries,
Inc.
Indianapolis
IN
5
Boiler
28K
(sister
unit
to
737
(30K))

764
Boiler
IND006376362
GE
Plastics,
Mt.
Vernon
IN
Facility
Mount
Vernon
IN
5
Boiler
H530A
(Unit
1)

Page
1
of
5
Table
2.
Phase
II
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
No.
Facility
Name
City
State
Region
Unit
ID
Name/
No.

765
Boiler
IND006376362
GE
Plastics,
Mt.
Vernon
IN
Facility
Mount
Vernon
IN
5
Boiler
H530B
(Unit
2)

840
Boiler
OHD004233003
Bayer
(Monsanto
Co.
Port
Plastic
PlaAddyston
OH
5
Boiler
No.
4
911
Boiler
OHD005108477
Aristech
Chemical
Corporation
Haverhill
OH
5
Unit
2001­
UA
911a
Boiler
OHD005108477
Aristech
Chemical
Corporation
Haverhill
OH
5
Unit
UB
911b
Boiler
OHD005108477
Aristech
Chemical
Corporation
Haverhill
OH
5
Unit
UC
912
Boiler
OHD005108477
Aristech
Chemical
Corporation
Haverhill
OH
5
Unit
2001­
UE
814
Process
Heater
LAD008213191
Rubicon,
Inc
Geismar
LA
6
DPA
I
Superheater
815
Process
Heater
LAD008213191
Rubicon,
Inc
Geismar
LA
6
DPA
II
superheater
1003
Process
Heater
TXD083472266
Lyondell
Chemical
Co.
Channelview
TX
6
F­
57180
Hot
Oil
Heater
1004
Process
Heater
TXD083472266
Lyondell
Chemical
Co.
Channelview
TX
6
F­
65630
Hot
Oil
Heater
1015
Process
Heater
TXD093565653
Georgia
Gulf
Corporation
Pasadena
TX
6
Hot
Oil
Heater
No.
1
1009
Boiler
ARD089234884
Eastman
Chemicals
Co.
­
Arkansas
Batesville
AR
6
Boiler
No.
3
1009a
Boiler
ARD089234884
Eastman
Chemicals
Co.
­
Arkansas
Batesville
AR
6
Boiler
No.
2
2000
Boiler
LAD057117434
Georgia
Gulf
Chemicals
and
Vinyls,
Plaquemine
LA
6
Nebraska
Boiler
2001
Boiler
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
F­
410
2001a
Boiler
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
F­
420
2002
Boiler
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
R­
4
2003
Boiler
LAD008187080
Dow
Chemical
Co.
Plaquemine
LA
6
R­
750
753
Boiler
LAD041581422
Union
Carbide
Corp.
Hahnville
LA
6
Boiler
31
756
Boiler
LAD059130831
DSM
Copolymer
Inc.
Addis
LA
6
No.
3
boiler
812
Boiler
LAD008213191
Rubicon,
Inc
Geismar
LA
6
TDI
boiler
813
Boiler
LAD008213191
Rubicon,
Inc.
Geismar
LA
6
Aniline
II
boiler
818
Boiler
LAD010390599
Westvaco
DeRidder
LA
6
Boilers
No.
2
and
3
(common
ESP
and
stack)

822
Boiler
LAD000778381
Exxon
Chemical
Co.
Baton
Rouge
LA
6
C­
Boiler
822a
Boiler
LAD000778381
Exxon
Chemical
Co.
Baton
Rouge
LA
6
D­
Boiler
828
Boiler
LAD020597597
Angus
Chemical
Company
Sterlington
LA
6
No.
7
Boiler
834
Boiler
LAD040776809
BASF
Geismar
LA
6
Amines
835
Boiler
LAD040776809
BASF
Geismar
LA
6
No.
3
Boiler
836
Boiler
LAD040776809
BASF
Geismar
LA
6
No.
6
Boiler
1017
Boiler
TXD980808778
Aristech
Chemical
Corp.
Pasadena
TX
6
Boiler
F­
8
1016
Boiler
TXD067261412
BASF
Corporation
Beaumont
TX
6
WOD
K541
833
Boiler
TXD008081697
BASF
Corporation
Freeport
TX
6
Neol
Boiler
1013
Boiler
TXD007376700
Celanese
Pampa
TX
6
Boiler
No.
9
1014
Boiler
TXD007376700
Celanese
Pampa
TX
6
Boiler
No.
10
1018
Boiler
TXD008113441
Celanese
Ltd
Bishop
TX
6
Boiler
No.
16
Page
2
of
5
Table
2.
Phase
II
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
No.
Facility
Name
City
State
Region
Unit
ID
Name/
No.

721
Boiler
TXD026040709
Celanese
Ltd
Bay
City
TX
6
Boiler
No.
4
721a
Boiler
TXD026040709
Celanese
Ltd
Bay
City
TX
6
Boiler
No.
5
720
Boiler
TXD078432457
Celanese
Ltd.,
Chemical
Group
CleaPasadena
TX
6
MH5A
843
Boiler
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
B­
902
843a
Boiler
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
B­
901
843b
Boiler
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
B­
903
849
Boiler
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
F­
820AB
2013
Boiler
TXD008123317
E.
I.
Du
Pont
De
Nemours
&
CompanVictoria
TX
6
Boiler
Nos.
3
&
4
2016
Boiler
TXD008123317
E.
I.
Du
Pont
De
Nemours
&
CompanVictoria
TX
6
Boiler
No.
1
2012
Boiler
TXD008123317
E.
I.
Du
Pont
Nemours
&
Company,
I
Victoria
TX
6
Boiler
No.
7
2012a
Boiler
TXD008123317
E.
I.
Du
Pont
Nemours
&
Company,
I
Victoria
TX
6
Boiler
No.
8
759
Boiler
TXD008123317
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
6
Boiler
No.
7
759a
Boiler
TXD008123317
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
6
Boiler
No.
5
760
Boiler
TXD008123317
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
6
Boiler
No.
8
761
Boiler
TXD008123317
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
6
ADN
North
761a
Boiler
TXD008123317
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
6
ADN
South
774
Boiler
TXD058275769
Equistar
Chemicals,
LP
­
ChannelvieChannelview
TX
6
Boiler
No.
3
774a
Boiler
TXD058275769
Equistar
Chemicals,
LP
­
ChannelvieChannelview
TX
6
Boiler
No.
1
774b
Boiler
TXD058275769
Equistar
Chemicals,
LP
­
ChannelvieChannelview
TX
6
Boiler
No.
2
774c
Boiler
TXD058275769
Equistar
Chemicals,
LP
­
ChannelvieChannelview
TX
6
Boiler
No.
4
811
Boiler
TXD086981172
Fina
Oil
&
Chemical
Co.
La
Porte
TX
6
Train
A
Waste
Heat
Boiler
811a
Boiler
TXD086981172
Fina
Oil
&
Chemical
Co.
La
Porte
TX
6
Train
B
Waste
Heat
Boiler
767
Boiler
TXD008077190
Goodyear
Tire
and
Rubber
CompanyBeaumont
TX
6
Boiler
B­
103
767a
Boiler
TXD008077190
Goodyear
Tire
and
Rubber
CompanyBeaumont
TX
6
B­
101
767b
Boiler
TXD008077190
Goodyear
Tire
and
Rubber
CompanyBeaumont
TX
6
B­
102
767c
Boiler
TXD008077190
Goodyear
Tire
and
Rubber
CompanyBeaumont
TX
6
B­
104
767d
Boiler
TXD008077190
Goodyear
Tire
and
Rubber
CompanyBeaumont
TX
6
B­
105
1005
Boiler
TXD008076846
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
6
Boiler
#
1
(6­
BB­
1)
At
C4
Facility
1005a
Boiler
TXD008076846
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
6
Boiler
#
2
1006
Boiler
TXD000201202
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
6
PO/
MTBE
steam
generator
#
1
(H­
K2­
001)

1006a
Boiler
TXD000201202
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
6
Unit
#
2
1007
Boiler
TXD980626014
Huntsman
Polymers
Odessa
TX
6
C­
Boiler
1001
Boiler
TXD084970169
Lonza,
Inc.
Pasadena
TX
6
Boiler
B­
4001C
772
Boiler
TXD084970169
Lonza,
Inc.
Pasadena
TX
6
Boiler
B­
4001B
772a
Boiler
TXD084970169
Lonza,
Inc.
Pasadena
TX
6
Boiler
B­
4001A
Page
3
of
5
Table
2.
Phase
II
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
No.
Facility
Name
City
State
Region
Unit
ID
Name/
No.

1002
Boiler
TXD083472266
Lyondell
Chemical
Co.
Channelview
TX
6
Utility
Boiler
3
1002a
Boiler
TXD083472266
Lyondell
Chemical
Co.
Channelview
TX
6
Utility
Boiler
1
1002b
Boiler
TXD083472266
Lyondell
Chemical
Co.
Channelview
TX
6
Utility
Boiler
2
724
Boiler
TXD008106999
Merichem
Company
Houston
TX
6
Boiler
No.
4
740
Boiler
TXD065096273
Rohm
and
Haas
Texas,
IncorporatedDeer
Park
TX
6
HT­
1
Thermal
Oxidizer
743
Boiler
TXD010797389
Schenectady
International
Freeport
TX
6
B­
503
744
Boiler
TXD067285793
Shell
Deer
Park
Refining
Company
Deer
Park
TX
6
F­
UT­
100
744a
Boiler
TXD067285793
Shell
Deer
Park
Refining
Company
Deer
Park
TX
6
F­
UT­
110
745
Boiler
TXD067285793
Shell
Deer
Park
Refining
Company
Deer
Park
TX
6
F­
UT­
130
232
Boiler
TXD001700806
Solutia
(Chocolate
Bayou
Plant)
Alvin
TX
6
Boiler
30H5
232a
Boiler
TXD001700806
Solutia
(Chocolate
Bayou
Plant)
Alvin
TX
6
Boiler
31H4
746
Boiler
TXD008079527
Sterling
Chemicals,
Inc.
Texas
City
TX
6
Waste
Oxidation
Boiler
A
2021
Boiler
TXD000461533
Union
Carbide
Coporation
Texas
City
TX
6
Boiler
53
910
Boiler
TXD000461533
Union
Carbide
Corporation
Texas
City
TX
6
Boiler
5
2005
HAF
LAD092681824
Vulcan
Materials
Co.
Geismar
LA
6
F­
1
Unit
785
HAF
LAD003913449
Borden
Chemicals
and
Plastics
(BCPGeismar
LA
6
VCR
Process
Unit
853
HAF
LAD001890367
Dupont
Dow
Elastomers
LaPlace
LA
6
HCl
Recovery
Unit
2022
HAF
LAD008086506
PPG
Lake
Charles
LA
6
Unit
3
855
HAF
LAD057117434
Georgia
Gulf
Chemicals
and
Vinyls,
Plaquemine
LA
6
IN­
662
2017
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
Unit
FTB­
401
2017a
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
Unit
FTB­
402
2018
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
Unit
FTB­
603
2020
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
F­
2820
786
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
Unit
R­
30
788
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
B­
824
842
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
Unit
FTB­
400
844
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
F­
2AB
845
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
F­
210
848
HAF
TXD008092793
Dow
Chemical
Company
Freeport
TX
6
F­
11
854
HAF
TXD007330202
Eastman
Chemical
Company,
TexasLongview
TX
6
RCRA
BIF
Unit
(Halogen
Acid
Furnace)

2007
Boiler
KSD007237746
Air
Products
Manufacturing
Corp.
Wichita
KS
7
COEN
boiler
733
Process
Heater
CAD009547050
Dow
Chemical
Co.
Torrance
CA
9
U­
305
733a
Process
Heater
CAD009547050
Dow
Chemical
Co.
Torrance
CA
9
U­
304
851
HAF
CAD076528678
The
Dow
Chemical
Company
Pittsburg
CA
9
MS
HAF
Boiler
Shell
Martinez
CA
9
CO
Boiler
Page
4
of
5
Table
2.
Phase
II
HWC
Universe
Data
Base
ID
No.
Comb
Type
EPA
ID
No.
Facility
Name
City
State
Region
Unit
ID
Name/
No.

771
Boiler
WAD092899574
Kalama
Chemical
(BF
Goodrich)
Kalama
WA
10
U­
3
Boiler
Page
5
of
5
20
Table
3.
Data
Summary
Sheet
File
Name
Listing
HWC
Category
D/
F
PM
Hg
SVM
LVM
Chlorine
Incinerator
inc_
df.
xls
inc_
pm.
xls
inc_
hg.
xls
inc_
svm.
xls
inc_
lvm.
xls
inc_
cl.
xls
Cement
Kiln
ck_
df.
xls
ck_
pm.
xls
ck_
hg.
xls
ck_
svm.
xls
ck_
lvm.
xls
ck_
cl.
xls
Lightweight
Aggregate
Kiln
lwak_
df.
xls
lwak_
pm.
xls
lwak.
hg.
xls
lwak_
svm.
xls
lwak_
lvm.
xls
lwak_
cl.
xls
Liquid
Fuel
Boiler
l_
blr_
df.
xls
l_
blr_
pm.
xls
l_
blr_
hg.
xls
l_
blr_
svm.
xls
l_
blr_
lvm.
xls
l_
blr_
cl.
xls
Coal­
Fired
Boiler
coal_
df.
xls
coal_
pm.
xls
coal_
hg.
xls
coal_
svm.
xls
coal_
lvm.
xls
coal_
cl.
xls
HCl
Production
Furnace
hcl_
df.
xls
hcl_
pm.
xls
hcl_
hg.
xls
hcl_
svm.
xls
hcl_
lvm.
xls
hcl_
cl.
xls
17
Appendix
I.
Data
Base
Quality
Assurance
and
Quality
Control
Plan
Quality
assurance
is
an
integrated
system
of
management
activities
which
involves
planning,
standard
operating
procedures,
training,
work
performance,
quality
assessment,
and
quality
improvement
to
ensure
that
the
end
product
meets
all
stated
levels
of
confidence.
Quality
assurance
encompasses
the
organization
within
which
quality
control
activities
are
performed.
Such
is
the
philosophy
and
practice
involved
in
developing
the
Phase
I
and
Phase
II
data
bases.

From
experience
in
developing
the
previous
Phase
I
and
Phase
II
data
bases,
we
recognize
that
processing
mistakes
and
inaccuracies
can
and
do
occur.
To
create
safeguards
against
missed
data,
incorrect
data
interpretation,
and
data
entry
errors,
we
recognize
the
need
to
be
proactive
and
reactive
in
building
collective,
comprehensive
QA
measures:
proactive
in
the
sense
of
establishing
concrete
planning
procedures
and
performance
guidelines
prior
to
work
initiation;
reactive
in
the
sense
of
being
sensitive
and
responsive
to
inadvertent
and
systematic
shortcomings.
An
important
key
step
is
to
build
in
quality
review
measures
and
to
identify
and
implement
improvements
to
the
systematic
processing
of
the
reported
data.

To
enhance
quality
assurance
in
developing
the
data
bases,
we
followed
the
following
philosophy
and
procedures:

Quality
Assurance
Philosophy
Quality
work
is
produced
from
personnel
with:

°
Clear
understanding
of
the
purpose
of
the
work
and
overall
project
objectives.

°
Clear
understanding
of
the
data
base
contents
and
requirements.

°
Background
in
HWC
design
and
operation,
APCS
operations,
environmental
testing
programs,
measurement
methods,
and
MACT
rulemaking.

°
Sense
of
pride/
purpose
in
work.

°
Organization
and
attention
to
detail.

Data
Base
Design
°
Simplify
data
base
design
to
the
degree
possible.

°
Make
data
base
fields
and
structure
self­
explanatory
to
the
degree
possible.
18
°
Minimize/
eliminate
redundant
data
entry
requirements.

°
Capitalize
on
opportunity
for
data
base
design
evolution;
after
initial
utilization,
perform
critical
review
and
evaluation
of
the
design
limitations,
then
identify
and
implement
improvements.

Data
Entry
Personnel
Training
°
Understand
purpose
of
the
data
base.

°
Review
results
of
previously
processed
test
reports.

°
Review
contents
and
fields
of
the
data
base.

°
Process
a
report.
Have
work
reviewed
by
experienced
personnel
to
provide
feedback
on
quality.
Continue
this
feedback
process
sequence
until
report
processing
is
of
highest
quality.

Test
Report
Review
Procedures
°
Before
data
entry,
review
report
to
identify:

­­
Number
of
different
sources
for
which
stack
gas
testing
is
performed.

­­
Unit
design
and
operation,
including
combustor
type,
APCS,
waste
types,
and
operating
characteristics.

­­
Number
of
different
test
conditions
tested,
and
purposes
of
each
test
condition.

­­
Measurements
taken
­­
stack
gas
measurements,
feedstream
and
other
process
operating
measurements.

­­
Report
organization
­­
extent
and
location
of
key
data
tables
and
corresponding
descriptions
of
test
conduct
and
any
technical
problems
with
process
operations,
sampling,
or
sample
analysis.

°
Assign
unit
ID
No.
to
each
different
combustor.

Data
Entry
Procedures
/
Guideline
°
Philosophy
19
­­
Emphasize
prevention
of
data
errors
by
entering
correctly
the
first
time.
­­
Minimize/
eliminate
redundant
data
entry
requirements
by
maximizing
cell
linkages
°
Enter
all
pertinent
data
regardless
if
incomplete
at
the
time
to
avoid
possible
data
bias.
Make
a
note
of
incomplete
data,
and
attempt
to
request
what
is
missing.
Fill
in
later
as
additional
data
is
received.
Omit
incomplete
data
in
analysis
as
necessary.

°
Enter
data
exactly
as
reported
in
test
report
to
ensure
data
traceability
/
data
origin
and
to
facilitate
review.

°
Enter
data
in
preferred
final
units
­­
stack
gas
concentrations
corrected
to
7%
O2
­­
when
available
in
the
test
report
as
a
first
choice.
Enter
data
in
other
units
(e.
g.,
mass
emissions
rates
(lb/
hr))
when
it
is
only
available
in
these
units.

°
Enter
data
on
a
run­
by­
run
basis
for
each
test
condition.

°
Enter
all
available
non­
feedrate
related
process
information
that
can
be
used
to
characterize
the
tested
operating
conditions.

Data
Evaluation
°
Identify
and
double
check
apparent
outliers
through
evaluation
of
data:

­­
Compare
three
runs
at
the
same
test
condition.

­­
Compare
data
within
similar
type
of
units.

­­
Compare
data
with
that
expected
from
engineering
judgement.

°
Second
party
review
of
selected
test
report
and
data
base
entries
to
identify
missed
data,
incorrect
data
interpretation,
and
data
entry
errors.

°
Random
or
systematic
spot
checks.

Data
Changes
°
Document
all
changes
(dates
and
person
making
change)
to
data
base.
Appendix
II.
Response
to
Comments
on
Phase
II
June
2000
NODA
Response
to
Comments
on
the
June
2000
Phase
II
Hazardous
Waste
Combustor
MACT
Data
Base
Notice
of
Data
Availability
U.
S.
Environmental
Protection
Agency
Office
of
Solid
Waste
1200
Pennsylvania
Avenue,
NW
Washington,
DC
20460
October
2000
Acknowledgment
This
document
was
prepared
by
EPA's
Office
of
Solid
Waste,
Hazardous
Waste
Minimization
and
Management
Division.
EERGC
Corporation
provided
technical
support
under
EPA
Contract
No.
68­
W7­
0029.
Contents
1.0
Introduction
2.0
Comment
Period
Extension
3.0
Data
Gaps
3.1
New
test
reports
3.2
Permit
limits
and
risk
modeling
parameters
insufficiently
described
3.3
Insufficient
condition
descriptions
3.4
Earlier
test
data
should
be
considered
3.5
Sister
unit
data
may
be
incomplete
4.0
Data
Handling,
Calculations,
and
Presentation
4.1
Documentation
of
conversions
and
calculations
4.2
Inconsistent
level
of
detail
for
test
conditions
4.3
Stack
gas
flowrates
should
not
be
estimated
4.4
Supplemental
fuel
nomenclature
unclear
4.5
Significant
figures
and
rounding
conventions
4.6
Averaging
feedrate
data
is
inappropriate
4.7
SVM/
LVM
emissions
should
evaluate
both
front­
half
and
back­
half
for
nondetects
4.8
Feedrate
non­
detect
calculation
unclear
4.9
Handling
and
reporting
non­
detects
for
group
calculations
of
SVM/
LVM
or
PCDD/
PCDF
4.10
Should
use
reliable
detection
limit
for
non­
detect
measurements
5.0
Specific
Database
Edits
5.1
Arch
Chemicals,
Inc.
(Phase
II
ID
#
1008)
5.2
Merck
&
Co.
Inc.
(Phase
II
ID
#
780,
781)
5.3
ExxonMobil
Chemical
Co.
(Phase
II
ID
#
822)
5.4
Westvaco
Corp.
(Phase
II
ID
#
818)
5.5
General
Electric
Plastics
Co.
(Phase
II
ID
#
764,
765,
766)
5.6
Eastman
Chemical
Company,
Texas
Operations
(Phase
II
ID
#
854)
5.7
Mallinckrodt
Inc.
(Phase
II
ID
#
778,
1000)
5.8
DuPont
Dow
Elastomers
(Phase
II
ID
#
853)
5.9
Celanese
Ltd,
Bay
City
(Phase
II
ID
#
721)
5.10
Eastman
Chemical
Company,
Kingsport,
Tennessee
(Phase
II
ID
#
717,
719,
1011,
1012)
5.11
Celanese
Ltd.
Clear
Lake
Plant
(Phase
II
ID
#
720)
5.12
Georgia
Gulf
(Phase
II
ID
#
855,
2000)
5.13
Lyondell
(Phase
II
ID
#
1002,
1003,
1004)
5.14
Reilly
Industries
(Phase
II
ID
#
735,
737,
738)
5.15
Ticona
Polymers,
Inc.
(Phase
II
ID
#
1018)
5.16
Rubicon
Inc.
(Phase
II
ID
#
812,
813,
814,
815)
5.17
Equistar
Chemicals,
LP.
(Phase
II
ID
#
774)
5.18
Dow
(Phase
II
ID
#
729,
730,
733,
786,
788,
842­
845,
848,
849,
2017,
2018,
2020)
5.19
General
Electric
(Phase
II
ID
#
766)
5.20
DSM
(Phase
II
ID
#
754,
756)
5.21
Union
Carbide
(Phase
II
#
753,
907,
908,
910)
5.22
Rohm
and
Haas
(Phase
II
#
740,
741)
5.23
Solutia
(Phase
II
#
232)
5.24
Eastman
(Phase
II
#
717)
Tables
1
List
of
Commenters
2
Complete
List
of
Phase
II
Units
and
Commenters
3
Data
Base
Revisions
1.0
Introduction
The
U.
S.
Environmental
Protection
Agency
(EPA)
regulates
the
burning
of
hazardous
wastes
in
incinerators,
boilers
and
industrial
furnaces
under
40
CFR
Parts
264,
265,
and
266
using
the
authority
of
the
Resource
Conservation
and
Recovery
Act
(RCRA).
In
addition,
the
Agency
recently
promulgated
maximum
achievable
control
technology
(MACT)
standards
for
hazardous
waste
burning
incinerators,
cement
kilns,
and
lightweight
aggregate
kilns
under
Subpart
EEE,
Part
63,
using
the
joint
authority
of
the
Clean
Air
Act
and
RCRA.
See
64
FR
52828
(September
30,
1999).
Those
MACT
standards
are
referred
to
as
"Phase
I"
of
the
Agency's
program
to
strengthen
its
regulation
of
hazardous
waste
combustors
(HWCs).
As
Phase
II
of
that
effort,
the
Agency
plans
to
establish
MACT
standards
for
hazardous
waste
burning
boilers
and
may
also
establish
MACT
standards
for
two
additional
categories
of
industrial
furnaces
that
burn
hazardous
wastes:
halogen
acid
furnaces
(HAFs)
and
sulfuric
acid
recovery
furnaces
(SARFs).
These
devices
are
defined
at
40
CFR
260.10.

As
the
initial
step
in
the
rulemaking
process,
EPA
has
collected
process
and
emissions
data
on
Phase
II
sources
nationwide.
This
information
has
been
put
into
a
data
base.
The
data
base
will
serve
as
the
primary
technical
basis
to
evaluate
and
ultimately
establish
the
MACT
standards
for
hazardous
waste
burning
boilers,
HAFs,
and
SARFs.

The
draft
Phase
II
HWC
MACT
database
was
completed
and
released
for
public
comment
in
a
June
27,
2000
Notice
of
Data
Availability
(65
FR
39581).
Responses
from
24
different
commenters
were
received
within
the
60
day
comment
period.
These
are
listed
in
Table
1.
Additionally,
comments
have
been
received
from
2
parties
after
the
close
of
the
comment
period.
Table
2
shows
the
complete
list
of
Phase
II
units
and
identifies
which
for
which
particular
units
comments
were
not
received
on
(as
well
as
all
of
those
for
which
comments
were
received
on).

This
document
contains
the
comments
to
the
draft
database
and
responses
to
these
comments.
Comments
and
responses
have
been
divided
up
into
four
sections.
The
first
three
sections
contain
general
comments
concerning:

Section
2
­­
Request
for
comment
period
due
date
extension.

Section
3
­­
Data
base
gaps.
Identification
of
potential
data
gaps,
including:
new
test
reports
supplied;
permit
limits
and
risk
modeling
parameters;
insufficient
condition
descriptions;
earlier
test
data;
and
sister
unit
data
may
be
incomplete.

Section
4
­­
Data
handling,
calculations,
and
presentation.
Issues
include:
documentation
of
conversions
and
calculations;
estimating
procedures;
nomenclature;
significant
figures
and
rounding
conventions;
feedrate
data
averaging;
SVM/
LVM
emissions;
and
handling
of
non­
detect
measurements.

In
these
sections,
the
actual
comments
are
presented
first,
followed
by
a
response.
The
last
Section
5
contains
all
specific
comments
and
responses
to
the
data
base
contents.
It
is
organized
by
commenter.
Responses
to
most
of
these
specific
requested
changes
are
contained
in
Table
2.
General
responses
are
also
contained
at
the
end
of
each
of
these
of
the
comments.
Some
responses
are
also
included
as
necessary
immediately
after
the
comment;
these
responses
are
highlighted
in
blue
underlined
text.
2.0
Comment
Period
Due
Date
Extension
American
Chemistry
Council
(24)

We
understand
that
some
of
our
members
are
submitting
extensive
comments
on
this
NODA,
addressing
gaps
as
significant
as
tests
that
were
omitted
in
their
entirety
and
errors
in
how
data
were
input
and/
or
used
in
resulting
calculations.
As
discussed
below,
we
are
requesting
that
potentially
large
amount
of
additional
data
be
included
(e.
g.,
permit
limits).
The
extent
of
such
comments,
the
amount
of
detailed
review
required
to
confirm
that
they
have
been
adequately
addressed,
and
the
importance
of
the
data
when
developing
the
emission
standards
all
lead
us
to
the
conclusion
that
the
revised
database
be
made
available
in
another
NODA.
Simply
put,
the
database
will
be
the
foundation
for
the
MACT
standard
and
a
single
60­
day
review
period
will
not
provide
an
adequate
opportunity
to
ensure
it
is
accurate
and
complete.

Similarly,
we
note
that
some
stakeholders
experienced
difficulty
in
accessing
and
interpreting
their
data
from
the
website
used
for
the
NODA.
While
we
worked
to
assist
our
members
access
and
review
of
the
data,
as
did
the
Agency,
we
understand
that
some
stakeholders
may
not
be
able
to
provide
their
data
within
the
60­
day
review
period
provided.
The
database
represents
a
complicated
effort
to
compile
myriad
test
reports
into
a
single
standard
format.
The
methodology
used
to
translate
individual
test
report
format
into
the
database
format
was
not
always
apparent,
and
some
stakeholders
spent
considerable
amounts
of
time
working
to
identify
how
this
translation
was
done.
The
time
period
for
the
review
encompassed
the
vacation
season
for
many
people,
and
review
time
was
in
effect
further
limited.
As
such,
we
respectfully
request
that
comments
that
are
received
after
the
August
28
th
date
be
considered.

Response
The
Phase
II
data
base
design
and
setup
was
as
simple
as
conceivably
possible
to
evaluate
and
review.
The
very
contents
of
the
data
base
directly
and
precisely
document
all
data
entry,
the
source
of
the
data
entry,
data
manipulations,
and
data
calculations.
Specifically,
each
individual
Excel
spreadsheet
cell
contains
(and
documents)
the
exact
calculation
that
was
used.
The
methodology
in
handling
and
manipulating
the
data
is
extremely
straightforward,
clear,
and
elementary.
Calculations
were
limited
to:
unit
conversions,
calculations
of
stack
gas
concentrations
from
stack
gas
mass
emissions
rates,
feedrate
"MTECs",
and
in
a
few
places,
estimates
of
stack
gas
flowrates
from
firing
rates.
Procedures
to
do
these
calculations
were
described
in
the
data
base
report
accompanying
the
NODA
and
Excel
data
sheets.

Each
of
the
reviewers
had
a
limited
number
of
very
simple
and
basic
spreadsheets
to
evaluate

from
in
most
cases,
one
most
recent
CoC
test
report
(which
could
contain
multiple
test
conditions)
for
each
unique
unit.

Comments
received
on
the
NODA
data
base
are
fairly
small
in
number,
consisting
of
mostly
minor
revisions
and
additions.
The
vast
majority
of
the
data
base
remains
unchanged.
Additionally,
only
a
handfull
of
new
test
reports
were
submitted;
and
not
one
facility
in
the
entire
universe
of
units
was
identified
as
missing
from
the
NODA
data
base
(at
the
time
it
was
created).
Thus,
we
object
strongly
to
the
suggestion
that
the
NODA
data
base
had
a
significant
number
of
major
errors
or
major
omissions.

Additionally,
the
revised
data
base
will
be
used
as
the
basis
for
the
future
proposed
Phase
II
MACT
rule.
Any
further
data
errors
can
be
included
as
part
of
response
by
concerned
stakeholders
to
the
proposed
rule
(i.
e.,
this
is
not
the
last
chance
to
comment
on
the
data
base).

Finally,
changes
to
the
Phase
II
data
base
will
be
made
over
the
first
couple
of
weeks
following
the
NODA
comment
period
closure
date.
Further
late
information
that
is
received
during
this
time
(first
couple
weeks)
will
most
likely
be
included.
To
the
highest
degree
possible,
the
data
base
will
be
kept
a
"living"
being,
and
will
continue
be
updated
as
best
as
reasonably
possible.
Of
course,
though,
eventually
the
revised
database
will
at
some
time
be
considered
final
(likely
a
1­
2
months
after
the
comment
period
close).
Comments
received
beyond
this
time
will
be
considered
depending
on
their
anticipated
significance
and
ability
to
be
incorporated
without
adversely
impacting
(impeding)
work
progress.
3.0
Data
Gaps
3.1
New
test
reports
A
few
new
test
reports
were
included
in
the
comment
submissions,
including:


Westvaco
­­
Complete
copy
of
1998
emissions
testing

DuPont
Dow
Elastomers
­­
Recent
trial
burn
and
supplemental
trial
burn
from
HAF
ID
No.
853

Reilly
­­
Recent
mini­
burn
and
trial
burn
retesting
from
Units
No.
735
and
737

Dow
Freeport
­­
Recent
risk
burn
testing
from
HAF
ID
No.
2020

Union
Carbide
­­
Trial
burn
from
new
boilers
just
recently
starting
to
burn
hazardous
waste
in
Texas
City,
TX.

These
reports
have
been
added
to
the
data
base
as
new
test
conditions.

3.2
Permit
limits
and
risk
modeling
parameters
insufficiently
described
American
Chemistry
Council
(24)

Permit
limits
applicable
to
sources
are
often
lacking
from
the
database.
The
"Permitting
Status"
field
in
the
"source"
worksheet
generally
reflected
if
a
source
had
feedrate
limits
(i.
e.,
Tier
I,
Adjusted
Tier
I,
Tier
II,
Tier
III,
or
site­
specific),
yet
these
permit
limits
were
not
cited
in
the
"feed"
worksheet
for
many
cases.
We
believe
that
consideration
of
such
permit
limits
is
necessary
to
fully
assess
the
levels
of
constituents
that
sources
may
be
feeding,
and
request
that
the
database
more
fully
detail
permit
limits.
Specifically,
we
request
that
the
database
be
expanded/
clarified
to
address
the
following:

°
Permitting
Status
–
The
database
does
not
clearly
indicate
if
a
source
is
permitted
or
operating
under
interim
status.
We
suggest
that,
in
addition
to
the
types
of
BIF
Tier
levels
used,
that
the
current
permitting
status
be
clearly
noted.
We
also
request
that
the
general
permitting
status
be
a
field
added
to
spreadsheets
that
summarize
emissions
and
feedrate
data
(e.
g.,
"emissfeed_
sum"
spreadsheet).

°
Permit
Limits
and
Relevant
Basis
–
With
the
exception
of
feedrate
limits
for
some
sources,
the
database
does
not
include
all
of
the
permit
limits
that
should
be
considered
when
developing
the
MACT
standards.
Specifically,
the
database
should
be
expanded
to
include
permit
limits
associated
with
standards
for
DRE
(40
CFR
266.104),
particulate
matter
(40
CFR
266.105),
the
10
BIF
metals
(40
CFR
266.107),
and
HCl/
Cl2
(40
CFR
266.107),
and
other
types
of
permit
limits
that
may
apply.
Options
for
the
DRE
standard
entry
should
be
limited
to
the
following
choices:
DRE
standard,
DRE
waiver,
low
risk
waiver,
CO
Standard,
alternative
CO
standard,
and
other.
For
metals,
the
following
categories
should
be
established:
Tier
I,
Tier
II,
Tier
III,
Adjusted
Tier
I,
and
Adjusted
Tier
I
with
testing.
The
HCl/
Cl2
standard
would
have
these
categories:
Tier
I,
Tier
II,
Tier
III,
and
Adjusted
Tier
I.

°
BIF
Tier
Modeling
Parameters
–
The
BIF
Tier
permit
limits
noted
above
are
based
on
parameters
that
are
generally
not
reflected
in
the
current
database.
As
these
parameters
are
critical
to
understand
the
basis
for
the
associated
permit
limits
as
they
were
developed
for
individual
facilities,
we
request
that
the
database
be
expanded
to
include
them.
Specifically,
we
request
that
the
database
include
the
shortest
distance
of
the
stack
to
the
property
line,
the
distance
of
the
stack
to
their
maximum
exposed
individual
(MEI)
or
the
nearest
maximum
exposed
receptor,
the
terrain
type
for
the
facility
(simple
or
complex),
the
siting
of
the
facility
(rural
or
urban),
type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.),
and
the
dilution
factor
determined
for
the
stack.

Response
Permit
status
­­
Permitting
status
(interim
status
vs
fully
permitted)
is
identified
where
available
in
the
data
base
in
the
source
description
sheet
in
the
"permitting
status"
row.
Note
that
very
little
additional
clarifying
information
was
provided
by
NODA
commenters.
It
is
not
at
this
time
considered
necessary
to
add
this
information
to
the
sheet
that
summarizes
the
emissions
and
feeds.

Permit
limits
­­
All
metals
and
chlorine
feedrate
limits
(as
well
as
the
status
of
Tier
I
vs
Tier
II,
etc.)
will
be
added
to
the
data
base
as
provided.
All
available
feedrate
limits
and
Tier
status
were
included
in
the
data
base
as
released
through
the
NODA
at
the
end
of
the
feedrate
sheet.
Permitting
status
related
to
DRE,
PM,
and
CO
was
also
included
as
available
in
the
source
description
sheet.
These
will
be
updated
as
requested
by
the
commenters
(although,
again,
very
little
new
information
was
supplied).
It
is
not
necessary
to
obtain
further
data
of
this
type.

Risk
modeling
parameters
­­
Information
on
risk­
based
factors
such
as
stack
distances
to
property
lines
and
maximum
exposed
individuals,
terrain
types,
and
dispersion
modeling
and
dilution
factors,
will
be
held
on
to
as
supplied,
but
will
not
be
added
to
the
data
base
at
this
time.
For
the
near
term
work,
this
type
of
information
is
not
expected
to
be
needed.
Additionally,
it
will
not
be
added
because
very
little
new
information
of
this
type
was
provided
by
commenters.
At
a
later
date,
the
information
will
be
appropriately
considered
in
the
use
of
any
risk
assessments
performed
as
part
of
the
Phase
II
rulemaking.
Chance
to
comment
further
on
future
risk
assessment
procedures
and
inputs
will
be
likely
provided
during
the
Phase
II
rulemaking.

3.3
Insufficient
condition
descriptions
and
spike
detail
American
Chemistry
Council
(24)

In
some
cases,
the
data
base
does
not
clearly
indicate
the
purpose
for
the
test
as
reported
in
the
"Condition
Descr"
field.
For
example,
it
is
not
readily
apparent
if
a
given
test
was
performed
for
carbon
monoxide
testing
or
metals
removal
testing.
When
establishing
a
standard
for
metals,
for
example,
it
would
not
be
appropriate
to
consider
low
levels
of
metals
in
a
test
that
was
not
intended
to
reflect
the
full
range
of
metal
concentrations
that
could
be
burned.
Similarly,
it
is
not
apparent
which
source
tests
"spiked"
constituents
levels
to
capture
the
high
end
of
feedrates
expected
and
which
did
not
do
so.
We
request
that
the
descriptions
of
the
test
conditions
be
more
detailed,
and
that
it
be
noted
if
a
given
constituent
was
"spiked"
during
testing.
Omission
of
such
parameters
may
result
in
an
emission
standard
developed
off
of
low­
end
values
that
are
not
representative
of
higher
levels
at
which
the
source
will
actually
operate.

Merck
(9)

Testing
Conditions
Description
EPA
has
collected
data
in
order
to
develop
Phase
II
Maximum
Achievable
Control
Technology
(MACT)
standards
for
hazardous
waste
combustors
(HWCs).
This
data
was
obtained
from
information
already
submitted
to
EPA
regional
offices
or
State
agencies
and
originated
from
many
different
sources,
including
certifications
of
compliance
(CoC),
trial
burns,
and
risk
burn
testing.
Each
of
these
tests
may
have
required
different
testing
conditions
and
therefore
may
have
different
feed
rates
or
emissions.
Although
the
EPA
database
provides
a
field
for
condition
descriptions,
Merck
feels
that
additional
detail
may
be
needed
to
highlight
unique
testing
descriptions.
For
example,
some
tests
may
not
have
been
performed
to
measure
system
removal
efficiency
(SRE)
and,
in
these
cases,
constituents
may
not
have
been
spiked
in
the
feedstreams
and
therefore
may
not
be
representative
of
the
full
range
of
waste
feed
concentrations
during
typical
operations.
Because
in
other
rules
EPA
has
used
feedrate
data
to
calculate
maximum
theoretical
emissions
concentration
(MTEC),
we
are
concerned
that
using
a
feed
concentration
that
has
not
been
spiked
may
result
in
an
unusually
low
MTEC
that
is
not
achievable
by
other
sources.
Comparing
an
MTEC
derived
from
spiked
waste
and
an
MTEC
derived
from
waste
that
has
not
been
spiked,
will
result
in
inconsistencies.
For
this
reason,
Merck
feels
the
database
should
clearly
indicate
whether
or
not
the
feed
waste
has
been
spiked.

Response
The
NODA
data
base
information
was
extracted
from
the
compliance
test
reports
that
were
obtained
from
the
various
state
and
EPA
agencies.
Many
times
these
test
reports
were
incomplete,
vague,
or
did
not
contain
the
required
information
to
fully
described
the
test
condition.
The
purpose
of
releasing
the
data
base
for
public
comment
was
to
encourage
owners
and
operators
to
review
the
information
in
the
data
base
to
ensure
that
it
is
complete
and
accurate,
and
to
provide
additional
information
as
appropriate.
All
of
the
clarifications
and
additional
information
received
from
commenters
will
be
reviewed
and
included
as
appropriate
in
the
revised
data
base.

Additionally,
note
that
EPA
suggests,
in
direct
opposition
to
the
commenters,
that
the
testing
intentions
of
the
vast
majority
of
each
of
the
test
conditions
in
the
NODA
data
base
were
in
fact
very
well
and
clearly
detailed.
Almost
all
test
conditions
are
identified
as
from
CoC
permit
limit
setting
conditions,
or
risk
burn
conditions.
Further
description
of
each
test
condition
details
the
testing
purpose,
for
example
setting
minimum
temperature
limit,
maximum
waste
feedrate,
etc.
There
is
a
specific
row
in
the
data
base
devoted
to
each
test
condition
which
is
intended
to
allow
and
provide
for
a
detailed
description
of
the
purpose
of
the
testing
condition.
As
an
indicator
of
the
completeness
of
the
NODA
data
base,
very
few
comments
very
provided
in
objection
to
the
NODA
data
base
description
of
the
test
condition.

In
regards
to
"spiking",
each
different
feedstream
is
clearly
differentiated,
including
whether
it
is
an
actual
waste,
surrogate
waste,
spiked
stream,
fossil
fuel,
etc.
Additionally,
the
proportion
of
total
feed
due
to
spiking
streams
is
included
in
the
summary
sheet,
indicating
how
much
spiking
took
place.

3.4
Earlier
test
data
should
be
considered
American
Chemistry
Council
(24)

The
Agency
notes
that
it
intends
to
base
the
standards
off
of
the
most
recent
certification
of
compliance
(CoC)
for
each
facility.
However,
we
note
that
there
may
be
instances
where
it
is
appropriate
to
consider
earlier
tests
if
the
most
recent
test
is
not
reflective
of
upper
bounds
of
operation,
and/
or
if
there
are
data
gaps
in
the
most
recent
test.
We
understand
that
some
operators
will
be
submitting
such
previous
tests
for
use
when
setting
the
standards,
and
we
request
that
the
Agency
incorporate
such
test
data
into
the
database.

Response
Emissions
data
from
the
most
recent
compliance
test
best
represent
the
current
emissions
performance
of
a
source
because
current
operating
limits
are
based
on
the
most
recent
compliance
test.
Also,
the
most
recent
compliance
test
information
best
represents
(the
upper
limits
on)
current
operating
practices.
This
is
consistent
and
supported
by
stakeholder
comments
to
the
HWC
MACT
Phase
I
rulemaking.
Thus,
additional
testing
data
provided
in
response
to
the
NODA
will
be
included
in
the
data
base
only
when
the
data
address
data
gaps
(for
example,
where
PCDD/
PCDF
measurements
were
taken
in
earlier
testing,
but
not
in
most
recent
compliance
testing)
or
when
it
is
clearly
being
used
for
setting
operational
limits
apart
from,
or
in
addition
to,
the
most
recent
compliance
testing
program.

As
a
practical
matter,
this
is
actually
a
moot
point,
and
has
no
relevance
to
the
data
base
revisions.
This
is
because
there
were
no
"older"
test
reports
that
were
actually
submitted
and
requested
to
be
entered
to
supersede
or
replace
newer
or
other
data
in
the
NODA
data
base.
Additionally,
commenters
did
not
identify
any
older
testing
conditions
in
the
data
base
that
should
be
used
to
replace
newer
data.
In
fact,
the
very
opposite
occurred;
one
or
two
commenters
suggested
that
older
data
contained
in
the
NODA
data
base
be
removed
and
not
considered.
As
discussed
above,
the
few
new
test
reports
that
were
supplied
by
commenters
have
been
added
to
the
data
base.

3.5
Sister
unit
data
may
be
incomplete
American
Chemistry
Council
(24)

As
noted
in
the
Federal
Register
notice,
the
database
relies
on
"data
in
lieu
of"
testing
for
38
of
the
153
sources
represented
in
the
database.
Some
of
our
members
with
multiple
units
have
employed
data
in
lieu
of
to
reduce
testing
burden
and
associated
emissions
from
testing.
Some
members
have
alternated
testing
between
"sister"
units.
For
example,
one
boiler
would
have
been
tested
initially,
and
the
second
(previously
untested)
boiler
would
have
been
tested
in
the
next
round
of
testing.
We
understand
that
the
most
recent
test
may
not
have
tested
for
certain
parameters,
instead
relying
on
the
data
from
the
earlier
test(
s).
It
may
therefore
be
necessary,
in
some
cases,
to
consider
earlier
tests
to
ensure
that
a
full
set
of
data
for
the
sister
units
is
available.
We
request
that
the
Agency
incorporate
such
test
data
into
the
database.

Response
As
indicated
by
commenters,
any
additional
"sister"
unit
data
which
may
provide
additional
information
on
unit
performance
will
be
added
to
the
data
base
under
the
current
ID
No.
which
represents
the
sister
unit.
Older
data
from
earlier
testing
periods
that
is
representative
of
any
of
the
Phase
II
units
(sister
or
non­
sister
units)
will
be
included
in
the
data
base
as
supplied
and
requested
by
Phase
II
unit
commenters,
as
mentioned
in
the
previous
comment.
4.0
Data
Handling,
Calculations,
and
Presentation
4.1
Documentation
of
conversions
and
calculations
American
Chemistry
Council
(24)

The
spreadsheets
used
to
compile
the
data
and
convert
them
to
consistent
units
and
format
employ
a
range
of
calculations.
While
the
basis
for
the
underlying
calculations
are
surely
clear
to
the
persons
who
developed
the
spreadsheets,
it
is
not
obvious
to
persons
reviewing
the
database.
Particularly
when
original
source
test
data
have
been
converted
to
a
different
basis,
it
may
not
be
clear
to
the
reviewer
how
the
conversion
was
done,
or
what
the
units
are
for
the
conversion
factors
cited.
The
conversion
from
waste
feedrates
to
MTEC
can
be
particularly
confusing.

In
order
to
maximize
clarity
and
minimize
the
extent
to
which
the
Agency
needs
to
spend
educating
reviewers
as
to
how
calculations
were
performed,
we
recommend
that
sample
calculations
and
notes
be
included
within
the
spreadsheet
describing
the
basis
fro
the
calculations
and
conversions
to
consistent
units.
The
lack
of
such
documentation
contributed
to
confusion
during
review
of
this
NODA,
and
would
hinder
review
of
the
subsequent
NODA
that
we
are
recommending.

Response
As
mentioned
above
in
Section
2,
calculations
that
are
made
in
the
data
base
are
used
for
unit
conversions,
determination
of
feedrate
MTECs,
and
estimations
of
flowrates
and
firing
rates.
The
specific
numbers,
formulas,
and
cells
that
are
used
in
the
calculations
are
clearly
contained
and
documented
in
the
Excel
spreadsheets.
The
majority
of
calculations
are
very
simple
in
nature,
again
involving
simple
unit
conversations
and
determination
of
concentrations
rates
from
mass
feedrates.
These
are
all
documented
by
the
very
contents
of
each
individual
Excel
cell
(i.
e.,
formulas
and
calculations
used
are
shown
clearly
in
the
Excel
data
cells).
The
calculation
of
feedrate
MTECs
through
the
normalization
of
mass
feedrates
by
stack
gas
flowrates
and
oxygen
conversions
is
described
in
detail
in
the
data
base
report
and
is
the
exact
same
procedure
used
in
the
Phase
I
HWC
MACT
rule
(which
is
very
familiar
to
most
all
of
the
Phase
II
companies,
and
certainly
to
the
ACC).

4.2
Inconsistent
level
of
detail
for
test
conditions
American
Chemistry
Council
(24)

Even
within
the
same
test,
the
level
of
detail
between
specific
test
conditions
varied.
For
example,
one
test
condition
only
noted
general
information
such
as
liquid
feed
rate
and
ash
content.
Another
test
condition
for
the
same
source
provided
very
detailed
descriptions.
The
detailed
level
of
information
should
have
been
used
for
all
cases,
as
it
may
be
important
in
discerning
how
to
consider
particular
data
when
establishing
the
MACT
standards.

Response
All
data
that
were
contained
in
the
test
report,
and
considered
relevant,
were
included
in
the
data
base.
The
intent
of
the
NODA
is
to
ensure
that
the
data
base
is
complete
and
accurate,
and
to
encourage
owners
and
operators
to
provide
additional
data
and
documentation
as
necessary
to
fully
clarify
the
purposes
of
the
testing
and
all
associated
data
and
measurements
taken.

4.3
Stack
gas
flowrates
should
not
be
estimated
American
Chemistry
Council
(24)

Stack
gas
flowrates
in
some
cases
used
the
actual
values
from
the
test,
yet
others
calculated
a
stack
gas
flowrate
(based
on
heat
input),
rather
than
using
the
value
from
the
test
report.
We
believe
that
the
flowrate
should
always
be
based
on
the
actual
stack
test
values,
rather
than
estimates
such
as
heat
input.

Response
We
strongly
agree
with
the
commenter
that
the
preference
is
to
use
stack
gas
flowrates
from
actual
measurements.
Only
as
a
last
resort
in
a
few
cases,
where
stack
gas
flowrates
were
either
not
taken
or
not
available
in
the
Agency's
copy
of
the
test
report,
were
flowrates
estimated
from
heat
input
firing
rates.
Any
actual
flowrates
that
can
be
provided
will
be
used
in
place
of
estimated
values.

However,
estimating
stack
gas
flowrates
based
on
firing
rates
and
an
"F­
factor"
approach
as
done
in
the
NODA
is
a
fully
accepted
and
conventional
approach,
and
is,
in
fact,
used
and
allowable
under
current
EPA
rules
for
various
types
of
fuel
combustion
systems.
Thus,
in
the
very
few
remaining
places
where
we
continue
to
not
have
stack
gas
flowrate
data,
F­
factor
type
estimates
are
appropriate
and
will
continue
to
be
used
to
provide
stack
gas
flowrates.

4.4
Supplemental
fuel
nomenclature
unclear
American
Chemistry
Council
(24)

Fuels
used
along
with
hazardous
waste
(e.
g.,
natural
gas)
are
variously
reported
as
"auxiliary"
and
"supplementary"
fuels.
Members
have
raised
questions
as
to
the
nomenclature;
some
operators
generally
refer
to
their
non­
hazardous
fuel
source
as
a
"primary"
fuel.
In
such
cases,
an
"auxiliary"
or
"supplemental"
fuel
would
refer
to
a
back­
up
fuel
source
such
as
No.
2
fuel
oil,
to
be
used
in
the
event
that
the
"primary"
fuel
of
natural
gas
is
not
available.
The
different
nomenclatures
used
for
fuel
types
may
have
resulted
in
inaccuracies
in
the
database.
This
possibility
should
be
considered
when
developing
standards
that
differ
based
on
fuel
type.

Response
The
data
base
report
clearly
identifies
the
"supplemental
fuels"
field
in
the
data
base
as
any
....
"auxiliary
fuel
(including
non­
hazardous
waste)
co­
fired
with
hazardous
waste.
This
is
typically
natural
gas.
May
also
include
coal,
fuel
oil,
process
gas,
or
any
other
non­
hazardous
waste
fuels....
"
We
apologize
for
the
confusion.
Please
consider
this
data
base
field
name
to
refer
to
any
non­
hazardous
waste
fuels
as
"Other
(non
HW)
Fuels"
instead
of
as
"auxiliary"
or
"supplementary"
fuels.
We
do
not
believe
there
was
any
confusion
in
the
commenters'
comments
to
the
data
base.
In
fact,
a
couple
of
revisions/
additions
to
this
field
were
pointed
out.
We
believe
the
data
base
is
highly
accurate
at
identifying
the
type
of
all
feeds
and
fuels
to
the
Phase
II
units.

4.5
Significant
figures
and
rounding
conventions
American
Chemistry
Council
(24)

The
spreadsheets
provided
in
the
database
employ
varying
numbers
of
significant
figures,
even
for
the
same
parameter.
For
example,
the
conversion
from
grams
to
pounds
is
presented
as
454
and
453.6.
Similarly,
calculations
employing
percent
oxygen
in
ambient
air
alternatively
use
20.9
and
21.
In
other
cases,
test
data
for
some
parameters
are
reported
with
no
decimal
points,
yet
the
average
value
calculated
is
reported
to
one
decimal
point
rather
than
rounding.
We
suggest
that
significant
figures
and
rounding
be
used
consistently,
as
appropriate
to
the
data.

General
Electric
(5)

While
reviewing
the
three
GE
boilers,
we
noted
that
the
use
of
significant
figures
is
inconsistent.
One
example
is
using
"21"
for
the
concentration
(in
%)
of
atmospheric
oxygen
instead
of
"20.9".
Another
is
the
use,
in
different
places,
of
"454
grams/
pound"
and
"453.6
grams/
pound"
as
a
conversion
factor.
GE
urges
EPA
to
confirm
that
the
significant
figures
used
are
appropriate
to
the
data.

Response
The
level
of
significant
figures
used
in
the
data
base
manipulations
is
considered
appropriate.
For
the
commenters'
example,
the
use
of
the
slightly
less
accurate
values
for
unit
conversions
(454
g/
hr
vs
453.6)
is
more
than
sufficient,
in
particular
considering
the
accuracy
of
the
stack
gas
measurements
themselves.
That
is
to
say,
the
difference
(and
impact)
between
the
use
of
454
and
453.6
or
is
not
significant,
again
especially
within
the
accuracy
of
the
stack
gas
measurements.
In
fact,
numbers
with
these
types
and
ranges
of
significant
figures
are
typically
and
conventionally
used
in
the
raw
data
calculations
throughout
the
test
reports
for
which
the
data
has
been
pulled.
Generally,
numbers
with
at
least
3
significant
figures
are
used.

For
oxygen
conversions,
the
use
of
21%
is
standard
conventional
practice
that
is
used
in
the
vast
majority
of
calculations
in
the
data
base.
EPA
will
make
an
attempt
to
ensure
that
calculations
are
made
using
the
21%
level
instead
of
20.9%.
Although,
note
for
the
majority
of
cases
where
the
oxygen
level
in
the
stack
gas
ranges
from
2­
8%,
the
use
of
21%
vs
20.9%
produces
no
significant
difference.

Any
appearance
of
"rounding"
is
only
as
a
function
of
the
choice
of
significant
figures
for
which
the
numbers
are
displayed.
That
is
to
say,
when
storing
and
transferring
the
data,
and
making
all
intermediate
and
final
calculations,
rounding
is
not
used.
Rounding
only
occurs
when
the
final
answer
is
displayed.
Depending
on
the
magnitude
of
the
number,
2
or
3
significant
figures
are
shown,
and
is
considered
adequate
and
appropriate
(and
again
has
no
bearing,
since
the
value
in
the
data
base
is
being
stored
to
many
more
significant
figures
than
that
being
shown).

4.6
Averaging
feedrate
data
is
inappropriate
American
Chemistry
Council
(24)

Waste
feedrate
data
for
each
of
the
three
runs
are
typically
shown
in
detail
for
each
test
run.
However,
when
these
data
are
later
used
to
calculate
the
amount
of
a
given
constituent
fed
during
the
test,
the
calculations
for
each
run
are
based
on
the
average
of
the
waste
feedrates
–
not
the
waste
feedrate
for
that
particular
run.
We
recommend
that
these
values
not
be
averaged,
as
it
is
further
diminishes
the
ability
to
discern
the
variability
between
runs.

Merck
(9)

II.
Number
of
Data
Points
Used
The
emissions
data
included
in
EPA's
database
is
presented
with
a
data
point
for
each
run.
Presenting
data
for
each
run
is
a
good
method
to
determine
if
there
are
any
anomalies
in
the
data.
It
is
assumed
that
this
is
the
reason
that
emissions
data
for
all
of
the
runs
has
been
presented.
In
contrast,
the
feedrate
data
has
been
averaged
and
consequently
gives
only
one
data
point
encompassing
all
runs.
Averaging
the
data
for
the
feedstreams
could
mask
feed
differences
between
runs
and/
or
data
quality
issues.
This
particularly
presents
a
problem
because
MTECs
are
being
derived
from
feedrate
values.
In
addition,
it
is
inconsistent
with
the
way
the
emissions
data
is
presented.
Merck
feels
that
feedstream
and
the
emissions
data
should
be
presented
for
each
run
included
in
the
database.

Response
Although
feedrate
levels
during
different
test
runs
within
the
same
test
condition
typically
exhibit
little
variability
(e.
g.,
because
the
same
batch
of
waste
or
feed
is
being
used,
and/
or
a
single
analysis
of
the
waste
is
used
to
represent
each
of
the
different
test
conditions
and,
thus,
the
feedrate
of
the
waste
is
the
only
variable
effecting
the
feedrate
of
waste
constituents)
we
agree
that,
if
constituent
feedrate
is
an
integral
consideration
in
developing
the
MACT
standards,
evaluating
run
feedrate
variance
may
be
appropriate.
Consequently,
we
have
re­
reviewed
the
test
reports
to
extract
constituent
(i.
e.,
metals,
chlorine,
ash)
feedrate
data
by
run
and
included
these
data
in
the
data
base.

We
don't
understand
the
intent
of
the
first
commenters
first
two
sentences
(if
they
are
referring
to
the
NODA
data
base,
or
the
reporting
practices
in
the
actual
test
reports).
However,
in
an
attempt
to
clarify,
in
the
NODA
data
base,
the
reported
test
condition
feedrate
averages
are
not
intended
to
represent
the
results
of
individual
measurements
for
each
run.
4.7
SVM/
LVM
emissions
must
consider
sampling
train
front­
half
and
back­
half
nondetect
status
American
Chemistry
Council
(24)

Our
members'
review
of
the
test
data
indicates
that
the
methodology
employed
to
estimate
the
concentration
of
constituents
in
emitted
stack
gas
underestimates
the
true
levels.

Metals
stack
sampling
methods
employ
two
sample
collection
areas,
a
"front­
half"
and
backhalf
of
the
multi­
metals
sampling
train.
The
gas
sampled
is
pulled
through
both
collection
areas,
generating
two
sample
fractions
that
are
analyzed
separately.

In
the
NODA,
SVM
emissions
were
calculated
by
summing
the
emissions
of
cadmium
and
lead.
LVM
emissions
were
calculated
by
summing
the
emissions
of
arsenic,
beryllium
and
chromium.
In
both
cases,
if
the
emission
level
of
a
specific
metal
was
reported
as
not
detected
(ND),
the
Agency
used
one­
half
the
detection
limit
for
that
metal
when
calculating
the
emissions
for
the
SVM
or
LVM
category.

In
the
NODA,
the
total
emission
rate
for
a
metal
was
reported
as
ND
if
either
the
front
or
back
half
results
were
ND.
While
this
convention
may
have
been
used
in
originally
reporting
the
source
test
data,
we
believe
that
it
is
inappropriate
for
the
purposes
of
calculating
SVM
and
LVM
emissions
rates
that
may
be
used
when
setting
the
MACT
standards,
because
it
understates
the
actual
SVM
and
LVM
emission
rates.
In
such
cases,
the
actual
detected
value
in
sample
fraction
is
inappropriately
discounted
solely
because
the
other
fraction
was
ND.
Our
members'
analyses
indicate
that
this
impact
may
be
considerable
in
some
cases,
reducing
the
total
level
of
emissions
reported
by
nearly
50
percent.
We
understand
that
American
Chemistry
Council
member
Eastman
Chemical
is
submitting
a
detailed
example
of
this
impact
in
response
to
the
NODA.

We
recommend
that,
when
there
is
a
non­
detect
value
in
one
of
the
two
sample
collection
fractions,
that
the
convention
of
treating
NDs
as
present
at
one­
half
the
detection
level
be
applied
to
each
half
of
the
sampling
train
individually,
rather
than
to
the
summed
front
and
back
half
results.
The
resulting
value
is
clearly
a
more
accurate
representation
of
emissions
from
a
given
source,
and
is
important
in
ensuring
that
the
MACT
standards
to
be
developed
are
achievable.
We
also
suggest
that
this
change
be
clearly
reported
as
part
of
the
second
NODA
we
are
recommending,
as
the
impact
of
this
methodology
may
not
have
been
recognized
during
review
of
the
NODA
if
reviewers
did
not
have
a
thorough
understanding
of
how
these
values
might
be
used
when
developing
the
MACT
standards.

Eastman
(11)

As
a
general
comment,
Eastman
suggests
that
EPA
examine
the
way
that
it
calculates
the
semivolatile
metal
(SVM)
and
low­
volatile
metal
(LVM)
emissions.
Eastman
believes
that
the
calculation
method
used
in
the
NODA
understates
actual
SVM
and
LVM
emissions.
In
the
NODA,
SVM
emissions
were
calculated
by
summing
the
emissions
of
cadmium
and
lead.
LVM
emissions
were
calculated
by
summing
the
emissions
of
arsenic,
beryllium
and
chromium.
In
both
cases,
if
the
emission
level
of
a
specific
metal
was
reported
as
not
detected
(ND),
the
agency
used
one­
half
the
detection
limit
for
that
metal.
The
emission
rate
of
each
specific
metal
is
determined
by
analyzing
samples
collected
in
the
front
half
and
back
half
of
the
multi­
metals
sampling
tram.
In
the
NODA,
the
total
emission
rate
was
reported
as
ND
if
either
the
front
or
back
half
results
were
ND.
While
this
convention
is
not
uncommon,
Eastman
believes
that
it
is
inappropriate
for
the
purposes
of
calculating
SVM
and
LVM
emissions
in
that
it
understates
the
actual
SVM
and
LVM
emission
rates.
For
example,
consider
the
following
example
based
on
actual
reported
SVM
results
for
Eastman's
Boiler
No.
20
(1011C1)
Run
1.

Analytical
Results
Metal
Front
Half
Fraction
µg
Back
Half
Fraction
µg
Total
Fraction
µg
Sample
Volume
(dscf)
%
O2
Emission
Rate*
(µg/
dscm)

Pb
99.98
<5.23
<105.2
39.76
12.1
<146.9
Cd
3.90
1.85
5.75
39.76
12.1
8.0
*Corrected
to
7%
O2
SVM
Calculation
Per
the
NODA:

SVM
=
(146.9
÷
2)
+
8.0
=
81.5
µg/
dscm
In
this
example,
the
total
emissions
of
Pb
were
reported
as
ND
because
the
level
of
Pb
in
the
backhalf
sample
was
less
than
the
detection
level.
Thus,
following
EPA's
convention
of
counting
NDs
as
one­
half
the
detection
level,
only
one­
half
of
the
total
Pb
emission
rate
was
used
to
calculate
SVM
emissions,
yielding
a
SVM
emission
rate
for
this
run
of
81.5
µg/
dscm.
It
seems
illogical
to
report
the
total
SVM
emission
rate
for
Run
1
as
81.5
µg/
dscm
when
99.98
µg
of
lead
and
8.0
µg
of
CD
were
actually
measured
as
being
present
in
the
stack
sampling
train.
These
two
measured
quantities,
added
together,
equate
to
a
stack
concentration
of
148.3
µg/
dscm.
It
is
apparent
that
EPA's
application
of
its
1/
2
ND
convention
to
the
total
reported
sample
train
fractions
understates
the
actual
quantity
of
SVM
metals
emitted
from
the
stack.

Eastman
suggests
that
EPA
modify
its
method
of
treating
NDs,
for
purposes
of
calculating
SVM
and
LVM
emission
rates,
to
more
accurately
reflect
the
actual
emission
rates
experienced
during
the
test
runs.
Eastman
believes
that
this
can
be
accomplished
by
applying
the
1/
2
ND
rule
to
each
half
of
the
sampling
train
individually,
rather
than
to
the
summed
front
and
back
half
results.
For
Eastman's
Boiler
No.
20
(1011C1)
Run
1,
SVM
emissions
would
be
calculated
as
follows:

Analytical
Results
Metal
Front
Half
Fraction
µg
Back
Half
Fraction
µg
Total
Fraction
µg
Sample
Volume
(dscf)
%
O2
Emission
Rate*
(µg/
dscm)

Pb
99.98
2.62**
102.6
39.76
12.1
143.9
Cd
3.90
1.85
5.75
39.76
12.1
8.0
*Corrected
to
7%
O2
**
Measured
value
was
below
detection
limit.
Reported
value
equals
1/
2
detection
limit.

SVM
Calculation:

SVM
=
143.9
+
8.0
=
151.9
µg/
dscm
Presented
in
Table
1
is
a
comparison
of
SVM
and
LVM
emission
rates
for
Eastman's
four
boilers
using
the
two
calculation
methods
discussed
above.
Supporting
data
and
calculations,
using
Eastman's
proposed
method,
are
presented
in
Attachment
2.

TABLE
1
Comparison
of
EPA
and
Eastman
Results
for
Calculating
SVM
and
LVM
Emission
Rates
Boiler
ID
Run
No.
SVM
Emission
Rate
(µg/
dscm
@
7%
O2)
LVM
Emission
Rate
(µg/
dscm
@
7%
O2)

EPA
Result
Eastman
Result
EPA
Result
Eastman
Result
Phase
II
No.
1011
1
2
3
81.5
83.8
89.2
152.0
164.4
174.7
90.2
112.9
153.7
92.6
129.6
174.2
Phase
II
No.
1012
2
3
4
34.2
31.0
43.4
64.3
59.0
83.7
26.9
38.6
31.2
37.7
63.6
53.9
Phase
II
No.
719
2
3
156.2
47.8
156.0
92.6
254.3
115.6
257.9
170.3
Phase
II
No.
717
1
2
3
18.0
40.6
14.9
28.4
42.2
23.2
14.9
14.6
11.6
21.1
15.8
12.0
Response
The
NODA,
as
done
in
all
of
the
HWC
MACT
Phase
I
work,
assumes
that
the
standard
convention
for
handling
and
reporting
metals
sampling
train
back
and
front
half
measurements
was
being
used
in
the
CoC
and
trial
burn
emissions
test
reports.
For
the
standard
convention,
as
the
commenter
and
EPA
supports,
when
either
the
front
half
or
back
half
is
detected,
the
total
value
is
reported
as
fully
detected,
and
as
the
sum
of
the
detected
and
non­
detected
front
half
and
back
half
values.
Only
in
cases
where
both
the
front
and
back
half
were
non­
detect
would
the
total
value
be
reported
as
non­
detect.

Again,
it
was
assumed
that
this
standard
data
handling
and
reporting
convention
for
metals
sampling
trains
results
was
used
when
metals
emissions
levels
were
reported
in
the
CoCs.
EPA
continues
to
believe
that
this
convention
was
used
for
the
vast
majority
of
the
reported
metals
stack
gas
emissions
data.
We
did
not
(and
will
not)
go
back
to
the
raw
data
to
determine
the
detection
status
of
the
front
and
back
parts
of
the
metals
sampling
train,
in
particular
since
in
many
cases
this
type
of
data
is
not
contained
in
the
testing
report
copy.
Where
it
is
documented
by
commenters
or
suspected
that
this
standard
convention
was
not
used
(in
particular
where
a
suspiciously
high
non­
detect
level
is
reported),
the
data
will
be
changed
to
conform
with
the
standard
convention
(e.
g.,
the
non­
detects
in
the
NODA
data
base
will
be
changed
to
detects
where
pointed
out
by
the
Eastman
facility).

Note
that
the
Eastman
facility
was
the
only
commenter
that
pointed
this
problem
out
with
the
metals
emissions
data.
Again,
for
this
facility,
we
will
report
the
metals
data
as
Eastman
suggests
based
on
standard
conventions
on
handling
and
reported
back
half
and
front
half
nondetects
Again,
however,
because
this
type
of
comment
was
received
from
only
one
source,
it
would
strongly
appear
this
problem
is
not
wide
spread
or
common
throughout
the
data
base,
and
instead
confined
to
only
this
single
source.
This
further
supports
the
decision
to
not
make
the
difficult
and
likely
unsuccessful
attempt
of
going
back
through
all
data
reports
and
locating
back
half
and
front
half
detection
status
for
metals.

4.8
Feedrate
non­
detect
calculation
unclear
American
Chemistry
Council
(24)

The
database
includes
calculations
of
maximum
theoretical
emissions
concentration
(MTEC)
for
metals,
chlorine,
and
ash.
We
understand
that
the
methodology
for
considering
constituents
that
were
not
detected
(ND)
when
calculating
the
MTEC
is
to
assume
that
the
constituent
is
present
at
one­
half
the
detection
level.
This
methodology
appears
to
have
been
used
in
the
"feed"
worksheets
when
calculating
the
semivolatile
metals
(SVM)
(combined
lead
and
cadmium)
and
low
volatility
metals
(LVM)
(combined
arsenic,
beryllium,
and
chrome).

It
is
unclear,
however,
what
the
approach
was
for
calculating
the
average
feedrate
for
a
test
condition
when
the
concentrations
of
a
constituent
varied
from
ND
to
detectable
levels
over
the
three
test
runs.
If
all
three
were
ND,
those
samples
would
be
reported
as
"ND"
at
the
average
of
the
three
feedrate
levels.
If
the
constituent
were
detected
in
all
three
runs,
they
would
be
reported
as
detected
at
the
average
of
the
three
levels
reported.
If,
however,
a
constituent
was
only
detected
during
two
of
the
three
runs,
however,
the
methodology
used
by
the
Agency
is
unclear.

Source
#
1018,
condition
12
(1018C12),
for
example,
detected
barium
in
the
feed
in
only
one
of
the
three
runs
(at
18
g/
hr),
while
the
two
other
runs
had
a
barium
feedrate
of
less
than
5.9
g/
hr.
The
feedrate
is
calculated
in
the
spreadsheet
as
non­
detect,
with
the
average
feedrate
of
15.9
g/
hr,
as
calculated
by
the
average
of
5.9,
5.9,
and
18
X
2.
It
is
unclear
why
the
one
detected
level
(18
g/
hr)
was
multiplied
by
2
in
the
calculation,
and
why
the
average
level
is
reported
as
"non­
detect"
when
one
of
the
runs
clearly
had
detectable
levels.

The
same
approach
of
doubling
one
of
the
feedrate
levels
prior
to
averaging
was
apparently
also
used
for
mercury
for
this
source,
yet
we
understand
that
mercury
was
ND
in
all
3
runs;
the
proper
average
would
be
ND
at
the
ND
feedrate.
In
this
case,
there
appears
to
be
a
basic
error
in
the
calculations.

We
do
not
understand
the
basis
for
this
method
of
calculating
average
feedrates
when
levels
constituents
were
not
detected,
and
request
that
the
Agency
explain
the
basis
for
it
within
the
database.

Ticona
(16)

Condition
1018C12
In
regards
to
the
liquid
waste
stream
metals'
feedrates
during
Condition
1018C12,
the
feed
rate
for
barium,
mercury,
and
thallium
are
incorrect
as
reported
in
the
NODA
database.
The
barium
feedrate
should
be
10
grams
per
hour
instead
of
the
reported
15.933
grams
per
hour.
The
mercury
feedrate
should
be
0.2
grams
per
hour
instead
of
the
reported
0.267
grams
per
hour.
Finally,
for
thallium,
the,
feedrate
reported
in
the
NODA
database
is
based
on
a
non­
detect
concentration
and
hence
a
"nd"
should
be
added
prior
to
the
reported
concentration
of
24
grams
per
hour.
These
feedrates
may
be
found
in
the
1998
Trial
Burn/
Risk
Burn
Plan.
As
a
convenience,
please
reference:
Table
5­
2
Metals,
Total
Chloride,
and
Ash
Content
in
Liquid
Waste
Fuel
in
the
Appendix
entitled
Condition
1018C12.

In
regards
to
the
ash
modifier
metals'
feedrates
during
Condition
1018C12,
the
feed
rate
for
antimony
is
incorrect
as
reported
in
the
NODA
database.
The
antimony
feedrate
should
be
0.004
grams
per
hour
instead
of
the
blank
space
reported
in
the
NODA
database.
This
feedrate
is
based
on
a
non­
detect
concentration
and
hence
a
"nd"
should
be
added
prior
to
the
0.004
grams
per
hour.
This
feedrate
may
be
found
in
the
1998
Trial
Burn/
Risk
Burn
Plan.
As
a
convenience,
please
reference:
Table
5­
10
Ash,
Metal,
and
Total
Chloride
Analysis
of
the
Ash
Modifier
in
the
Appendix
entitled
Condition
1018C12.

In
addition,
the
NODA
database
is
inconsistent
in
the
manner
that
the
constituent
feed
rates
are
averaged
and/
or
recorded
in
the
Feedstreams
worksheet.
For
example,
in
the
case
of
barium
in
the
liquid
waste
stream
for
Condition
1018C12,
its
average
was
computed
by
placing
the
spreadsheet
average
formula
in
the
corresponding
cell
and
averaging
the
following
values,
5.9
g/
hr,
18
X
2
g/
hr,
and
5.9
g/
hr.
This
condition
consisted
of
three
runs
with
the
first
run
resulting
in
a
barium
feedrate
of
less
than
5.9
g/
hr,
the
second
run
resulting
in
a
barium
feedrate
of
18
g/
hr,
and
the
third
run
resulting
in
a
barium
feedrate
of
less
than
5.9
g/
hr.
It
is
unclear
to
Ticona
why
the
feedrate
for
the
second
run
is
multiplied
by
a
factor
of
2.
As
discussed
above,
the
barium
feedrate
should
be
10
grams
per
hour
for
Condition
1018C12
instead
of
the
15.933
grams
per
hour
that
is
reported
in
the
NODA
database
resulting
from
adjusting
the
feedrate
of
the
second
run
by
a
factor
of
2.
Similarly,
this
same
approach
(multiplying
by
a
factor
of
2)
is
used
to
compute
the
mercury
feedrate.
As
discussed
above,
the
mercury
feedrate
should
be
0.2
grams
per
hour
for
Condition
1018C12
instead
of
the
0.267
grams
per
hour
reported
in
the
NODA
database
resulting
from
adjusting
the
feedrate
of
one
of
the
runs
by
a
factor
of
2.

Furthermore,
the
method
by
which
the
average
is
computed
for
the
constituent
feedrates
in
Condition
1018C12,
in
particular,
is
not
consistent
from
constituent
to
constituent.
In
the
case
of
barium
and
mercury
as
discussed
above,
the
average
feedrate
for
the
condition
is
computed
by
placing
the
spreadsheet
average
formula
and
multiplying
the
feedrate
for
one
of
the
runs
by
two
(2).
In
other
cases,
such
as
the
feedrate
of
arsenic
and
barium
in
the
ash
modifier,
feed
stream
averages
are
computed
by
placing
the
spreadsheet
average
formula
and
computing
the
arithmetic
average
of
the
three
individual
run
feedrates
which
compose
Condition
1018C12.
Still
in
other
cases,
such
as
with
the
liquid
waste
feedrates
for
chromium
and
lead,
the
average
calculated
across
the
three
runs
composing
Condition
1018C12
and
reported
in
the
1998
Trial
Burn/
Risk
Burn
Report
is
simply
inputted
into
the
spreadsheet
cell
representing
the
specific
constituent
feedrate.
Ticona
respectfully
recommends
that
the
agency
adopt
a
consistent
format
for
computing
the
arithmetic
average
and
strongly
supports
the
use
of
the
averages
computed
via
the
preparation
of
the
1998
Trial
Burn/
Risk
Burn
Report.

Response
As
clearly
detailed
in
the
NODA
data
base
report,
the
intent
of
the
data
base
was
when
determining
condition
averages,
to
use
the
standard
convention
of
handling
individual
run
nondetect
measurements
as
present
at
one­
half
of
the
detection
limit.
The
calculation
of
the
condition
average
is
straightforward,
being
simply
the
arithmetic
average
of
the
three
runs,
again
where
fully
detected
runs
are
directly
used,
and
runs
at
the
detection
limit
(non­
detects)
are
assumed
to
be
present
at
one
half
of
the
detection
limit.
The
intended
convention
was
that
when
at
least
one
of
the
runs
is
fully
detected,
the
condition
average
is
also
considered
and
reported
as
detected.
Alternatively,
when
all
three
are
non­
detect,
the
condition
average
is
identified
as
nondetect
This
convention
was
clearly
used
and
followed
in
the
vast
majority
of
the
data
base.
Unfortunately,
however,
there
were
a
few
inconsistencies
to
this
practice
­­
where
when
two
of
the
runs
were
identified
as
non­
detect,
the
overall
condition
average
was
also
reported
as
nondetect
This
quite
understandably
led
to
the
confusion
of
the
commenters.

Specifically,
the
commenters
identified
this
inconsistency
(and
resulting
apparent
calculation
mistake)
in
the
single
example
of
the
calculation
of
the
Ba
and
Hg
feedrates
for
ID
No.
1018C12.
In
this
only
noted
example,
two
of
the
three
Ba
feedrate
data
were
non­
detects
and
the
third
was
fully
detected.
The
Ba
feedrate
condition
average
was
inconsistently
(and
improperly)
labeled
as
"nd";
however
the
calculation
was
performed
correctly.
The
single
fully
detected
feedrate
measurement
was
intentionally
(and
confusingly)
multiplied
by
two.
This
was
to
account
for
future
adjustment
of
the
condition
average
value
by
½
due
to
the
condition
average
non­
detect
identification
("
nd"
label).
Although
highly
confusing,
the
final
MTEC
concentration
value
would
be
correct.
This
example
was
modified
to
be
consistent
with
the
convention
used
throughout
the
data
base
as
described
above
(where
non­
detect
runs
are
treated
at
½
nd,
and
condition
averages
are
reported
as
fully
detected
as
long
as
one
or
more
of
the
runs
were
detected).
We
have
attempted
to
correct
this
problem
by
going
back
through
the
data
base
and
other
places
where
this
inconsistency
might
have
occurred.
4.9
Reporting
of
non­
detects
from
"added
groups"
(such
as
LVM,
SVM,
or
PCDD/
PCDF)
or
condition
averages
Celanese
(10)

Feedstreams
721C10
Feedrate
MTEC
Calculations:
Should
not
the
Mercury
(Hg)
Total
reflect
the
fact
that
BOTH
feeds
had
"nd"
and
mark
"nd"
as
well?

Rubicon
(17)

Database
The
EMTEC
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
812C2
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
7
Both
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
812C2
are
the
sums
of
non­
detect
metals,
it
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
812C2.

...(
section
removed
and
addressed
in
5.16
Edits
to
Rubicon
Inc.,
Phase
II
ID
#
812,
813,
814,
and
815)

PCDDF
Spreadsheet
­
812
Database
The
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
Run
1
and
Run
3
of
812C3
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
11
Both
of
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
Run
1
and
Run
3
of
812C3
have
non­
detect
PCDD/
PCDF's
in
their
respective
sums.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
Run
I
and
Run
3
of
812C3.

...(
section
removed
and
addressed
in
5.16
Edits
to
Rubicon
Inc.,
Phase
II
ID
#
812,
813,
814,
and
815)

Database
The
EMTEC
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
813C2
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
17
Both
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
813C2
are
the
sums
of
non­
detect
metals.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action;
Place
a
non­
detect
notation
in
front
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
813C2.

PCDDF
Spreadsheet
­
813
Database
The
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
813C3
(B
Runs)
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
18
Both
of
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
813C3
(B
Runs)
have
non­
detect
PCDD/
PCDF's
in
their
respective
sums.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
813C3
(B
Runs).

...(
section
removed
and
addressed
in
5.16
Edits
to
Rubicon
Inc.,
Phase
II
ID
#
812,
813,
814,
and
815)

Database
The
EMTEC
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
814C2
(A
Runs)
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment24
Both
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
814C2
(A
runs)
are
the
sums
of
non­
detect
metals.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
814C2
(A
Runs).

PCDDF
Spreadsheet
­
814
Database
The
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
814C2
(B
Runs)
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
25
Both
of
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
814C2
(B
Runs)
have
non­
detect
PCDD/
PCDF's
in
their
respective
sums.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
814C2
(B
Runs).

...(
section
removed
and
addressed
in
5.16
Edits
to
Rubicon
Inc.,
Phase
II
ID
#
812,
813,
814,
and
815)

Database
The
EMTEC
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
815C2
(A
Runs)
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
31
Both
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
815C2
(A
runs)
are
the
sums
of
non­
detect
metals.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
non­
detects.

Requested
Action:
Place
a
non­
detect
notation
in
front
of
the
Semi
Volatile
Metals
and
Low
Volatile
Metals
calculations
for
815C2
(A
Runs).

PCDDF
Spreadsheet
­
815
Database
The
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
815C2
(C
Runs)
do
not
have
non­
detect
notations
in
front
of
their
sums.

Comment
32
Both
of
the
PCDD/
PCDF
(ng
In
sample),
and
PCDO/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
815C2
(C
Runs)
have
non­
detect
PCDD/
PCDF's
in
their
respective
sums.
It
is
common
practice
to
place
a
non­
detect
notation
in
front
of
a
sum
that
is
made
up
of
one
or
more
nondetects

Requested
Action:
place
a
non­
detect
notation
in
front
of
the
PCDD/
PCDF
(ng
in
sample),
and
PCDD/
PCDF
(ng/
dscm
@
7%
O2)
for
all
three
runs
of
815C2
(C
Runs).

Response
Commenters
failed
to
realize
that
this
information
on
the
contribution
of
non­
detects
to
"added"
groups
was
presented
in
the
existing
NODA
data
base
files
(and
described
in
the
accompanying
data
base
report).
The
"emissions
and
feedrate
data
summary
sheet"
provides
a
succinct
rundown
of
this
type
of
information,
specifically
including
the
relative
amount
of
the
stack
gas
emissions
and
feedrate
derived
from
non­
detects,
in
terms
of
percent.
Note
that
for
"single
pollutants"
such
as
Hg
or
PM,
the
%
ND
will
be
either
0
or
100%.
However,
for
the
"added"
groups
where
a
number
of
different
individual
measurements
are
added
together
(such
as
PCDD/
PCDF,
SVM,
LVM,
or
total
chlorine),
the
%
ND
may
range
anywhere
between
0
and
100%.
This
column
is
labeled
"ND
%"
in
the
feedrate
columns.
In
the
stack
gas
columns,
the
"ND%"
is
presented
in
the
column
immediately
to
the
right
of
each
of
the
HAP
or
HAP
surrogate
emissions
concentrations.

4.10
Should
use
reliable
detection
limit
for
non­
detect
measurements
Dow
Dupont
Elastomers
(8)

EPA
Should
Use
the
Reliahle
Detection
Limit
Rather
Than
One­
Half
the
Detection
Limit
for
Non­
Detect
Emissions
Data
In
the
Phase
11
HWC
MACT
Data
Base
Report
(June,
2000)
the
USEPA
consistently
replaces
non­
detect
emissions
data
with
'place­
holder'
values
that
are
one­
half
the
detection
limit
for
the
non­
detected
constituents.
For
example,
see
the
calculated
values
for
dioxins
and
furans
and
the
LVM
and
SVM
metals
in
the
"Data
and
Information
File
for
Individual
Sources"
spreadsheets.
Also
see
the
paragraph
entitled
'Metals'
on
page
7
of
the
Phase
II
HWC
MACT
Data
Base
Report.

Using
one­
half
the
detection
limit
as
'place­
holder'
values
for
non­
detect
emissions
data
is
inconsistent
with
the
protocol
established
by
the
USEPA
for
managing
combustion
emissions
data.
Recently
the
USEPA
used
the
same
Pontchartrain
Site
halogen
acid
furnace
Risk
Assessment
Trial
Bum
data
as
in
the
Phase
11
HWC
MACT
Data
Base
Report
to
conduct
a
unit
specific
risk
assessment.
In
establishing
'place­
holder'
values
for
non­
detect
emissions
data,
the
USEPA
determined
the
Reliable
Detection
Limits
(RDL's)
for
the
non­
detect
emissions
data.
The
RDL's
are
defined
by
the
USEPA
as
2.623
times
the
Method
Detection
Limits
(MDL's).
For
example,
see
pages
2­
79
through
2­
82
in
"Human
Health
Risk
Assessment
Protocol
for
Hazardous
Waste
Combustion
Facilities"
(USEPA,
EPA530­
D­
98­
OOOIA,
July
1998).
During
numerous
meetings
and
symposia
over
the
last
two
years
the
USEPA
has
consistently
confirmed
that
for
non­
detect
emissions
data
the
RDL's
must
be
used
as
'place­
holder'
values
in
risk
assessment
calculations.
As
an
example,
during
the
recent
May
8­
12,
2000
International
Conference
on
Incineration
and
Thermal
Treatment
Technologies
in
Portland,
OR,
Ms.
Cynthia
Kaleri
(US
EPA
Region
6)
stated
several
times
during
formal
presentations
that
non­
detect
emissions
data
must
be
replaced
by
RDL
'place­
holder'
values
prior
to
conducting
the
risk
assessment.
The
reasons
given
by
the
US
EPA
for
using
the
RDL's
as
'place­
holder'
values
for
non­
detect
emission
data
is
t
environmental
protection
and
to
aid
in
developing
required
permitting
limits.
Since
the
Phase
11
HWC
NMCT
has
the
same
goals
as
the
risk
assessment
process
­
that
is,
environmental
protection
and
permit
limit
development
the
USEPA
should
be
consistent
in
selection
of
'place­
holder'
values
across
these
two
regulatory
processes.
If
it
is
necessary
to
use
the
RDL
for
the
risk
assessment
process,
then
the
RDL
should
be
used
also
in
the
data
package
for
developing
the
Phase
11
HWC
NMCT.

DuPont
Dow
Elastomers
requests
that
the
USEPA
revise
all
affected
calculated
values
in
the
"Phase
II
HWC
MACT
Data
Base
Report"
by
using
the
reliable
detection
limits,
rather
than
onehalf
the
detection
limits,
as
'place­
holder'
values
for
non­
detect
emissions
data.

Response
For
the
MACT
setting
process,
as
done
for
the
Phase
I
HWC
MACT
rule,
we
currently
plan
to
continue
to
consider
measurements
at
the
detection
limit
to
be
present
at
one­
half
of
the
detection
limit.
It
is
not
anticipated
that
the
procedure
for
handling
non­
detect
measurements
(for
example,
either
at
full,
half,
or
as
suggested
at
the
reliable
detection
limit
of
2.6
x's
full)
will
have
an
influence
on
the
MACT
process.
Nonetheless,
the
impact
will
be
evaluated.
If
the
process
to
handle
non­
detects
does
have
an
impact,
further
consideration
into
how
to
handle
non­
detect
measurements
will
be
taken.
Also,
there
will
be
opportunity
for
further
comment
on
this
issue
during
rule
proposal.
5.0
Specific
Data
Base
Edits
5.1
Arch
Chemicals
(Phase
II
ID
#
1008)

Arch
(1)

Arch
Comment
On
page
1,
the
database
lists
supplemental
fuel
as
natural
gas
and
process
gas.
EPA
should
strike
out
process
gas.
The
only
supplemental
fuel
is
natural
gas.

Arch
Comment
On
page
3,
Section
1008C1
(max.
feeds)
­
the
total
feed
rate
in
lbs/
hour
of
spiking
solution
is
shown
as
226.4
lbs/
hour.
This
number
should
be
305
lbs/
hour
(combination
of
metals/
ash
spiking
solution
and
POHC
spiking
solution).

Arch
Comment
On
page
3,
Section
1008C1
(max.
feeds)
­
no
firing
rate
is
given
for
sulfur.
The
number
should
be
45.7
M2
BTU/
hour
which
would
make
a
total
firing
rate
of
133.9
M2
BTU/
hour.
The
estimated
firing
rate
is
listed
as
187.1
M2
BTU/
hour.
Arch
believes
this
number
should
be
145
M2
BTU/
hour.

Arch
Comment
On
page
3
and
4,
BIF
Feed
Rate
Limits
­
EPA
lists
the
barium
limit
as
284,407
g/
hour
and
silver
limit
as
17,055
g/
hour.
These
numbers
should
be
129,844
and
7,809
g/
hour
respectively
per
the
Arch
Certification
of
Compliance
Report.

Arch
Comment
On
pages
3
and
4,
BIF
Feed
Rate
Limits
­
EPA
lists
the
limits
for
arsenic,
beryllium,
cadmium,
chromium,
and
total
chlorine
as
Tier
III.
Arch
has
provided
the
limits
established
with
the
1998
Certification
of
Compliance
Test:

Arsenic
2116
g/
hour
Beryllium
390
g/
hour
Cadmium
2116
g/
hour
Chromium
2116
g/
hour
Total
chlorine
40,406
g/
hour
Response
EPA
has
reviewed
the
requested
data
base
edits.
The
commenter
also
submitted
data
base
Excel
spreadsheets
containing
written
and
highlighted
comments.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.2
Merck
&
Co.,
Inc.
(Phase
II
ID
#
780,
781)

Merck
(2)

For
the
unit
with
Phase
II
ID
No.
780
(Boiler
No.
7):

Stack
Characteristics
­
Diameter
(ft)
10
Height
(ft)
235
Gas
Velocity
(f/
sec)
5.8
For
the
unit
with
Phase
II
ID
No
781
(Boiler
No.
8):

Stack
Characteristics
­
Diameter
(ft)
l0
Height
(ft)
235
Gas
Velocity
(ft/
sec)
5.8
Condition
2
­
Testing
Dates
October
18­
19,
1999
The
gas
velocity
was
calculated
from
the
flow
rate
(in
DSCFM)
measured
during
the
1999
Recertification
of
Compliance
Test
and
the
stack
diameter.

Merck
(9)

III.
Site
Specific
Comments
In
addition
to
the
general
comments
presented
above,
Merck
has
the
following
specific
comments
related
to
the
collected
data
for
the
Merck
owned
and
operated
sources.
For
clarification
purposes,
revised
data
has
also
been
attached.

ID
No.
780

Under
Source
Description,
Permitting
Status,
please
note
that
this
unit
is
operating
under
interim
status.


Under
Source
Description,
the
information
about
the
soot
blowing
cycle
and
when
it
occurred
is
incorrect.
There
is
one
10
min.
soot
blowing
cycle
(Condition
1
run
3)
not
(Condition
2
run
3).


Under
Stack
Gas
Emissions,
the
gas
flowrate
for
condition
1
(780C1),
run
3,
should
be
27555
dscfm
not
27550
dscfm.


Under
Feedstreams,
the
feedrate
for
liquid
solvent,
condition
1
(780C1),
should
be
1191.9
kg/
hr
not
1195.5
kg/
hr.


Under
Feedstreams,
the
feedrate
for
ash
in
the
liquid
solvent,
condition
1
(780C1),
should
be
1236
g/
hr
not
1300
g/
hr.
This
will
change
the
corresponding
MTEC
calculation.

Under
Feedstreams,
the
feedrate
for
chlorine
in
the
liquid
solvent,
condition
1
(780C1),
should
be
596
g/
hr
not
595
g/
hr.
This
will
change
the
corresponding
MTEC
calculation.


Under
Feedstreams,
the
feedrate
for
liquid
solvent,
condition
2
(780C2),
should
be
231.6
kg/
hr
not
234
kg/
hr.


Under
Feedstreams,
the
thermal
feedrate
for
the
liquid
solvent,
condition
2
(780C2),
should
be
4.3
MMBtu/
hr
not
4.5
MMBtu/
hr
and
the
total
thermal
feedrate
should
be
40.3
MMBtu/
hr
not
40.5
MMBtu/
hr.

ID
No.
781

Under
Source
Description,
Permitting
Status,
please
note
that
this
unit
is
operating
under
interim
status.


Under
Stack
Gas
Emissions,
the
gas
flowrate
for
condition
1
(781C1),
run
1,
should
be
27383
dscfm
not
273383
dscfm.


Under
Feedstreams,
the
feedrate
for
liquid
solvent,
condition
1
(781C
l),
should
be
1181.3
kg/
hr
not
1185.5
kg/
hr.


Under
Feedstreams,
the
thermal
feedrate
for
the
liquid
solvent,
condition
1
(781C1),
should
be
21.7
MMBtu/
hr
not
21
MMBtu/
hr.


Under
Feedstreams,
the
feedrate
for
ash
in
the
liquid
solvent,
condition
1
(781C1),
should
be
1732
g/
hr
not
1790
g/
hr.
This
will
change
the
corresponding
MTEC
calculation.


Under
Feedstreams,
the
feedrate
for
chlorine
in
the
liquid
solvent,
condition
1
(781C1),
should
be
591
g/
hr
not
586
g/
hr.
This
will
change
the
corresponding
MTEC
calculation.


Under
Feedstreams,
the
feedrate
for
lead
in
the
liquid
solvent,
condition
1
(781C
1),
should
be
0.118
g/
hr
not
0.13
g/
hr.
This
will
change
the
corresponding
MTEC
calculation.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.3
ExxonMobil
Chemical
Co.
(Phase
II
ID
#
822)

Exxon/
Mobil
(3)

ExxonMobil
Chemical
Company
has
a
direct
interest
in
this
NODA
because
an
Exxon
Chemical
Company
(now
ExxonMobil
Chemical
Company)
facility
in
Baton
Rouge
is
inappropriately
identified
in
the
database.

Two
boilers
at
the
ExxonMobil
Chemical
Company
Baton
Rouge
Plastics
Plant
(EPA
ID
No.
LAD000778381)
appear
in
the
database
as
Phase
II
ID
No.
822.
These
boilers
should
not
be
included
In
the
database
because
they
no
longer
burn
hazardous
waste.
As
indicated
in
the
attached
May
17,
1999
letter
to
the
Louisiana
Dept.
of
Environmental
Quality,
this
facility
is
operating
in
compliance
with
the
Comparable
Fuels
Exclusion
at
40
CFR
261.38,
and
as
such,
any
new
NESHAPs
for
hazardous
waste
bumlng
boilers
would
not
be
applicable
to
these
units.
To
ensure
that
the
data
on
which
the
new
standards
will
be
based
properly
represents
the
intended
universe
of
regulated
facilities,
please
remove
these
boilers
from
the
database.

Response
EPA
has
identified
the
boilers
at
the
Exxon
Mobil
Chemical
Company
Baton
Rouge
Plastics
Plant,
Phase
II
ID
No.
822
as
no
longer
burning
hazardous
waste.
At
this
point,
they
have
not
been
removed
from
the
data
base,
but
in
the
future
will
be
considered
as
units
which
are
no
longer
burning
hazardous
waste.

5.4
Westvaco
Corp
(Phase
II
ID
#
818)

Westvaco
(4)

Westvaco
hereby
submits
the
following
comments:

2.
Stack
testing
data
from
the
BIF's
1998
re­
certification
of
compliance
testing
was
not
included
in
the
USEPA's
data
package.
This
testing
event
included
polychlorinated
dibenzo­
p­
dioxins,
polychlorinated
dibenzofurans,
and
carbon
monoxide.
The
data
are
attached
as
Exhibit
I.

3.
Minor
clarifications
and
additions
were
performed
throughout
the
Westvaco
DeRidder
data
(ID
No.
818).
Refer
to
Exhibit
II
for
the
revised
data.
The
Westvaco
clarifications
and
additions
are
highlighted.

Response
The
new
data
from
the
supplied
testing
has
been
added
to
the
data
base.
Also,
the
commenter
submitted
electronic
copies
of
data
base
Excel
spreadsheets
with
comments
highlighted
and
corrected.
EPA
has
reviewed
all
comments,
and
made
changes
or
additions
as
documented
in
Table
3.

5.5
General
Electric
Plastics
Co.
(Phase
II
ID
#
764,
765,
766)

General
Electric
(5)

Information
about
Test
Conditions
and
Results
GE
provided
EPA
with
information
about
our
three
boilers
that
was
developed
during
emissions
testing
of
those
boilers.
The
testing
was
conducted
when
the
boilers
were
operating
under
"normal"
conditions.
Further,
the
results
that
we
reported
for
Chrome
are
data
for
"total
Cr".

GE
Plastics
Facility
in
Mt.
Vernon,
Indiana
GE
operates
two
hazardous
waste
burning
boilers
at
this
facility.
They
are
designated
#764
and
#765
in
the
EPA
database.
We
offer
the
following
comments
on
the
data
for
these
two
boilers.

Both
boilers
1.01
It
is
unclear
from
the
EPA
database
whether
EPA
is
aware
that
these
two
boilers
have
a
common
stack.
The
purpose
of
this
comment
is
to
explicitly
bring
this
fact
to
your
attention.
1.02
In
both
of
the
"feed"
worksheets,
there
is
a
designation
of
"nd"
in
an
untitled
column.
We
assume
that
"nd"
stands
for
"non­
detectable"
or
"not
detected".
In
the
data
we
provided
to
the
agency,
we
reported
the
values
as
less
than
detection
limits
and
provided
the
detection
limits.
This
comment
is
simply
intended
to
confirm
with
the
agency
that
"nd"
does
correctly
indicate
that
the
subject
compounds
are
below
detection
limits.
1.03
In
the
764.
xls
workbook,
in
the
"feed"
worksheet,
under
the
heading
"BIF
Feedrate
Limits
for
ID
Nos.
764
and
765",
GE
revised
the
limits
for
each
of
these
elements
in
an
August
3,
2000
letter
to
USEPA,
Region
V,
as
shown
in
the
table
below.
EPA
should
use
the
revised
limits
to
replace
the
values
currently
in
the
database.

Element
Feedrate
in
database
(g/
hr)
New
feedrate
(g/
hr)

Sb
6532
6246
As
1.8
2.9
Ba
1426264
1041064
Be
7.8
1.7
Cd
9.5
2.3
Cr
19.7
15.8
Pb
2556
1874
Hg
8532
6246
Ag
85572
62464
Tl
14256
10411
Cl
11376
8329
#764
(all
worksheets
in
this
section
of
the
comments
are
in
workbook
764.
xls)
1.04
In
the
"source"
worksheet,
under
the
heading
"Stack
Characteristics",
the
gas
velocity
is
blank.
The
gas
velocity
is
63.7
ft/
sec
(when
both
boilers
are
operating
­
as
noted
above,
the
two
boilers
vent
to
a
common
stack).
Footnote­
1
[Gas
velocity
=
((
37,887
scfm
+
37,191
scfm)/(
60
sec/
min))/(
2.5
ft)
2
x
3.1416)
=
63.7
ft/
sec.
The
gas
flows
in
the
equation
are
the
averages
of
the
gas
flows
measured
during
the
3
test
runs
on
each
boiler,
which
can
be
found
in
Tables
1
and
2,
respectively,
or
Appendix
B
of
the
Final
Report
entitled
"Revised
Recertification
of
Compliance
of
BIF
Boilers
H530A
and
H530B
at
GE
Plastics,
Mt.
Vernon,
Indiana
Facility"
(March
12,
1998),
the
same
report
identified
in
the
"source"
worksheet
under
"Report
Name/
Data"
("
GE
Test
Report").]

1.05
In
the
"source"
worksheet,
under
the
heading
"Stack
Characteristics",
the
gas
temperature
is
blank.
The
gas
temperature
is
529

F.
Footnote­
2
[This
temperature
is
the
average
of
the
temperatures
measured
during
the
3
test
runs
on
each
boiler.
The
temperature
data
can
be
found
in
Tables
1
and
2,
respectively,
of
Appendix
B
in
the
GE
Test
Report.]

1.06
In
the
"source"
worksheet,
under
the
heading
"Permitting
Status",
the
word
"Adjusted"
should
be
inserted
at
the
beginning
so
that
the
entry
reads
"Adjusted
Tier
I
for
all
metals,
chlorine".

1.07
In
the
"emiss"
worksheet,
under
the
column
headed
"3
sootblowing",
the
PM
emissions
should
be
0.398
gr/
dscf,
not
0.0662
gr/
dscf.
Footnote­
3
[The
value
of
0.0652
gr/
dscf
is
the
uncorrected
value.
According
to
the
Phase
II
HWC
MACT
Data
Base
Report
prepared
by
USEPA
(June
2000),
the
soot
blowing
corrected
average
should
be
entered
here.
Id.
at
6.
The
value
of
0.0398
gr/
dscf
is
the
corrected
value.
Both
the
uncorrected
and
corrected
values
can
be
found
in
Table
4­
4
of
the
GE
Test
Report.]

1.08
In
the
"feed"
worksheet,
the
"Thermal
Feedrate"
should
be
70.7
MMBtu/
hr,
not
74.0
MMBtu/
hr.
Footnote­
4
[Thermal
feedrate
=
(4.679.37
lbs/
hr
x
15,106
Btu/
lb)/(
1,000,000
Btu/
MMBtu)
=
70.7
MMBtu/
hr.
The
waste
feed
rate
of
4,679.37
lbs/
hr
and
higher
heating
value
of
15,106
Btu/
lb
can
be
found
in
Tables
4­
1
and
4­
2,
respectively,
of
the
GE
Test
Report.]

1.09
In
the
"feed"
worksheet,
the
"(
Ash)"
feedrate
should
be
6.125
lb/
hr,
not
5.99
lb/
hr.
Footnote­
5
[The
value
of
6.125
lb/
hr
was
reported
in
Table
4­
1
of
the
GE
Test
Report
as
the
average
over
the
3
test
runs.
The
value
of
5.99
lb/
hr
is
the
maximum
ash
feed
rate
for
the
first
test
run
only.]

1.10
In
the
"feed"
worksheet,
the
"Stack
Gas
Flowrate"
should
be
18,657.0
dscfm,
not
17,037.2
dscfm.
Important
note:
GE
believes
that
EPA's
calculation
of
17,037.2
dscfm
is
fundamentally
in
error.
First,
GE
does
not
understand
why
EPA
is
performing
a
calculation
to
determine
stack
gas
flowrate
when
GE
measured
stack
gas
flowrate
during
testing.
GE
believes
that
EPA
should
use
the
value
actually
measured,
not
a
calculated
surrogate
(assuming
that
is
what
the
equation
represents).
In
addition,
EPA's
calculation
in
the
subject
cell
of
the
worksheet
appears
to
attempt
to
correct
for
oxygen
concentration,
but
is
in
error
in
two
ways.
First,
it
appears
to
use
7%
as
the
oxygen
concentration
to
correct
from.
As
indicated
in
Comment
#11
below,
the
oxygen
concentration
measured
during
tests
was
8.1%,
not
7%.
Second,
the
formula
in
the
cell
contains
the
term
"21(
21­
D25)".
The
correct
formula
to
correct
the
oxygen
from
test
conditions
to
7%
is
"(
21­
7)/(
21­
D25)",
where
the
cell
D25
should
contain
the
number
8.1
as
noted
in
comment
#11
below.
These
same
errors
appear
in
the
same
worksheet
for
our
other
Mt.
Vernon
boiler,
765.
xls.
However,
in
766.
xls,
the
file
for
our
Selkirk
boiler,
it
appears
that
EPA
used
the
average
of
the
flowrate
values
we
reported,
without
calculation
from
heat
input
rates
and
without
oxygen
correction.
Footnote­
6
[The
value
of
18,657.0
dscfm
is
the
average
of
the
volumetric
flowrates
(in
dscfm)
reported
for
the
3
test
runs.
The
test
run
data
can
be
found
in
Table
1
of
Appendix
B
in
the
GE
Test
Report.]

1.11
In
the
"feed"
worksheet,
the
"Oxygen"
concentration
should
be
8.1%,
not
7%.
Footnote­
7
[The
value
of
8.1%
is
the
average
oxygen
concentration
measured
during
each
of
the
3
test
runs.
The
test
run
data
can
be
found
in
Table
1
of
Appendix
B
in
the
GE
Test
Report.
It
appears
EPA
has
used
the
value
to
which
the
measured
oxygen
concentration
is
to
be
corrected,
not
the
measured
concentration
itself.]

1.12
In
the
"feed"
worksheet,
the
"Firing
Rate"
of
the
liquid
waste
should
be
70.7
MMBtu/
hr,
not
74.0
MMBtu/
hr.
Accordingly,
the
total
firing
rate
(liquid
waste
÷
auxiliary
fuel)
should
be
72.4
MMBtu/
hr,
not
75.7
MMBtu/
hr.
Footnote­
8[
See
footnote
4
above.]

1.13
In
the
"feed"
worksheet,
under
the
heading
"Feedrate
MTEC
Calculations",
the
calculation
of
"Ash"
feedrate
(in
mg/
dscm)
uses
the
correct
term
to
correct
the
oxygen
concentration
from
test
conditions
to
7%.
However,
the
ash
feedrate
shown
was
incorrectly
calculated
because
the
calculation
uses
7%
as
the
measured
oxygen
concentration
when,
as
noted
in
comment
number
11
above,
the
actual
value
measured
in
the
testing
was
8.1%
(average
of
the
3
runs).
Thus,
the
calculated
Ash
feedrate
is
not
correct.

#765
(all
worksheets
in
this
section
of
the
comments
are
in
workbook
765.
xls)

1.14
In
the
"source"
worksheet,
under
the
heading
"Stack
Characteristics",
the
diameter
should
be
5
ft.,
not
8
ft.
As
noted
above,
both
boilers
vent
to
a
common
stack.
The
diameter
shown
in
workbook
764.
xls
is
correctly
shown
as
5
ft.

1.15
In
the
"source"
worksheet,
under
the
heading
"Stack
Characteristics",
the
gas
velocity
is
blank.
The
gas
velocity
is
63.7
ft/
sec
(when
both
boilers
are
operating
­
as
noted
above,
the
two
boilers
vent
a
common
stack).
Footnote­
9[
See
footnote
1
above.]

1.16
In
the
"source"
worksheet,
under
the
heading
"Stack
Characteristics",
the
temperature
is
blank.
The
gas
temperature
is
529

F.
Footnote­
10[
See
footnote
2
above.]

1.17
In
the
"source"
worksheet,
under
the
heading
"Permitting
Status",
the
word
"Adjusted"
should
be
inserted
at
the
beginning
so
that
the
entry
reads
"Adjusted
Tier
I
for
all
metals,
chlorine".

1.18
In
the
"emiss"
worksheet,
under
column
"3
sootblowing",
the
PM
emissions
should
be
0.0411
gr/
dscf,
not
0.0808
gr/
dscf.
Footnote­
11[
The
value
of
0.0808
gr/
dscf
is
the
uncorrected
value.
According
to
the
Phase
II
HWC
MACT
Data
Base
Report
prepared
by
USEPA
(June
2000),
the
soot
blowing
corrected
average
should
be
entered
here.
Id.
at
6.
The
value
of
0.0411
gr/
dscf
is
the
corrected
value.
Both
the
uncorrected
and
corrected
value
can
be
found
in
Table
4­
4
of
the
GE
Test
Report.]

1.19
In
the
"feed"
worksheet,
the
"Thermal
Feedrate"
should
be
72.0
MMBtu/
hr,
not
72.8
MMBtu/
hr.
Footnote­
12[
Thermal
feedrate
=
(4,763.5
lbs/
hr
x
15,107
Btu/
lb)/(
1,000,000
Btu/
1
MMBtu)
=
72.0
MMBtu/
hr.
The
waste
feed
rate
of
4,763.5
lbs/
hr
and
higher
heating
value
of
15,107
Btu/
lb
can
be
found
in
Tables
4­
1
and
4­
2,
respectively,
of
the
GE
Test
Report.]

1.20
In
the
"feed"
worksheet,
the
"(
Ash)"
feedrate
should
be
5.626
lb/
hr,
not
5.6
lb/
hr.
Footnote­
13[
The
value
of
5.626
lb/
hr
was
reported
in
Table
4­
1
of
the
GE
Test
Report
as
the
average
over
the
3
test
runs.
The
incorrect
value
of
5.6
lb/
hr
appears
to
be
a
typographical
error.

1.21
In
the
"feed"
worksheet,
the
"Stack
Gas
Flowrate"
should
be
17,518.7
dscfm,
not
16,475.3
dscfm.
In
addition,
the
same
"Important
Note"
at
Comment
10
above
regarding
764.
xls
applies
here.
Footnote­
14[
The
value
of
17,518.7
dscfm
is
the
average
volumetric
flow
rate
measured
during
each
of
3
test
runs.
The
test
run
data
can
be
found
in
Table
2
of
Appendix
B
in
the
GE
Test
Report.]

1.22
In
the
"feed"
worksheet,
the
"Oxygen"
concentration
should
be
5.5%,
not
7%.
Footnote­
15[
The
value
of
5.5%
is
the
average
oxygen
concentration
measured
during
each
of
the
3
test
runs.
The
test
run
data
can
be
found
in
Table
2
of
Appendix
B
in
the
GE
Test
Report.]

1.23
In
the
"feed"
worksheet,
the
"Firing
Rate"
of
the
liquid
waste
should
be
72.0
MMBtu/
hr,
not
72.8
MMBtu/
hr.
Accordingly,
the
total
firing
rate
should
be
72.4
MMBtu/
hr,
not
73.2
MMBtu/
hr.
Footnote­
16[
See
footnote
12
above.]
1.24
In
the
"feed"
worksheet,
under
the
heading
"Feedrate
MTEC
Calculations",
the
calculation
of
"Ash"
feedrate
(in
mg/
dscm)
uses
the
correct
term
to
correct
the
oxygen
concentration
from
test
conditions
to
7%.
However,
the
ash
feedrate
shown
was
incorrectly
calculated
because
the
calculation
uses
7%
as
the
measured
oxygen
concentration
when,
as
noted
in
comment
number
22
above,
the
actual
value
measured
in
the
testing
was
5.5%
(average
of
the
3
runs).
Thus,
the
calculated
Ash
feedrate
value
is
not
correct.

GE
Plastics
Facility
in
Selkirk,
New
York
GE
operates
one
hazardous
waste
burning
boiler
at
this
facility.
It
is
designated
#766
in
the
EPA
database.
We
offer
the
following
comments
on
the
data
for
this
boiler.
All
worksheets
in
this
section
of
the
comments
pertain
to
workbook
766.
xls.

1.25
In
the
worksheets
titled
"source"
and
"summ
1",
the
EPA
ID
No.
is
incorrect.
In
both
worksheets,
the
EPA
ID
No.
is
presented
as
NYD06683023.
The
correct
EPA
ID
No.
for
this
boiler
is
"NYD066832023".

1.26
In
the
"source"
worksheet,
the
word
"None"
appears
next
to
the
row
designated
as
"Soot
Blowing".
It
is
correct
that
soot
blowing
was
not
conducted
during
the
emissions
testing
for
which
we
have
provided
data.
However,
we
do
conduct
soot
blowing
on
this
boiler.

1.27
In
the
"source"
worksheet,
natural
gas
is
identified
as
the
"supplemental
fuel".
Similarly,
in
the
worksheet
"summ
1",
natural
gas
is
identified
as
the
"Aux
Fuel"
and
in
the
worksheet
"summ
2"
natural
gas
is
identified
as
the
"Aux
Fuel
Type".
We
consider
natural
gas
to
be
the
primary
fuel
for
this
boiler
and
we
are
permitted
to
burn
either
#2
or
#6
oils
as
auxiliary
fuel.

1.28
In
the
"feed"
worksheet,
there
is
a
designation
of
"nd"
in
an
untitled
column.
We
assume
that
"nd"
stands
for
"non­
detectable"
or
"not
detected".
In
the
data
we
provided
to
the
agency,
we
reported
the
values
as
less
than
detection
limits
and
provided
the
detection
limits.
This
comment
is
simply
intended
to
confirm
with
the
agency
that
"nd"
does
correctly
indicate
that
the
subject
compounds
are
below
detection
limits.

In
both
of
the
"feed"
worksheets,
there
is
a
designation
of
"nd"
in
an
untitled
column.
We
assume
that
"nd"
stands
for
"non­
detectable"
or
"not
detected".
In
the
data
we
provided
to
the
agency,
we
reported
the
values
as
less
than
detection
limits
and
provided
the
detection
limits.
This
comment
is
simply
intended
to
confirm
with
the
agency
that
"nd"
does
correctly
indicate
that
the
subject
compounds
are
below
detection
limits.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

Note
that
in
response
to
the
very
last
comment,
as
indicated
in
the
Phase
II
HWC
MACT
Data
Base
Report,
non­
detect
measurements
are
designated
by
a
"nd".

5.6
Eastman
Chemical
Company,
Texas
Operations
(Phase
II
ID
#
854)

Eastman
Texas
(6)

The
following
changes
and
corrections
are
needed
for
Source
Description,
Phase
II
ID
No.
854.
EPA
ID
NO.
TXD007330202
Eastman
Chemical
Company,
Texas
Operations,
Longview,
Texas
Spreadsheet,
Source
Description:

Facility
Name:
From
Texas
Eastman
Division,
Eastman
Chemical
Company
to
Eastman
Chemical
Company,
Texas
Operations.

Haz
Waste
Descr:
From
By­
product
liquid
feed
to
Liquid
hazardous
waste
Stack
Height:
Not
previously
in
spreadsheet,
insert
63
ft.
See
Appendix
7­
1,
page
7.

Gas
Temperature
(F):
From
190
to
187F.
During
1998
testing,
the
average
stack
temperature
average
was
187
F.
See
Table
3­
5,
page
3­
7.

Velocity
(ft/
s):
From
45.0
to
44.1.
Test
velocity
average
during
1998
testing
was
44.1
ft/
s.
See
Table
3­
5,
page
3­
7.

Permitting
Status:
From
BIF
Tier
I
for
all
metals
to
Adjusted
BIF
Tier
I.

Spreadsheet,
Emiss:

Run
2,
POHC
DRE
­
Chlorobenzene,
DRE,
should
be
99.99988,
instead
of
99.9999.
If
the
column
width
is
widened
the
number
to
5
significant
digits
will
show
up
as
99.99988,
instead
of
99.9999.

854C2,
Sampling
Train
1­­
HCl/
Cl2,
Run
1
and
Run
2.
The
information
in
Run
2
column
for
Stack
gas
flowrate,
O2,
Moisture
and
temperature
should
be
switched
with
the
numbers
under
Run
1.
See
the
attached
1996
sheet
with
supporting
data.

Correct
values
for
Run
1:
Stack
Gas
flowrate
(dscfm)
=
2901
incorrect
value
3174
02
(%)
=
5.2
incorrect
value
8.3
Moisture
(%)
=
62.5
incorrect
value
60.6
Temperature
(F)
=
191
incorrect
value
190
Correct
values
for
Run
2:
Stack
Gas
flowrate
(dscfm)
=
3174
incorrect
value
2901
02
(%)
=
8.3
incorrect
value
5.2
Moisture
(%)
=
60.6
incorrect
value
62.5
Temperature
(F)
=
190
incorrect
value
191
Spreadsheet,
Emiss:
(continued)

854C2,
Sampling
Train
1­­
HCl/
Cl2,
Run
1
and
Run
2.
The
HCl,
Cl2
and
Total
chlorine
data
in
columns
for
Runs
1
and
2
change,
by
EPA
calculation
method,
when
the
data
for
854C2,
Sampling
Train
1­­
HCl/
Cl2
runs
1
and
2,
stack
gas
flowrate
and
O2
were
corrected
for
the
respective
runs.
See
the
correct
HCl,
Cl2
and
Total
chlorine
values
for
Run
1
and
Run
2.

Correct
values
for
Run
1:
HCl
(ppmv)
=
20.4
incorrect
value
23.2
Cl2
(ppmv)
=
66.9
incorrect
value
76.1
Total
chlorine
(ppmv)
=
154.2
incorrect
value
175.4
Correct
values
for
Run
2:
HCl
(ppmv)
=
23.1
incorrect
value
20.3
Cl2
(ppmv)
=
74.2
incorrect
value
65.3
Total
chlorine
(ppmv)
=
171.6
incorrect
value
150.9
Spreadsheet,
Feedstreams:

854C1:
Heat
content,
Btu/
lb,
Liq
waste:
From
1200
Btu/
lb
to
1150
Btu/
lb.
See
Table
4­
3,
page
4­
2.
EPA's
input
did
not
include
the
Run
2­
dup
which
when
added
into
the
other
Btu/
lb
values
averages
to
be
1150
Btu/
lb.

Heat
content,
Btu/
dscf,
vent
gas:
From
100
Btu/
dscf
to
92.3
Btu/
dscf.
See
Table
4­
31,
page
4­
56.
All
three
runs
Btu/
dscf
averaged
equals
92.3
Btu/
dscf,
not
100
Btu/
dscf.

Chlorine,
lb/
hr,
Liq
waste:
From
815
lb/
hr
to
813
lb/
hr.
See
Table
5­
19,
page
5­
35.
The
average
of
363000
+
371,000
÷
372000
=
368,666/
3/
453.6
=
812.75
lb/
hr.

Chlorine,
lb/
hr,
Vent
gas:
From
28
lb/
hr
to
29.3
lb/
hr.
See
Table
5­
19,
page
5­
35.
The
average
of
13,000
+
14,700
÷
12,100
=
39,800/
3/
453.6
=
29.24
lb/
hr.

Chlorine,
lb/
hr,
POHC
spike:
From
4.6
lb/
hr
to
4.7
lb/
hr.
See
Table
5­
17,
page
5­
34.
The
average
of
2,130
+
2,150
÷
2,160
=
6,440/
3/
453.6
=
4.73
lb/
hr.

Firing
Rate,
MMBtu/
hr,
Liq
waste:
The
number
will
change,
by
spreadsheet
calculation,
from
4.9
to
4.7,
when
the
Heat
content,
Btu/
lb,
Liq
waste
is
changed
from
1200
to
1150.
No
change
was
made
to
EPA's
formula
of
calculation.

Firing
Rate,
MMBtu/
hr,
Vent
gas:
The
number
will
change,
by
spreadsheet
calculations,
from
1.4
to
1.3,
when
the
Heat
content,
Btu/
lb,
Vent
gas
is
changed
from
100
to
92.3.
See
Table
4­
31,
page
4­
56.
No
change
was
made
to
EPA's
formula
of
calculation.

Feedrate
MTEC
Calculations,
Chlorine,
µg/
dscm,
Liq
waste:
The
number
will
change,
by
spreadsheet
calculation,
from
71983154
to
71806508,
when
the
Chlorine,
lb/
hr,
Liq
waste
is
changed
from
815
to
813.
See
Table
5­
19,
page
5­
35.
No
change
was
made
to
EPA's
formula
of
calculation.

Feedrate
MTEC
Calculations,
Chlorine,
µg/
dscm,
Vent
gas:
The
number
will
change,
by
spreadsheet
calculation,
from
2473041
to
2579028,
when
the
Chlorine,
lb/
hr,
Vent
gas
is
changed
from
28
to
29.2.
See
Table
5­
19,
page
5­
35.
No
change
was
made
to
EPA's
formula
of
calculation.

Feedrate
MTEC
Calculations,
Chlorine,
µg/
dscm,
POHC
Spike:
The
number
will
change,
by
spreadsheet
calculation,
from
406285
to
415118,
when
the
Chlorine,
lb/
hr,
Vent
gas
is
changed
from
4.6
to
4.7.
See
Table
5­
17,
page
5­
34.

Feedrate
MTEC
Calculations,
Chlorine,
µg/
dscm,
Total:
The
number
will
change
by
spreadsheet
calculation
from
74862480
to
74800654
when
the
liquid
and
vent
gas
and
POHC
spike
chlorine
levels
were
corrected.
No
change
was
made
to
EPA's
formula
of
calculation.

854C2:
Firing
Rate,
MMBtu/
hr,
Liq
waste:
From
9.4
to
9.3.
See
CC­
4
fore,
runs
1,
2
&
3.

Heating
Value,
Btu/
lb,
Liq
waste:
From
2167
to
2144,
when
the
Firing
Rate,
MMBtu/
hr
is
changed
from
9.4
to
9.3.
The
change
to
2144
is
automatically
calculated
by
the
spreadsheet
when
9.3
is
entered.
See
CC­
4
forms,
runs
l,
2
&
3.
No
change
was
made
to
EPA's
formula
of
calculation.

Firing
Rate,
M2Btu/
hr,
Liq
waste:
From
9.4
to
9.3.
This
cell
automatically
changes
when
9.3
is
entered
in
cell
C31.
No
change
was
made
to
EPA's
formula
of
calculation.

Spreadsheet,
Process
Information:

854C1
&
854C2:
Wet
Scrubber
Operation,
L/
G
Ratio,
Units:
Delete
gal/
Macf7.
The
units
are
simply
a
ratio
of
a
liquid
to
gas
flow.
Spreadsheet,
PCDDF:

824C1:

All
the
numbers
changed
below
can
be
seen
in
Table
4­
12,
page
4­
24.

1,2,3,4,6,7,8­
HpCDD,
Run
1,
Total
&
Total
1/
2
ND,
pg:
Change
from
840
to
830.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
830
value
ia
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,6,7,8­
HpCDD,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
660
to
650.
See
Table
4­
12,
page
4­
24.
The
TRQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
650
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,6,7,8­
HpCDD,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
650
to
640.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
640
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HpCDD
Other,
Run
1,
Total
&
Total
1/
2
ND,
pg:
Change
from
560
to
570.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
670
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HpCDD
Other,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
440
to
450.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
450
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HpCDD
Other,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
450
to
460.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
460
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

OCDD,
Run
1,
Total
&
Total
1/
2
ND,
pg:
Change
from
1200
to
1100.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1100
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

OCDD,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
970
to
920.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
920
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.
OCDD,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
920
to
870.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
870
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,7,8­
HxCDF,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
790
to
780.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
780
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,7,8­
HxCDF,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
660
to
650.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
650
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HxCDF
Other,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
1880
to
1890.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1890
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HxCDF
Other,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
1570
to
1580.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1580
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,7,8,9­
HpCDF,
Run
1,
Total
&
Total
1/
2
ND,
pg:
Change
from
1000
to
990.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
990
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,7,8,9­
HpCDF,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
830
to
820.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
820
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

1,2,3,4,7,8,9­
HpCDF,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
780
to
770.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
770
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HpCDF
Other,
Run
1,
Total
&
Total
1/
2
ND,
pg:
Change
from
1700
to
1610.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1610
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.
HpCDF
Other,
Run
2,
Total
&
Total
1/
2
ND,
pg:
Change
from
1370
to
1280.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1280
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

HpCDF
Other,
Run
3,
Total
&
Total
1/
2
ND,
pg:
Change
from
1120
to
1030.
See
Table
4­
12,
page
4­
24.
The
TEQ
1/
2
ND
value
is
automatically
re­
calculated/
changed
by
the
spreadsheet
when
the
1030
value
is
inserted.
No
change
was
made
to
EPA's
formula
of
calculation.

PCDD/
PCDF
(ng
in
sample):
All
these
numbers,
for
all
three
runs,
in
this
row
are
automatically
re­
calculated/
changed
when
the
above
number
entries
are
changed.
No
calculation
formula
changes
were
made.
No
change
was
made
to
EPA's
formula
of
calculation.

PCDD/
PCDf
(ng/
dscm
@7%
O2),
Run
1,
2
&
3,
Total
1/
2
ND:
These
numbers
are
re­
calculated/
changed
when
the
numbers
in
row
40,
PCDD/
PCDF
(ng
in
sample)
are
changed.
No
change
was
made
to
EPA's
formula
of
calculation.

Total
Cond
Avg:
This
number
changes
from
6.97
to
6.92
when
the
average
of
the
Row
41,
Run's
1,
2
&
3,
Total
1/
2
ND's
is
re­
calculated/
changed.
No
change
was
made
to
EPA's
formula
of
calculation.

Spreadsheet,
Summ2,
summary
­
condition
averages
@7%
O2:

Changes
made
to
Summ2,
Summary
­
condition
averages
@7%
O2,
for
Heat
input
rate,
D/
F
Total
ng/
dscm,
TC1
HW
µg/
dscm
are
changed
based
on
different
values
in
the
feed
and
emission
spreadsheets.
No
change
to
EPA's
formula
of
calculation.

Feedrate
Characteristics,
Spike
%:
The
number
changes
from
82
to
83
percent.
The
change
is
made
since
Cell
F22
in
the
Feed
spreadsheet
is
174,
see
cell
F22.
Feedrate,
MTEC,
Ash
Spike,
Ash
is
174
instead
of
171
which
is
currently
used
in
the
spreadsheet
calculation.
The
previous
formula
was
171/
AQS*
100.
The
formula
has
been
changed
to
=feed!
F22/
AQ8*
l00,
which
equals
83%.

Other
Information
Requested:

Answer
to
Federal
Register:
June
27,
2000,
Section
VI,
No.
4,
paragraph
2.
Does
the
Halogen
Acid
Furnace
(HAF)
we
operate
have
any
energy
recovery
features?
No.

Answer
to
Federal
Register:
June
27,
2000,
Section
VI,
No.
4,
paragraph
3.
Does
the
HAF
have
a
waste
heat
boiler?
No.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

Note
that
many
of
the
above
comments
reference
PCDD/
PCDF
catches.
The
commenter
suggests
that
these
values
should
be
corrected
for
levels
found
in
the
field
blanks.
The
current
data
base
convention
is
to
use
uncorrected
catches
and
concentrations
(actual
levels
found
in
the
testing,
not
adjusted
for
field
blank
levels).
Typically,
field
blanks
(and
other
types
of
"blanks")
are
used
for
quality
assurance
and
quality
control
purposes
to
indicate
testing
problems,
not
to
actually
alter
measured
values.
Note
additionally,
that
either
way,
the
field
blank
levels
are
very
small,
and
the
difference
between
field
blank
corrected
and
un­
corrected
levels
are
insignificant.
Thus,
this
is
really
a
moot
issue.

5.7
Mallinckrodt
Inc.
(Phase
II
ID
#
778,
1000)

Mallinckrodt
(7)

Mallinckrodt
Inc.
Boiler
MACT
NODA
Review
Boiler
No.
1
Phase
II
ID
Number
778
Comment
1
Source
Description,
Combustor
Characteristics
­
Zinc
should
read
Zink.

Comment
2
Source
Description,
Capacity
­
19
should
read
18.6
(from
Combustor
Characteristics).
Please
adjust
on
Source
Description
Summary
Sheet
as
well.

Comment
3
Source
Description,
Supplement
Fuel
­
Natural
gas
is
fed
to
Boiler
No.
1
during
start­
up
and
shutdown
(Section
2.3
of
Recertification
of
Compliance
Notification
and
Test
Plan
for
Boiler
No.
1,
June
5,
1998).

Comment
4
Source
Description,
Permitting
Status
­
Adjusted
Tier
1
for
all
BIF
metals
and
chlorine/
chlorides
(Section
2.3
of
Recertification
of
Compliance
Test
Report
for
Boiler
No.
1,
August
27,
1998).

Comment
5
Source
Description,
Report
Name/
Date
­
The
date
for
the
Recertification
of
Compliance
Test
Report
for
Boiler
No.
1
should
be
changed
to
read
8/
27/
98.

Comment
6
Stack
Gas
Emissions,
778C10
­
Sampling
Train
1
consisted
of
particulate
matter
and
metals
and
Sampling
Train
2
consisted
of
hexavalent
chromium
(Cr
+6
).

Comment
7
Stack
Gas
Emissions,
778C10
­
Our
calculations
of
the
Cr
+6
values
from
g/
hr
to
g/
dscm
@
7%
O2
indicate
that
for
Runs
2
and
3
the
numbers
should
be
7.81
g/
dscm
@
7%
O2
and
7.12
g/
dscm
@
7%
O2
,
respectively.
Our
calculations
of
the
soot
blow
corrected
value
indicate
that
the
value
should
be
5.02
g/
dscm
@
7%
O2
.

Comments
8
Feedstreams,
778C10
­
Our
records
indicate
that
the
Condition
Averages
of
the
K083
liquid
waste
are
as
follows
(Table
8­
1
of
Recertification
of
Compliance
Test
Report
for
Boiler
No.
1,
August
27,
1998):

Parameter
Condition
Average
Ash
(lb/
hr)
0.17
Chlorine
(g/
hr)
50.7
Mercury
(g/
hr)
<
0.03
Lead
(g/
hr)
<
0.2
Cadmium
(g/
hr)
<
0.2
Arsenic
(g/
hr)
<
0.2
Beryllium
(g/
hr)
<
0.2
Chromium
(g/
hr)
1.3
Antimony
(g/
hr)
<
0.2
Please
adjust
the
Feedrate
MTEC
Calculations
to
reflect
these
changes.

Comment
9
Please
adjust
the
Emissions
and
Feedrate
Data
Summary
Sheets
to
include
all
of
the
above
comments.

Mallinckrodt
(7)

Mallinckrodt,
Inc.
Boiler
MACT
NODA
Review
Boiler
No.
2
Phase
II
ID
Number
1000
Comment
1
Source
Description,
Combustor
Characteristics
­
Zinc
should
read
Zink.
Comment
2
Source
Description,
Capacity
­
30
should
read
30.3
(from
Combustor
Characteristics).
Please
adjust
on
Source
Description
Summary
Sheet
as
well.

Comment
3
Source
Description,
Permitting
Status
­
Adjusted
Tier
I
for
all
BIF
metals
and
chlorine/
chlorides
(Section
2.3
of
Recertification
of
Compliance
Test
Report
for
Boiler
No.
2,
December
4,
1997).

Comment
4
Source
Description,
Number
1,
Content
­
Cr
+6
emissions
were
measured
as
well.

Comment
5
Our
records
indicate
that
the
MHRA
CO
values
for
Runs
3,
5,
and
6
are
3.8
ppmv,
9.9
ppmv,
and
9.8
ppmv,
respectively
(Table
7.3­
1
of
Recertification
of
Compliance
Test
Report
for
Boiler
No.
2,
December
4,
1997).

Comment
6
Stack
Gas
Emissions,
1000C1
­
Our
records
indicate
that
the
stack
gas
flow
rates
for
Runs
3,
5,
and
6
of
Sampling
Train
1
(PM/
Metals)
were
4100
dscfm,
4200
dscfm,
and
4400
dscfm,
respectively
(Table
2­
2,
Emission
Test
Results
for
Particulate,
Total
Chromium,
and
Cr+
6
from
Boiler
No.
2,
November
5,
1997).
Please
adjust
the
chromium
calculations
in
µg/
dscm
to
reflect
these
changes.

Comment
7
Feedstreams,
1000C1
­
Our
records
indicate
that
the
results
for
the
ash
and
chlorine
in
the
K083
feed
stream
are
as
follows
(Table
8­
1
of
Recertification
of
Compliance
Test
Report
for
Boiler
No.
2,
December
4,
1997):

Parameter
Run
3
Run
5
Run
6
Average
Ash
150.53
47.08
89.26
95.62
Chlorine
11.76
9.42
10.34
10.50
Comment
8
Please
adjust
the
Feedrate
MTEC
Calculations
to
account
for
the
correct
stack
gas
flow
rates
of
4100
dscfm,
4200
dscfm,
and
4400
dscfm
for
Runs
3,
5,
and
6,
respectively.

Comment
9
A
second
sampling
train
(Cr
+6
)
was
run
during
the
Recertification
of
Compliance
test
for
Boiler
No.
2.
Calculations
were
run
for
this
train
for
Boiler
No.
1,
but
omitted
for
Boiler
No.
2.
The
stack
gas
flow
rates,
O2
contents,
moisture
contents,
and
temperatures
for
each
run
are
presented
below
to
aid
in
these
calculations
for
Boiler
No.
2
(Table
2­
2,
Emission
Test
Results
for
Particulate,
Total
Chromium,
and
Cr+
6
from
Boiler
No.
2,
November
5,
1997).

Parameter
Run
3
Run
5
Run
6
Average
Stack
Gas
Flow
Rate
(dscfm)
4400
4600
4700
4566.67
O2
Content
(%)
8.8
8.2
8.2
8.4
Moisture
Content
(%)
11.1
10.5
10.8
10.8
Temperature
(°
F)
674.8
665.0
670.8
670.2
Comment
10
Please
adjust
the
Emissions
and
Feedrate
Data
Summary
Sheets
to
include
all
of
the
above
comments.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.8
DuPont
Dow
Elastomers
(Phase
II
ID
No.
854)

Dupont
Dow
Elastomers
(8)

DuPont
Dow
Elastomers
L.
L.
C.
(DuPont
Dow)
has
a
significant
interest
in
the
projected
standards
for
hazardous
air
pollutants
for
hazardous
waste
boilers
and
industrial
bumers
under
NESHAPS
[i.
e.,
the
Phase
II
Hazardous
Waste
Combustor
(HWC)
Maximum
Achievable
Control
Technology
(MACT)].
DuPont
Dow
Elastomers
owns
and
operates
at
its
Pontchartrain
Site
in
LaPlace,
LA
an
halogen
acid
furnace
combusting
hazardous
wastes.
Specific
comments
on
and
additional
information
not
included
in
the
Phase
II
HWC
MACT
rulemaking
database
are
delineated
and
provided
in
the
Enclosure.

DuPont
Dow
Elastomers
also
participated
with
DuPont,
the
American
Chemistry
Council
and
the
Louisiana
Chemical
Association
(LCA)
in
developing
comments
on
information
contained
with
the
Phase
11
HWC
MACT
rulemaking
database
and
incorporates
by
reference
the
DuPont,
American
Chemistry
Council
and
LCA
comments
within
this
submittal.
Attached
to
this
original
are
two
copies
of
the
comments
from
DuPont
Dow
Elastomers.
No
Confidential
Business
Information
is
included
with
this
submittal.

Sincerelv.

R.
Martin
Guidry
Technology
Associate
­
Environmental
ENCLOSURE
DUPONT
DOW
ELASTOMERS
L.
L.
C.
WILMINGTON,
DE
COMMENTS
REQUESTED
BY
THE
"NOTICE
OF
DATA
AVAILABILITY'9
FORTHE
"NESHAPS:
STANDARDS
FOR
HAZARDOUS
AIR
POLLUTANTS
FOR
HAZARDOUS
WASTE
BOILERS
AND
INDUSTRIAL
FURNACES
99
AUGUST
22,
2000
DuPont
Dow's
Stake
in
the
Issue
DuPont
Dow
Elastomers
L.
L.
C.
(DuPont
Dow)
is
a
5
015
0
j
oint
venture
company
formed
April
1,
1996
from
the
elastomer
businesses
and
technologies
of
E.
1.
dupont
de
Nemours
and
Company
and
Dow
Chemical
Company
­
­With
headquarters
in
Wilmington,
DE,
DuPont
Dow
had
revenues
of
approximately
$1.3
billion
in
1999
and
has
approximately
1400
employees
worldwide
­
of
which
about
1200
work
in
the
United
States.
DuPont
Dow
manufactures
a
suite
of
elastomeric
products
including
Neoprene,
Kalrezm,
Viton
,
Hypalon
TM
,
Tyrin
TM
,
NordelTM
IP
and
Engage
TM
that
are
used
in
the
automotive,
wire
and
cable,
adhesives,
semiconductor,,
aerospace,
chemical
processing,
construction
and
rubber
industries.
Its
U.
S.
manufacturing
facilities
are
located
in
Louisiana,
Kentucky,
Texas,
New
Jersey,
Delaware
and
Maryland.

DuPont
Dow
Neoprene
operations
may
be
impacted
significantly
by
the
Phase
II
HWC
MACT
rulemaking
since
DuPont
Dow
owns
and
operates
at
its
LaPlace,
LA
Pontchartrain
Site
an
halogen
acid
furnace
combusting
hazardous
wastes
from
the
Pontchartrain
Site
and
from
the
DuPont
Dow
Louisville,
KY
Neoprene
manufacturing
facility.
DuPont
Dow,
therefore,
has
a
vital
interest
in
ensuring
that
the
"NESHAPS:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Boilers
and
Industrial
Furnaces"
[i.
e.,
the
Phase
II
Hazardous
Waste
Combustor
(HWC)
Maximum
Achievable
Control
Technology
(MACT)]
rulemaking
database
is
correct
and
contains
the
most
recent
test
results.
Furthermore,
it
is
imperative
that
the
assumptions
and
guidelines
used
in
developing
the
database
are
correct
and
consistent
with
other
USEPA
programs.

Corrections
to
Testing
Data
Contained
in
the
"Phase
II
HWC
MACT
Data
Base
Report"

Sections
VI.
4
and
VI.
5
of
the
"NESHAPS:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Boilers
and
Industrial
Furnaces:
Notice
of
Data
Availability"
(i.
e.,
Phase
II
HWC
@CT
NODA)
[65
FR39583]
request
corrections
to
data
in
the
Phase
11
HWC
MACT
Data
Base
Report
and
missing
information
in
this
report.
Specific
corrections
and
missing
information
for
the
DuPont
Dow
Elastomers
Pontchartrain
Site
halogen
acid
furnace
are
detailed
below.
Attachment
I
provides
documentation
for
these
corrections.
Attachment
II
contains
documentation
of
missing
information.

Specific
corrections
to
the
"Data
and
Information
File
for
Individual
Sources"
include:

In
the
"Source
Description"
table
under
'APCS
Characteristics'
the
information
should
state
that
water
is
used
in
the
primary,
secon@
l­
tertiary
and
vent
scrubbers
and
that
caustic
is
used
in
the
Dynawave
scrubber.
[See
page
A­
I
of
Attachment
1.]

In
the
"Source
Description"
table
under
'Supplemental
Fuel'
the
information
should
state
that
natural
gas
is
used
during
startup
and
shutdown
(including
automatic
waste
feed
cutoff
conditions),
but
is
not
used
during
normal
operations
when
hazardous
waste
is
fed
to
the
halogen
acid
furnace.
[See
page
A­
2
of
Attachment
1.]

In
the
"Source
Description"
table
under
'Stack
Characteristics'
the
diameter
of
the
halogen
acid
furnace
stack
at
the
tip
is
1.5
feet.
[See
Precompliance
Certification
Fon­
n
4
(PC­
4C)
in
the
Revised
BIF
Certification
of
Precompliance
(1
1/
9/
92)
within
Attachment
11.]

In
the
"Source
Description"
table
under
'Permitting
Status'
DuPont
Dow
Elastomers
L.
L.
C.
submitted
a
RCRA
Class
3
Permit
Modification
Request
to
the
USEPA
and
the
Louisiana
Department
of
Environmental
Quality
(LDEQ)
on
February
17,
1992
to
permit
the
Pontchartrain
Site
halogen
acid
furnace
within
the
Pontchartrain
Site
RCRA
hazardous
waste
permit
(LADOO
1
8903
67).
The
USEPA
and
the
LDEQ
are
still
reviewing
this
Class
3
Permit
Modification
Request.
Currently
the
halogen
acid
furnace
operates
under
Tier
I
for
carbon
monoxide,
Adjusted
Tier
I
for
all
BIF
metals
except
chromium
and
Tier
III
for
chromium,
chlorine
and
hydrogen
chloride.
[See
Submittal
Letter
of
RCRA
Class
3
Permit
Modification
and
Certification
of
Compliance
Test
Forms
3
(CC­
3)
and
5
(CC­
5)
in
Attachment
11.]

In
the
"Feedstreams"
table
the
'Total
Feedrate'
during
the
halogen
acid
furnace
Risk
Assessment
Trial
Bum
averaged
4331
lbs/
hour.
This
value
should
replace
the
estimated
value
in
the
table
of
3
885.9
lbs/
hour.
[See
the
Plant
Operational
Data
at
the
end
of
Attachment
I.]

In
the
"Feedstreams"
table
the
"Estimated
Firing
Rate"
should
be
48.2
Btu/
hr.
This
is
calculated
by
multiplying
the
"Total
Feedrate"
of
4331
lbs/
hr
by
the
"Heat
Content"
of
0.01
1
140
Btu/
lb.
This
value
should
replace
the
43.3
tu/
hr
in
the
table.
This
change
should
be
made
also
on
the
"Emissions
and
Feedrate
Summary
Sheet"
tab
e@­[
See
the
Plant
Operational
Data
at
the
end
of
Attachment
I
for
the
"Total
Feedrate"
and
page
21
of
Attachment
I
for
the
"Heat
Content".]

In
the
"Feedstreams"
table
the
'Viscosity'
of
the
feed
stream
during
the
halogen
acid
furnace
Risk
Assessment
Trial
Bum
was
<6.0
cps.
This
value
should
replace
the
incorrect
value
of
6
cps
in
the
table.
[See
page
21
of
Attachment
1.]
Currently
the
"Process
Information"
table
has
no
information
for
the
Pontchartrain
Site
halogen
acid
furnace.
Pages
A­
1
through
A­
1
1,
B­
1,
C­
1
through
C­
2
and
the
extensive
data
in
the
Plant
Operational
Data
section
of
Attachment
I
provides
substantial
information
on
non­
feed
rate
related
process
operating
data
that
could
be
included
in
this
table.

Response:
None
of
the
information
found
in
the
attachments
was
determined
appropriate
for
including
in
the
process
information
sheet.

In
the
"Stack
Gas
Emissions
&
Feedrate
Characteristics"
table
the
'Hg
Other'
column
should
contain
zero,
the
'Hg
Spike'
column
should
contain
zero,
the
'SVM
Other'
column
should
contain
zero,
the
'SVM
Spike'
column
should
contain
zero,
the
'LVM
Other'
colum­
n
should
contain
zero,
the
'LVM
Spike'
column
should
contain
zero,
the
'LVM
ND'
column
should
contain
5.6,
the
'TCI
Other'
column
should
contain
zero,
the
'TCI
Spike'
column
should
contain
zero,
the
'Ash
Other'
column
should
contain
zero
and
the
'Ash
Spike'
column
should
contain
zero.
The
Risk
Assessment
Trial
Burn
involved
no
spiking
of
feed
materials
and
had
a
single,
composite
feed
stream
which
was
liquid
chlorinated
hazardous
waste.
These
same
corrections
should
also
be
made
to
the
"Emissions
and
Feedstream
Summary
Sheet­
Condition
Averages".
[See
page
21
of
Attachment
I.]

Response:
Where
the
"ND
%"
and
"spike
%"
cells
have
been
left
blank,
this
implies
that
the
value
is
either
zero,
or
insufficient
information
is
available
to
determine
the
nd
of
spike
%.
Thus,
no
changes
are
made.

Most
Recent
Test
Data
for
the
DuPont
Dow
Elastomers
Pontchartrain
Site
Halogen
Acid
Furnace
As
requested
in
Section
VI.
5
of
the
"NESHAPS:
Standards
for
Hazardous
Air
Pollutants
for
Hazardous
Waste
Boilers
and
Industrial
Furnaces:
Notice
of
Data
Availability"
(i.
e.,
BIF
NODA)
[65
FR39583],
Attachment
11
contains
more
recent
test
data
for
the
DuPont
Dow
Elastomers
Pontchartrain
Site
halogen
acid
furnace
than
that
contained
in
the
Phase
II
HWC
MACT
Data
Base
Report.
The
Pontchartrain
Site
halogen
acid
furnace
test
data
currently
in
the
Phase
11
HWC
MACT
Data
Base
Report
is
from
the
Risk
Assessment
Trial
Bum
conducted
on
April
23­
24,
1997.
Attachment
II
contains
the
Permit
Trial
Bum
test
data
for
the
Pontchartrain
Site
halogen
acid
furnace
that
was
conducted
on
April
25­
26,
1997
and
the
Supplemental
Trial
Bum
test
data
for
this
unit
conducted
on
September
2­
3,
1997.
The
Permit
Trial
Bum
and
Supplemental
Trial
Bum
also
constitute
the
most
recent
Certification
of
Compliance
Test
for
the
Pontchartrain
Site
halogen
acid
furnace;
therefore,
Attachment
11
also
contains
the
most
recent
Certification
of
Compliance
Test
forms
for
the
Pontchartrain
Site
halogen
acid
furnace
.

The
information
being
submitted
in
Attachment
11
includes
the
submittal
letters
to
the
U.
S.
Environmental
Protection
Agency
(USEPA),
the
cover
pages
of
the
test
reports,
the
summary
pages
containing
the
test
results
and
the
detailed
operating
conditions
of
the
halogen
acid
furnace
during
the
Permit
Trial
Bum
and
the
Supplemental
Trial
Bum
including
the
hazardous
waste
feed
rates
during
these
test
bums.
Also
included
are
the
Certification
of
Compliance
Test
forms
for
the
halogen
acid
furnace.

Although
the
Permit
Trial
Bum
and
Supplemental
Trial
Bum
test
data
do
not
contain
dioxin/
furan
emissions
data,
they
do
contain
hydrogen
chloride,
chlorine,
carbon
monoxide,
oxygen,
particulates
and
metals
emissions
data.
Since
the
Permit
Trial
Bum
and
Supplemental
Trial
Bum
were
conducted
at
conditions
that
stressed
the
halogen
acid
furnace
operating
range,
data
from
these
test
conditions
are
more
representative
for
the
Phase
11
HWC
MACT
selection
process
than
data
from
the
Risk
Assessment
Trial
Bum
where
the
halogen
acid
furnace
operated
in
a'minimal
stress
condition.

DuPont
Dow
Elastomers
requests
that
the
USEPA
include
the
April
25­
26,
1997
Permit
Trial
Bum
test
data
and
the
September
2­
3,
1997
Supplemental
Trial
Bum
test
data
in
the
Phase
II
HWC
MACT
Data
Base
Report.
Furthermore,
where
these
test
data
contain
feed
and
emissions
data
being
determined
by
the
Phase
11
HWC
MACT
selection
process,
DuPont
Elastomers
requests
that
the
Permit
Trial
Bum
and
the
Supplemental
Trial
Bum
test
data
be
used
rather
than
test
data
from
the
Risk
Assessment
Trial
Bum.
The
Permit
Trial
Bum
and
the
Supplement
Trial
Bum
test
data
are
more
recent
and
are
more
representative
of
the
data
required
for
the
Phase
II
HWC
MACT
selection
process.

Response:
The
newly
supplied
permit
trial
burn
and
supplemental
trial
burn
data
have
been
added
to
the
data
base.
As
the
most
recent
compliance
test,
it
will
be
used
to
represent
the
unit
performance.

Attachments:
New
trial
burn
and
supplemental
trial
burn
for
unit
ID
No.
853.

Response:
As
mentioned
above
in
Section
3.1,
these
new
test
condition
data
have
been
added
to
the
data
base.

5.9
Celanese
Ltd,
Bay
City
(Phase
II
ID
#
721)

Celanese
(10)

Source
Description
Boiler
No.
4,
and
its
sister
facility
Boiler
No.
5,
is
a
C­
E
Type
VU­
60
boiler
each
rated
at
350,000­
pounds/
hour­
steam
generation.
For
clarification
only
one
boiler
performs
as
a
BIF
at
any
time;
the
other
will
either
be
idled
or
burning
natural
gas
and
process
vent
gases
for
steam
production
as
a
regular
boiler.

Soot
Blowing
of
the
air
preheater
has
since
been
discontinued.
None
in
the
combustion
zone.
Haz
Waste
Description
should
read:

"V­
1041
(Vinyl
Acetate
Unit's
waste
organics)
and
V­
683
(combined
OXO
Units'
liquid
waste)"...

Stack
Characteristics
Height
(ft):
Top
of
stack
is
50.5
ft
above
grade.
Gas
inlet
centerline
is
~16
1
1/
2"
above
grade.

Gas
Velocity:
The
average
for
the
PM
testing
in
runs
7,
8,
and
9
was
2,997
arpm
and
83,806
dry
scrim.
Permitting
Status
Should
be
adjusted
Tier
l...

Report
Name/
Date
"Trial
Burn/
Risk
Bum
Report,
Boiler
4,
Celanese
Ltd"/
November
1998
Report
Preparer:

TRC
Environmental
Corporation,
Houston,
TX
(section
removed
and
addressed
in
a
previous
section)

Emissions
&
Feedrate
Data
Summary
Sheet
Condition
ID
721C12
­­
Condition
should
read
"Risk
burn;
typical
feedrate."

Observation
The
PDF
files
have
errors.
The
EXCEL
spreadsheet
seems
to
be
correct.

Conclusion:

If
the
revisions
noted
arc
made
the
spreadsheet
version
for
Phase
II
ID
No.
721
will
be
correct.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

Also,
regarding
the
very
last
comment,
the
Excel
files
and
corresponding
PDF
files
were
investigated
for
accuracy
and
found
to
be
the
same.
Because
no
specific
examples
were
provided
by
the
commenter,
EPA
can
not
make
any
further
assessment,
response,
or
actions.

5.10
Eastman
Chemical
Company,
Kingsport,
Tennessee
(Phase
II
ID
#
717,
719,
1011,
and
1012)

Comment
and
Response
Eastman
Chemicals
Tennessee
(11)

First,
commenter
requested
through
handwritten
notes
on
copy
of
Excel
spreadsheets,
some
very
minor
changes
to
data
base.
Changes
have
been
made
as
requested.
Changes
included:
for
unit
No.
719,
identification
of
Cl2
runs
at
non­
detect
and
full
detection
limit
instead
of
reporting
at
one­
half
of
the
detection
limit
and
not
identifying
runs
as
non­
detect
(although
these
does
not
result
in
any
change
in
the
actual
levels
that
are
used),
and
correction
to
Be
stack
gas
emissions
rate
(cut
in
half
inadvertantly).
For
unit
ID
No.
717,
changes
included:
steam
pressure
at
1500
psi
not
150
psi,
and
Hg
in
coal
feed
is
non­
detect
(in
database
shown
as
detected),
although
no
impact
on
the
calculated
value
(shown
correctly
at
one­
half
of
detection
limit).
These
minor
changes
have
not
documented
in
Table
3.

Next,
commenter
enclosed
detailed
recalculation
of
SVM
and
LVM
emissions
for
units
717,
719,
1011,
and
1012.
In
particular,
for
proper
consideration
and
reporting
of
non­
detect
measurements
in
the
front
half
and
back
half
of
the
multi­
metals
sampling
trains.
These
are
addressed
in
detail
in
the
above
Section
4.
Specifically,
changes
are
made
as
requested
to
conform
with
the
standard
convention
as
documented
by
commentor
(i.
e.,
considering
measurements
as
fully
detected
when
atleast
the
front
half
or
back
half
measurement
is
detected).

5.11
Celanese
Ltd.
Clear
Lake
Plant
(Phase
II
ID
#
720)

Celanese
(12)

Stack
Characteristics
Height
(ft)
133
Firing
rate
for
the
condition
listed
in
the
database:

5.1
MMBtu/
hr
liquid
waste
methanol
3.3
MMBtu/
hr
vent
gas
27.0
MMBtu/
hr
natural
gas
Total
firing
rate
of
35.4
MMBtu/
hour
Design
firing
rate
of
MH5A
is
~68
MMBtu/
hr.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.12
Georgia
Gulf
(Phase
II
ID
No.
855,
2000)

Georgia
Gulf
Corporation
(13)

Georgia
Gulf
Chemicals
and
Vinyls,
LLC
(GGCV)
submits
comments
on
docket
number
F2000­
RC2A­
FFFFF,
as
requested
by
the
U.
S.
Environmental
Protection
Agency
(US
EPA)
in
the
Federal
Register
dated
June
27,
2000.
These
comments
are
being
submitted
to
correct
and/
or
append
the
US
EPA's
database
that
will
be
used
to
propose
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(NESHAPS)
for
hazardous
waste
burning
boilers,
halogen
acid
furnaces,
and
sulfuric
acid
recovery
furnaces.

In
this
correspondence,
GGCV
is
submitting
comments
on
the
hazardous
waste
combustion
units
assigned
Phase
II
ID
No.
's
855
and
2000.
Unit
no.
855
refers
to
GGCV's
IN­
662
or
Industrial
Furnace
for
VCM
and
EDC
production
units.
Unit
no.
2000
refers
to
GGCV's
Nebraska
Boiler.
All
supporting
documentation
for
these
comments
will
be
numbered
to
reference
the
specific
comment
and
will
appear
in
the
appendix.
GGCV
assumes
that
the
US
EPA
will
correct
all
Feedrate
MTEC
Calculations
using
the
corrected
data
submitted
in
these
comments.

Comments
for
Phase
11
ID
No.
855
1.
Under
the
section
for
Source
Description,
Facility
Name
should
be
changed
to
Georgia
Gulf
Chemicals
and
Vinyls,
LLC.

2.
Under
the
section
for
Source
Description,
Haz
Waste
Description
should
read
Liquid
wastes
­­
Heavy
ends
from
the
distillation
of
ethylene
dichloride
in
ethylene
dichloride
production
(KO
1
9).
This
is
the
waste
description
as
it
appears
in
the
Louisiana
Department
of
Environmental
Quality's
Environmental
Regulations,
LAC
33:
V.
Chapter
22,
Table
2.

3.
Under
the
section
for
Source
Description,
Stack
Characteristics,
the
Gas
Temperature
(F)
should
read
104.39
F.

4.
Under
the
section
for
Source
Description,
Stack
Characteristics,
the
Velocity
(ft/
s)
should
read
59
ft/
s.

5.
Under
the
section
for
Source
Description,
Permitting
Status
should
read
"Permitted
as
an
incinerator;
will
be
repennitted
as
a
HAF."
The
unit's
classification
has
been
changed
from
that
of
"Incinerator"
to
"BIF
Halogen
Acid
Furnace"
via
a
Louisiana
Department
of
Environmental
Quality
initiated
Class
I
permit
modification.

6.
Under
the
section
for
Source
Description,
Number
11,
the
Report
Preparer
should
read
Environmental
Science
&
Engineering,
Inc.

7.
Under
the
section
for
Source
Description,
Number
12,
the
Cond
Description
should
read
Trial
bum
­­
heavy
liquid
waste
feed
and
wet/
dry
vent
streams.
The
waste
stream
descriptions
for
Numbers
12
and
13
should
be
identical,
since
the
wastes
are
the
same.

8.
Under
the
section
for
Stack
Gas
Emissions,
855CIO,
POHC
DRE,
the
Cond
Avg
for
DRE
should
read
99.999984.

9.
Under
the
section
for
Stack
Gas
Emissions,
855CIO,
POHC
DRE,
the
Cond
Avg
for
Feedrate
should
read
105.89.

10.
Under
the
section
for
Stack
Gas
Emissions,
855CI
1,
CO
(RA)
(not
adjusted),
the
Cond
Avg
should
read
0.39.

11.
Under
the
section
for
Stack
Gas
Emissions,
855CI
1,
HCI
(lb/
hr),
the
Cond
Avg
should
read
0.069.

12.
Under
the
section
for
Stack
Gas
Emissions,
855Cl
1,
C12
(lb/
hr),
the
Cond
Avg
should
read
0.789.

13.
Under
the
section
for
Stack
Gas
Emissions,
855Cl2,
HCI
(lb/
hr),
the
Cond
Avg
should
read
2.197.

14.
Under
the
section
for
Stack
Gas
Emissions,
855C12,
C12
(lb/
hr),
the
Cond
Avg
should
read
1.39.

15.
Under
the
section
for
Stack
Gas
Emissions,
855C13,
POHC
DRE,
1,1,2­
trichloroethane
DRE,
the
Cond
Avg
should
read
>
99.9999.

Response:
Condition
averages
are
not
calculated
and
not
shown
in
the
data
base
for
"intermediate"
calculations
and
in
cases
where
further
units
conversions
are
to
be
made
(e.
g.,
when
the
value
is
in
a
mass
emissions
rate
as
opposed
to
the
final
desired
gas
concentration).
Also,
condition
averages
for
DRE
are
not
appropriate
and
not
calculated
or
reported.
Note
that
the
condition
average
for
DRE
is
not
strictly
the
arithmatic
average
on
the
individual
run
condition
averages.
Instead,
a
true
and
correct
DRE
condition
average
would
be
determined
as
the
ratio
of
total
POHC
emissions
over
all
three
runs
to
the
total
POHC
feed
rate
over
all
three
runs.
This
is
not
the
same
as
the
condition
average
of
each
individual
run
DRE.

16.
Under
the
section
for
Stack
Gas
Emissions:

855C
12,
POHC
DRE,
1,
1,2­
trichloroethane,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
22057,
22045,
and
23345,
respectively.
The
Cond
Avg
should
read
22482.
855CI3,
POHC
DRE,
1,1,2­
trichloroethane,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
21132,
21213,
and
21276,
respectively.
The
Cond
Avg
should
read
21207.

17.
Under
the
section
for
Stack
Gas
Emissions:

855CI2,
POHC
DRE,
Tetrachloroethylene,
DRE,
the
Cond
Avg
should
read
99.9990.
855Cl3,
POHC
DRE,
Tetrachloroethylene,
DRE,
the
Cond
Avg
should
read
99.9974.

18.
Under
the
section
for
Stack
Gas
Emissions:

855CI2,
POHC
DRE,
Tetrachloroethylene,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
877,
1
1
00,
and
1077,
respectively.
The
Cond
Avg
should
read
101
8.

855Cl3,
POHC
DRE,
Tetrachloroethylene,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
717,
1059,
and
1149,
respectively.
The
Cond
Avg
should
read
975.

19.
Under
the
section
for
Stack
Gas
Emissions:

855CI2,
POHC
DRE,
Hexachloroethane,
DRE,
the
Cond
Avg
should
read
99.9917.
855Cl3,
POHC
DRE,
Hexachloroethane,
DRE,
the
Cond
Avg
should
read
99.9923.

20.
Under
the
section
for
Stack
Gas
Emissions:

855C
1
2,
POHC
DRE,
Hexachloroethane,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
17,
21,
and
22,
respectively.
The
Cond
Avg
should
read
20.

8
5
5
C
13,
POHC
DRE,
Hexachloroethane,
Feedrate,
the
Feedrates
(g/
min)
for
Runs
1,
2,
and
3,
should
read
24,
18,
and
17,
respectively.
The
Cond
Avg
should
read
20.

Response:
These
above
requested
changes
to
POHC
feedrates
are
not
significant.
We
have
not
made
these
changes
because
the
differences
between
the
NODA
data
base
and
suggested
changes
are
very
small.
Note
also
that
the
POHC
DREs
that
are
in
the
data
base
are
correct
based
on
the
precise
feedrates
and
those
reported
in
the
test
report.

21.
Under
the
section
for
Feedstreams,
855
C12
and
C13,
the
Cond
Avg
for
(Total
Feedrate)
in
g/
min
and
L/
min
should
read
49583.5
and
37.85,
respectively.
This
data
was
miscalculated
and
should
be
the
average
of
Runs
1
through
6.
22.
Under
the
section
for
Feedstreams,
855CI2
and
C13,
the
Cond
Avg
for
Cr
(mg/
L)
should
read
0.9.
This
data
was
incorrectly
rounded­
off
to
a
whole
number.

23.
Under
the
section
for
Feedstreams,
855CI2
and
C13,
the
Cond
Avg
for
Gas
Flowrate
(dscfin)
should
read
10635.
The
value
that
currently
appears
is
the
average
for
Runs
4,
5,
and
6.
The
value
in
this
comment
is
the
average
for
Runs
I
through
6.

24.
Under
the
section
for
Fecdstreams,
855
C12
and
C13,
the
Cond
Avg
for
Oxygen
should
read
8.66.
The
value
that
currently
appears
is
the
average
for
Runs
4,
5,
and
6.
The
corrected
value
in
this
comment
is
the
average
for
Runs
I
through
6.

25.
Under
the
section
for
Process
Information,
855Cl2
and
C13,
the
Cond
Avg
for
Steam
Production
(lb/
hr)
should
read
36823.
This
is
the
average
of
Runs
I
through
6.

26.
Under
the
section
for
Process
Information,
855C12
and
C13,
the
Cond
Avg
for
Natural
Gas
Feed
(scfh)
should
read
2812.
This
is
the
average
of
Runs
I
through
6.

27.
Under
the
section
for
Process
Information,
855C12
and
C13,
the
Cond
Avg
for
Boiler
exit
temperature
(F)
should
read
592.
This
is
the
average
of
Runs
I
through
6.

28.
Under
the
section
for
Process
Information,
855C12
and
C13,
Fume
Scrubber,
the
Cond
Avg
for
Liquor
pH
should
read
8.6.
This
is
the
average
of
Runs
1
through
6.

29.
Under
the
section
for
Process
Information,
855C12
and
C13,
Fume
Scrubber,
the
Cond
Avg
for
Water
feed
(gal/
min)
should
read
11.5.
This
is
the
average
of
Runs
1
through
6.

30.
Under
the
section
for
Process
Information,
855CI2
and
C13,
Fume
Scrubber,
the
Cond
Avg
for
Liquor
feed
(gal/
min)
should
read
342.
This
is
the
average
of
Runs
I
through
6.

Response:
The
commenter
has
correctly
noted
that
the
feedrate
results
of
C12
and
C13
were
incorrectly
presented
and
combined
as
a
single
test
condition
(we
incorrectly
assumed
they
were
the
same
test
condition
because
the
feedrates
were
identical).
However,
as
the
commenter
notes,
the
stack
gas
conditions
are
not
identical.
Thus,
the
revised
data
base
has
properly
separated
C12
from
C13
as
two
distinct
test
conditions,
with
C12
comprising
runs
1­
3,
and
C13
comprising
runs
4­
6.

Comments
for
Phase
II
ID
No.
2000
31.
Under
the
section
for
Source
Description,
Facility
Name
has
been
changed
to
Georgia'
Gulf
Chemicals
and
Vinyls,
LLC.

32.
Under
the
section
for
Source
Description,
Haz
Waste
Description
should
read
Liquid
wastes
­­
Distillation
bottom
tars
from
the
production
of
phenol/
acetone
from
cumene
(KO22).
This
is
the
waste
description
as
it
appears
in
the
Louisiana
Department
of
Environmental
Quality's
Environmental
Regulations,
LAC
33:
V.
Chapter
22,
Table
2.
33.
Under
the
section
for
Source
Description,
Stack
Characteristics,
Diameter
(ft),
Height
(ft),
Gas
Velocity
(ft/
sec)
and
Gas
Temperature
(F)
should
read
6.7,
100,
50
and
460,
respectively.

34.
Under
the
section
for
Source
Description,
Condition
1
and
Condition
3,
Content,
the
word
acetephenone
is
misspelled
and
should
read
acetophenone.

35.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
HCI
(g/
s),
the
Cond
Avg
should
read
0.000192.

36.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
C12
(g/
s),
the
Cond
Avg
should
read
0.00045.

37.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
Benzene
(g/
s),
the
Cond
Avg
should
read
0.0072.

38.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
POHC
DRE,
Cumene
the
Cond
Avg
should
read
99.99501
.

39.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
POHC
DRE,
Phenol
the
Cond
Avg
should
read
99.999913.

40.
Under
the
section
for
Stack
Gas
Emissions,
2000C
1
Trial
Bum,
POHC
DRE,
the
word
Acetephenone
is
misspelled
and
should
read
Acetophenone.

41.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
POHC
DRE,
Acetophenone
(%),
the
Cond
Avg
should
read
99.999823.

42.
Under
the
section
for
Stack
Gas
Emissions,
200OC1
Trial
Bum,
Sampling
Train
2
DRE,
Gas
Flowrate
(dscfrn),
the
Cond
Avg
should
read
41119.8.

43.
Under
the
section
for
Stack
Gas
Emissions,
2000C
I
Trial
Bum,
Sampling
Train
2
DRE,
Oxygen
(%),
the
Cond
Avg
should
read
13.025.

44.
Under
the
section
for
Stack
Gas
Emissions,
2000C
1
Trial
Bum,
Sampling
Train
2
DRE,
Moisture
(%),
the
Cond
Avg
should
read
14.56.

45.
Under
the
section
for
Stack
Gas
Emissions,
20OOCl
Trial
Bum,
SamplingTrain
2­
DRE,
Gas
Temperature
(F),
the
Cond
Avg
should
read
477.76.

46.
Under
the
section
for
Stack
Gas
Emissions,
200OC2
Risk
Bum,
POHC
DRE,
Cumene
(%),
the
Cond
Avg
should
read
99.99944.

47.
Under
the
section
for
Stack
Gas
Emissions,
200OC2
Risk
Bum,
POHC
DRE,
Phenol
(%),
the
Cond
Avg
should
read
99.99994.
48.
Under
the
section
for
Stack
Gas
Emissions,
200OC2
Risk
Bum,
POHC
DRE,
the
word
Acetephenone
is
misspelled
and
should
read
Acetophenone.

49.
Under
the
section
for
Stack
Gas
Emissions,
200OC2
Risk
Bum,
POHC
DRE,
Acetophenone
(%),
the
Cond.,
kvg
should
read
99.99986.

50.
Under
the
section
for
Stack
Gas
Emissions,
200OC2
Risk
Bum,
Sampling
Train
1
­
PM,
the
Gas
Flowrate
(avg)
(dscfrn)
for
Runs
1,
2,
and
3
should
read
26895.1,
29069.7,
and
26223.
1,
respectively.
The
Cond
Avg
should
read
27,396.
This
data
was
not
calculated
in
the
Trial
Bum
Report.
The
supporting
data
in
the
appendix
uses
data
from
Table
3.2.2
from
the
Trial
Bum
Report
to
calculate
the
Gas
Flowrate.
Table
3.2.2
from
the
Trial
Bum
Report,
along
with
the
calculations,
are
attached
in
the
appendix
for
reference.

51.
Under
the
section
for
Stack
Gas
Emissions,
200OC3
DRE
Bum,
POHC
DRE,
Cumene
(%),
the
Cond
Avg
should
read
99.9815.

52.
Under
the
section
for
Stack
Gas
Emissions,
200OC3
DRE
Bum,
POHC
DRE,
Phenol
the
Cond
Avg
should
read
99.99976.

53.
Under
the
section
for
Stack
Gas
Emissions,
200OC3
DRE
Bum,
POHC
DRE,
the
word
Acetephenone
is
misspelled
and
should
read
Acetophenone.

54.
Under
the
section
for
Stack
Gas
Emissions,
200OC3
DRE
Bum,
POHC
DRE,
Acetophenone
(%),
the
Cond
Avg
should
read
99.99952.

55.
Under
the
section
for
Stack
Gas
Emissions,
200OC4
Cr+
6
Bum,
HCI
(g/
s),
the
Cond
Avg
should
read
0.000192.

56.
Under
the
section
for
Stack
Gas
Emissions,
200OC4
Cr+
6
Bum,
C12
(g/
s),
the
Cond
Avg
should
read
0.000192.

57.
Under
the
section
for
Stack
Gas
Emissions,
200OC4
Cr+
6
Bum,
Cr+
6
(g/
hr),
the
Cond
Avg
should
read
14.72.

58.
Under
the
section
for
Stack
Gas
Emissions,
200OC4
Cr+
6
Bum,
an
MTEC
Calculation
is
performed
for
Cr+
6.
It
is
inappropriate
to
report
this
calculation
in
this
section
and
it
should
be
removed,
as
it
is
properly
reported
in
the
Feedrates
section.

Response:
This
is
not
an
MTEC
calculation.
It
is
a
direct
conversion
of
a
stack
gas
emissions
rate
from
a
mass
emissions
rate
to
a
stack
gas
emissions
concentration.
It
is,
of
course,
similar
in
nature
to
an
MTEC
calculation.

59.
Under
the
section
for
Feedrates,
2000C
I
Trial
Bum,
Feedrate
(gpm)
for
Mixed
Oil
should
read
12.983.
60.
Under
the
section
for
Feedrates,
200OC1
Trial
Bum,
Viscosity
(cSt)
for
Mixed
Oil
should
read
1073.

61.
Under
the
section
for
Feedrates,
200OC1
Trial
Bum,
Specific
Gravity
for
Mixed
Oil
and
Quench
Water
should
read
1.09
and
1.006,
respectively.

62.
Under
the
section
for
Feedrates,
2000C
I
Trial
Bum,
Ash
(wt
%)
for
Mixed
Oil
should
read
0.062.

63.
Under
the
section
for
Feedrates,
200OC1
Trial
Bum,
Acetophenone
(ppmw)
for
Mixed
Oil
should
read
28200.

64.
Under
the
section
for
Feedrates,
2000CI
Trial
Bum,
Ethyl
Benzene
(ppmw)
for
Mixed
Oil
should
read
370.

65.
Under
the
section
for
Feedrates,
2000C
I
Trial
Bum,
1
­Methyl
Propyl
Benzene
(ppmw)
for
Mixed
Oil
should
read
1820.

66.
Under
the
section
for
Feedrates,
200OC1
Trial
Bum,
Phenol
(ppmw)
for
Mixed
Oil
should
read
54000.

67.
Under
the
section
for
Feedrates,
2000C
I
Trial
Bum,
Estimated
Firing
Rate
(MMBTU/
hr)
for
Mixed
Oil
should
read
93.3.

68.
Under
the
section
for
Feedrates,
2000CI
Trial
Burn,
Feedrate
MTEC
Calculations,
the
EPA
spreadsheet
equation
for
Chlorine
contains
an
error
and
references
the
wrong
cell
in
the
spreadsheet.
Once
the
cell
reference
is
corrected,
the
resulting
calculation
will
be
correct.

69.
Under
the
section
for
Feedrates,
200OC2
Risk
Bum,
Be
(ppmw)
for
Quench
Water
should
read
0.01.

70.
Under
the
section
for
Feedrates,
200OC2
Risk
Bum,
Estimated
Firing
Rate
(MMBTU/
hr)
for
Mixed
Oil
should
read
83.9.

71.
Under
the
section
for
Feedrates,
200OC3
DRE
Bum,
the
units
for
Viscosity
should
read
cSt
(for
centistokes).

72.
Under
the
section
for
Feedrates,
200OC3
DRE
Bum,
Acetophenone
(ppmw)
for
Mixed
Oils
should
read
20333.

73.
Under
the
section
for
Feedrates,
200OC3
DRE
Bum,
Estimated
Firing
Rate
(MMBTU/
hr)
for
Mixed
Oil
should
read
70.
1.

74.
Under
the
section
for
Feedrates,
200OC4
Cr+
6
Bum,
Firing
Rate
(MMBTU/
hr)
was
not
calculated.
The
value
should
read
85.6
MMBTU/
hr.
The
Heating
Value
was
not
one
of
the
parameters
for
which
the
feedstream
was
analyzed
during
200OC4.
The
85.6
MMBTU/
hr
value
was
calculated
using
the
feedrate
from
200OC4
and
the
average
heating
value
(1
6,000
BTU/
lb)
from
the
other
runs
in
the
Trial
Bum
Report.

Response:
As
a
reasonable
estimate,
the
data
base
will
continue
to
use
an
estimate
of
the
heating
value
from
other
runs
to
represent
that
of
C4.

75.
Under
the
section
for
PCDD/
PCDF,
the
Total
for
OCDF
under
Run
2
should
read
0.29.

76.
Under
the
section
Emissions
and
Feedrate
Data
Summary
Sheet
­­
condition
averages,
@
7%
02,
the
Estimated
Firing
Rate
was
used
for
the
Heat
Input
Rate
(MM
Btu/
hr)
for
200OC3
and
200OC4.
This
is
inconsistent
with
the
data
for
2000C
1
and
200OC2,
as
well
as
for
Unit
ID
No.
855.
The
Heat
Input
Rate
for
200OC3
and
200OC4
should
read
29.9
and
68.5,
respectively.

77.
Under
the
Feedrate
Characteristics
Summary
Sheet,
the
data
presented
in
this
table
is
inconsistent.
Some
of
these
values
are
at
1/
2the
detection
limit,
while
others
are
reported
at
the
detection
limit.
Georgia
Gulf
Chemicals
&
Vinyls,
LLC
(GGCV)
is
providing
the
data
both
at
the
detection
limit
and
at
1/
2the
detection
limit.
GGCV
recommends
that
EPA
select
the
data
that
is
most
appropriate
to
use
in
this
summary
sheet.

The
data
for
Hg
(mercury)
for
200OC2
should
read
10.9
ug/
dscm
at
the
detection
limit
and
5.4
ug/
dscm
at
1/
2
the
detection
limit.
The
data
for
TCI
(Total
chlorides)
for
200OC1
should
read
1807
ug/
dscm
at
the
detection
limit
and
904
ug/
dscm
at
1/
2
the
detection
limit.
The
data
for
TCI
(Total
chlorides)
for
200OC2
should
read
1088
ug/
dscm
at
the
detection
limit
and
544
ug/
dscm
at
V2
the
detection
limit.
The
data
for
TCI
(Total
chlorides)
for
200OC3
should
read
650
ug/
dscm
at
the
detection
limit
and
325
ug/
dscm
at
1/
2the
detection
limit.
The
data
for
TCI
(Total
chlorides)
for
200OC4
should
read
1
1
7243
ug/
dscm
at
the
detection
limit
and
58622
ug/
dscm
at
V2
the
detection
limit.

Response:
All
values
reported
in
the
summary
sheets
are
intended
to
be
reported
at
½
the
detection
limit
as
appropriate
for
measurements
at
the
detection
limit.
Values
in
the
feedrate
sheet
are
reported
at
full
detection
limit
when
initially
entered.
Subsequent
calculations
will
consider
at
½
detection
limits,
as
clearly
discussed
in
the
data
base
report.

78.
Under
the
Stack
Gas
Conditions
Summary
Sheet,
the
data
presented
in
this
table
is
inconsistent.
The
flowrates
are
not
properly
represented,
because
the
flowrates
were
different
for
the
different
sampling
trains
that
were
run
during
the
trial
bum.
Also,
for
200OC2,
the
data
that
is
reported
is
all
from
Train
2.
GGCV
is
providing
all
of
the
data
for
the
Stack
Gas
Conditions
for
the
various
trains
that
were
run
during
the
trial
bum.
Not
all
of
the
trains
were
run
concurrently.
Some
trains
were
run
in
series
during
the
test
conditions.
For
2000C
I,
Train
1
(PM,
HCI/
CI2),
the
Flowrate
(dscfin),
02
(%),
Moisture
(%),
and
Temp
(F)
should
read
39186.3,
13.5,
16.
1,
and
479.4
respectively.

For
2000C
I,
Train
2
(DRE),
the
Flowrate
(dscfm)
'
02
(%),
Moisture
(%),
and
Temp
(F)
should
read
41119.8,
13.025,
14.56,
and
477.79,
respectively.

For
200OC2,
Train
1
(PM),
the
Flowrate
(dscfin),
02
(%),
Moisture
(%),
and
Temp
should
read
27,396
(See
Comment
50),
12.13,
18.3,
and
440.73,
respectively.

For
200OC2,
Train
2
(DRE)
and
Train
3
(PCDD/
PCDF),
the
Flowrate
(dscfm),
02
Moisture
(%),
and
Temp
W)
should
read
26523.9,
11.0,
19.3,
and
436.13,
respectively.

For
200OC3,
Train
1
(DRE),
the
Flowrate
(dscfm),
02
(%),
Moisture
(%),
and
Temp
(F)
should
read
21876.2,
10.9,
21.3,
and
420.03,
respectively.

For
200OC4,
Train
1
(PM,
HCI/
CI2),
the
Flowrate
(dscfrn),
02
(%),
Moisture
(%),
and
Temp
(F)
should
read
3
415
3.7,
10.3
3,
16.
1,
and
491.43,
respectively.

For
200OC4,
Train
2
(Cr+
6),
the
Flowrate
(dscftn),
02
(%),
Moisture
(%),
and
Temp
(F)
should
read
33134.3,
10.33,
11.8,
and
512.63,
respectively.

Response:
Stack
gas
condition
values
in
the
summary
sheet
are
only
presented
and
intended
as
a
general
representation
of
the
general
stack
gas
parameters
during
a
given
test
condition.
They
are
not
used
to
calculate
MACT
emission
levels.
Potentially
they
could
be
determined
a
variety
of
different
ways,
for
example
as
the
average
of
simultaneous
runs,
that
of
the
longest
duration
run,
that
from
the
highest
flowrate
condition,
etc.
Note,
in
general,
the
determination
procedure
is
of
little
significance
because
the
values
from
the
simultaneous
and
back
to
back
trains
is
for
all
purposes
the
same.

Georgia
Gulf
Chemicals
and
Vinyls,
LLC
appreciates
the
opportunity
to
comment
on
the
data
that
is
being
used
to
propose
the
NESHAP
standards
for
hazardous
waste
burning
boilers,
halogen
acid
furnaces,
and
sulfuric
acid
recovery
furnaces.
If
you
have
any
questions
concerning
the
comments
that
are
being
submitted
to
correct
data
and/
or
fill
in
data
gaps,
please
contact
Chad
Scott
at
225­
685­
2632.

Sincerely,

Patricia
A.
Haynes
Manager
of
Environmental
Services
Attachment
­
Appendix
Enclosure
­
Floppy
Disk
PAH/
CVS/
tam
File
601.3
cc:
Dr.
James
Brent,
Louisiana
Department
of
Environmental
Quality
Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.
Other
EPA
responses
are
provided
above
within
the
comments
shown
in
underlined
and
blue
type.

5.13
Lyondell
(Phase
II
ID
#
1002,
1003,
1004)

Lyondell
(14)

Lyondell
Chemical
Company,
Channelview,
Texas
(formerly
ARCO
Chemical
Company)
Phase
11
ID
No.
1002,1003
and
1004
EPA
I.
D.
No.
TXDO83472266
Lyondell
Chemical
Company,
Channelview
Texas
is
submitting
the
following
comments
and
corrections
to
the
database
information
to
be
used
to
establish
standards
in
the
Phase
11
combustion
rulemaking
of
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(NESHAPS)
for
hazardous
waste
burning
boilers
and
furnaces.
The
units
at
the
Channelview
site
that
are
applicable
are
Boilers
1,2,3
(Phase
11
number
1002),
F­
57180
Hot
Oil
Heater
(phase
11
number
1003)
and
F­
65630
@Hot
Oil
heater
(phase
11
number
1004).
Information
from
the
1998
and
1999
BIF
recertification
reports
were
used
to
revise
the
proposed
NESHAP
database.
Please
note
of
the
following
changes:

The
name
of
the
company
is
changed
from
ARCO
Chemical
Company
to
Lyondell
Chemical
Company.

All
information
in
the
database
was
revised
with
the
latest
information
from
the
most
up
to
date
Certification
of
Compliance
Reports
that
were
performed
in
1998
(for
phase
11
number
1002,
1004)
and
in
1999
(for
phase
11
number
1003).

The
values
from
the
"Feedrate
MTEC
Calculations"
contained
in
the
database
for
each
of
the
ten
BIF
metals,
ash,
chlorine,
SVM
and
LVM
have
not
been
corrected
for
the
revised
information
and
will
need
to
be
recalculated.

Enclosed
are
an
original
and
two
copies
of
the
comment
response
which
include
a
copy
of
the
Certificate
of
Compliance
forms
and
pages
containing
the
additional
information
from
the
1998
and
1999
BIF
recertification
reports.
Also,
a
diskette
containing
the
revised
NODA
electronic
file
using
Microsoft
Excel
97@
has
been
enclosed.
If
you
have
any
questions
pertaining
to
these
units
or
the
revised
data
you
may
contact
Paul
T.
Dang
at
(281)
860­
1289.

Response
Information
from
the
newly
supplied
CoCs
has
been
added
as
additional
test
conditions
for
each
of
the
units
(ID
No.
s
1002,
1003,
and
1004).
The
old
CoC
test
conditions
are
kept
and
will
be
considered
as
such
(i.
e.,
old,
not
most
recent,
test
data).

5.14
Reilly
Industries
(Phase
II
#
735,
737,
738)

Reilly
Industries
(15)

On
June
27,
2000
the
United
States
Environmental
Protection
Agency
(US
EPA)
published
in
the
Federal
Register
a
Notice
of
Data
Availability
(NODA)
for
Future
Phase
11
Combustion
Rulemaking.
This
NODA
presented
for
public
comment
the
data
base
that
the
US
EPA
plans
to
utilize
during
the
Phase
11
combustion
rulemaking
process.

Reilly
Industries,
Inc.
(Reilly)
[EPA
ID
Number
IND
000
807
107]
has
completed
a
review
of
the
data
base
compiled
by
the
US
EPA
for
Boiler
70K
(source
735),
Boiler
30K
(source
737),
and
Boiler
28K
(source
738)
located
at
its
Indianapolis,
Indiana
facility
and
is
providing
comments
related
to
such.
Compliance
Strategies
&
Solutions,
Inc.
(CS2
Inc.)
is
hereby
submitting
the
original
plus
two
copies
of
these
comments
along
with
supporting
documentation
for
each
comment
on
behalf
of
Reilly.

The
time
and
effort
undertaken
by
the
EPA
to
build
and
populate
the
data
base
has
been
a
significant
task.
As
discussed
in
the
June
2000
Phase
11
HWC
MACT
Data
Base
Report
(The
Report),
"The
resulting
data
base
will
serve
as
the
primary
technical
basis
to
evaluate
and
ultimately
establish
the
MACT
standards
for
hazardous
waste
burning
boilers,
HAFs,
and
SARFS."
For
this
reason,
and
coupled
with
Reilly's
waste
burning
operations
for
energy
recovery,
Reilly
is
thankful
to
have
the
opportunity
to
comment
on
the
accuracy
and
completeness
of
the
data
base.
As
expressly
stated
by
the
EPA
in
their
Federal
Register
notice,
"We
request
comment
only
on
the
accuracy
and
completeness
of
the
data
base
at
this
time.
We
do
not
seek
nor
will
we
use
or
respond
to
comments
on
how
to
use
the
data
base
to
establish
MACT
standards."
Therefore,
Reilly
is
providing
three
suggestions
for
improving
upon
the
completeness
and
utility
of
the
data
base.
Also
included
are
specific
comments
and
additional
infomation
regarding
Reilly's
sources
to
improve
the
accuracy
of
the
data
base.
And
at
closing,
Reilly
presents
three
objections
to
the
EPA's
inclusion
of
data
which
the
EPA
has
calculated
for
purposes
of
developing
a
MACT
standard.
These
objections
result
from
the
EPA's
statement
that
they
are
not
taking
or
responding
to
comments
on
how
to
use
(or
manipulate)
the
data
to
develop
a
MACT
standard.
As
such,
the
EPA
should
not
present
their
assessment
of
data
at
this
time,
such
data
manipulation
is
not
appropriate
considering
the
EPA's
reluctance
to
address
comments
on
"how
to
use
the
data
base".

Of
the
115
sources
included
in
the
data
base,
The
Report
notes
that
20
are
HAFs
and
SARFS,
each
with
specialized
process
equipment
for
recovering
acid.
It
also
notes
that
9
boilers
are
coal
fired,
all
of
which
are
equipped
with
APCSs
(presumably
to
control
emissions
associated
with
burning
coal).
Of
the
remaining
86
sources,
only
14
employ
an
APCS.
The
report
indicates
that
those
with
controls
are
special
cases,
stating
that
the
APCSs
are
"due
to
the
burning
of
high
chlorine
containing
waste"
and
"is
known
to
bum
'off­
site'
waste".
These
distinctions
are
of
a
significance
that
must
not
be
overlooked.
Noting
the
type
of
boiler
is
important,
but
even
more
so,
the
EPA
should
expand
the
data
base
to
characterize
the
waste
being
burned
in
the
unit.
Specifically,
Reilly's
first
suggestion
is
that
the
EPA
include
the
following
information
to
more
fully
characterize
the
BIFs
that
are
being
assessed:

Average
ash
content
for
the
waste
feed
(liquid,
sludge,
etc.)
and
the
primary
fuel
source
(natural
gas,
coal,
etc.);
The
average
concentration
for
each
of
the
10
BIF
metals
in
the
waste
feed
and
the
primary
fuel
source;

The
average
chlorine
content
in
the
waste
feed
and
the
primary
fuel
source;
and,

The
average
sulfur
content
in
the
waste
feed
and
the
primary
fuel
source.

It
appears
that
some
of
this
information
may
already
be
imbedded
in
the
data
base
(perhaps
based
on
feedrate
'information
from
the
test
reports),
however,
Reilly
could
not
extract
any
of
this
data
in
a
useful
manner.
This
information
is
required
to
completely
understand
the
nature
of
the
controls
currently
in
place
and
being
assessed
in
this
MACT
standard.
Failure
to
include
and
consider
this
information
in
the
MACT
standard
evaluation
will
compromise
the
integrity
of
the
EPA's
efforts.

Response:
All
of
these
suggested
data
are
clearly
included
in
the
data
base
in
the
feedrate
description
sheet.

Reilly
also
suggests
that
the
EPA
expand
the
Source
Description
(Stack
Characteristics)
portion
of
the
data
base
to
be
inclusive
of
the
modeling
information
that
was
utilized
by
the
facility.
Failing
to
include
this
information,
which
is
readily
available
from
the
reports
used
thus
far
in
assembling
the
data
base,
will
not
allow
a
complete,
thorough,
and
consistent
review
between
the
facilities.
Specifically,
Reilly
requests
that
the
EPA
expand
this
section
to
include
the
shortest
distance
from
the
stack
to
the
property
line,
the
distance
of
the
stack
to
their
MEI
(maximum
exposed
individual
or
the
nearest
maximum
exposed
receptor),
the
terrain
type
for
the
facility
(simple,
inten­
nediate,
or
complex),
the
land
use
of
the
facility
(rural
or
urban),
type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.),
and
the
dilution
factor
determined
for
the
stack.
This
information
will
be
vital
in
the
comparison
of
limits
established
for
short
stacks
positioned
near
property
lines
(actually
their
MEI)
versus
the
limits
established
for
taller
stacks
that
are
quite
some
distance
from
an
MEI.
Failing
to
consider
this
infon­
nation
will
also
significantly
compromise
the
integrity
of
any
effort
used
to
establish
a
MACT
standard.

Response:
As
discussed
elsewhere
(Section
3.2),
these
data
may
be
compiled
and
included
in
the
data
base
at
a
later
date
when
risk
assessment
is
performed.

As
a
final
suggestion
for
improvement
and
completeness,
Reilly
asks
that
the
EPA
modify
the
Source
Description
(Permitting
Status)
section
of
the
data
base
to
be
more
precise
and
thorough
in
its
inclusion
of
data.
Specifically,
Reilly
recommends
that
the
data
base
be
expanded
to
include
the
specific
status
and
limits
under
which
each
BIF
is
operating.
This
information
is
significant,
and
should
not
be
overlooked
when
evaluating
MACT
standards.
In
so
making
these
changes,
the
utility
of
the
data
base
will
be
greatly
enhanced.
Therefore,
the
data
base
should
be
expanded
to
include
(at
a
minimum)
the
DRE
standard
(40
CFR
266.104),
particulate
matter
(§
266.105),
the
10
BIF
metals
(§
266.107),
and
HCI/
CI2
(§
266.107).
These
changes
can
be
readily
implemented
since
it
is
appears
that
the
EPA
already
made
a
simple
attempt
to
provide
limited
amounts
of
this
information.
In
an
effort
to
facilitate
matters,
Reilly
suggests
the
following
categories:

The
DRE
standard
may
be
limited
to
the
following
categories:
(a)
DRE
standard,
(a4)
DRE
waiver,
(a5)
low
risk
waiver,
(b)
CO
Standard,
(c)
Alt
CO
Standard,
and
(d)
other;

For
metals,
the
following
categories
should
be
established:
Tier
1,
Tier
11,
Tier
111,
Adjusted
Tier
1,
and
Adjusted
Tier
I
with
testing
as
allowed
by
§266.106(
g);
and,

The
HCI/
CI2
standard
would
have
these
categories:
Tier
1,
Tier
11,
Tier
III,
and
Adjusted
Tier
1.

This
information
is
readily
available
in
full
detail
in
RCOC
reports
and
draft/
final
permits
that
may
exist
for
the
BIFS.

Response:
This
is
discussed
in
some
detail
in
Section
3.2.
Note
that,
in
fact,
the
BIF
allowable
Tier
I
feedrate
limits
for
metals
and
chlorine
are
clearly
included
in
the
data
base
in
the
feedrate
sheet.
There
is
no
reason
to
compile
PM,
CO,
or
DRE
limits,
as
these
are
all
generally
the
same,
federal,
standard
under
the
current
RCRA
BIF
rule.

Reilly
encourages
the
EPA
to
expand
the
data
base
as
presented
above
in
Reilly's
three
suggestions.
This
expansion
will
consist
of
information
on
the
waste
and
fuel
being
fed
to
the
boilers,
the
dispersion
and
risk
characteristics
associated
with
each
source,
and
the
performance
standards,
feed
rates,
and
the
basis
for
establishing
limits
upon
them.
Assembling
the
data
in
this
fashion
will
facilitate
a
much
more
efficient
and
thorough
assessment
and
development
of
a
viable
MACT
standard.

Reilly
has
also
reviewed
the
data
and
information
specific
to
its
three
sources
(735,
737,
and
738)
and
a
few
specific
concerns
have
arisen.
First,
there
are
extensive
and
excessive
amounts
of
errors
for
the
data
input
for
these
three
sources.
Attached
are
comments
specifically
addressing
each
error
that
has
been
identified.
A
second
error
noted
in
our
review
is
that
test
condition
averages
were
used
instead
of
the
data
from
each
of
the
three
individual
runs.
The
EPA
should
not
average
information
at
this
point
in
the
data
base
preparation.
Instead,
the
raw
data
should
be
published
in
place
of
averages
of
data
that
may
actually
already
be
based
on
averages.
In
similar
regard,
the
EPA
used
data
from
one
test
condition
to
fill
in
gaps
from
another
test
condition
that
may
not
have
included
testing
for
that
parameter.
This
too
appears
premature
and
it
does
not
present
an
accurate
depiction
of
the
data.
As
stated
in
the
opening,
Reilly
is
submitting
the
original
plus
two
copies
of
these
comments
along
with
supporting
documentation
for
each
comment.
Response:
All
of
these
issues
are
discussed
and
responded
to
in
detail
in
the
above
Sections
3
and
4.
We
do
not
agree
with
any
of
these
comments,
as
discussed
above.

Recognizing
the
significance
of
the
effort
that
the
EPA
has
undertaken,
Reilly
realizes
that
errors
may
be
widespread
throughout
all
of
the
sources
and
not
simply
limited
just
to
Reilly's
three
boilers.
Considering
the
nature
of
these
errors
and
the
omissions
identified
in
Reilly's
three
suggestions
for
improvement,
Reilly
hereby
requests
that
a
second
NODA
be
published
for
comment
prior
to
finalizing
the
data
base.
A
second
review
of
the
revised
data
is
imperative
considering
the
magnitude
and
pervasiveness
of
the
needed
revisions.

Reilly
has
two
objections
to
the
presentation
of
the
MTEC
Feedrate
Calculations
and
a
third
objection
to
the
presentation
of
estimated
firing
rates.
The
first
objection
is
for
basing
MTEC
calculations
on
feed
rate
data
obtained
during
testing.
The
purpose
behind
most
all
of
the
testing
was
not
to
demonstrate
feedrates
at
the
allowable
risk
based
levels
(Tier
1,
Adjusted
Tier
1,
etc.).
Instead,
the
feedrate
data
presented
was
used
to
show
that
the
operations
were
taking
place
at
levels
well
enough
below
the
allowable
risk
based
limits.
Reilly
requests
that
if
the
MTEC
Feedrate
Calculations
are
to
be
presented
as
part
of
the
data
base,
then
they
should
be
based
on
the
operating
limits
discussed
as
Reilly's
third
suggestion
for
improvement.
Reilly's
second
objection
is
based
on
the
fundamental
intent
of
the
data
base
to
present
the
data.
Reilly
understands
that
the
data
base
is
not
intended
to
manipulate
or
analyze
data,
and
that
in
fact,
the
EPA
is
not
accepting
any
comments
towards
such
an
exercise.
Therefore,
Reilly
concludes
that
the
EPA's
decision
to
choose
feedrate
data
for
MTEC
calculations
and
to
present
said
information
is
unfair
and
unjustified.
MTEC
calculations
should
be
dropped
from
the
data
base
at
this
time
in
their
entirety
and
a
separate
NODA
comment
period
should
be
established
to
allow
comment
on
data
manipulation
and
interpretation.
If
the
EPA
disagrees
with
this
second
objection,
then
at
a
minimum,
the
MTEC
should
be
expanded
to
include
calculations
based
on
the
allowable
feed
rates
discussed
in
our
first
objection.
Lastly,
Reilly
objects
to
the
use
of
an
Ffactor
determined
estimated
firing
rate.
Reilly
believes
that
the
firing
rates
should
be
based
only
on
data
generated
during
actual
testing
or
as
established
in
permit
or
RCOC
limits,
since
this
data
is
readily
available.
As
already
expressed,
Reilly
objects
to
any
manipulation
of
data
at
this
point
in
the
NODA
process.
Since
the
EPA
has
specifically
declined
to
consider
comment
on
data
assessment,
it
is
unfair
for
the
EPA
to
present
such
a
manipulation
of
the
data
at
this
time.

Again,
Reilly
appreciates
the
opportunity
to
comment
on
the
infon­
nation
included
in
the
data
base.
Reilly
is
also
anticipating
the
opportunity
to
review
the
data
a
second
time
after
the
EPA
implements
these
suggestions,
comments,
and
objections.
If
you
have
any
questions
or
need
additional
information,
please
contact
John
Jones
of
Reilly
Industries,
Inc.
at
(317)
248­
6427
or
email
jjones@
reillyind.
com.

Respectfully
Submitted,

CS2
Inc.

Enclosures
Boiler
70K
Comments
Support
pages
from
Trial
Bum
Report
for
Boiler
70K
(multiple
pages
from
report)
Page
14
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
I
Page
6
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
2
Page
4
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
3
Table
4.2­
1
from
Trial
Bum
Plan
for
Boiler
70K
Mini­
Bum
Test
Report
for
Boiler
70K
(in
its
entirety)
Page
4
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Minibum
Test
Report
Quality
Assurance
Oversight
Reports
for
Mini­
Bum
Test
­
Independent
and
Stack
Sampling
(in
their
entirety)
Trial
Bum
Retest
Report
for
Boiler
70K
(in
its
entirety)
Page
4
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Trial
Bum
Retest
Report
Quality
Assurance
Oversight
Reports
for
Trial
Bum
Retest
­
Independent
and
Stack
Sampling
(in
their
entirety)

Boiler
30K
Comments
Support
pages
from
Trial
Bum
Report
for
Boiler
3
OK
(multiple
pages
from
report)
Page
14
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Condition
I
Page
6
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Condition
2
Table
4.2­
1
from
Trial
Bum
Plan
for
Boiler
30K
Trial
Bum
Retest
Report
for
Boiler
30K
(in
its
entirety)
Page
4
of
Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Trial
Bum
Retest
Report
Quality
Assurance
Oversight
Reports
for
Trial
Bum
Retest
­
Independent
and
Stack
Sampling
(in
their
entirety)

Boiler
28K
Comments
Demonstration
of
Similarity
Report
for
Boiler
28K
(in
its
entirety)

Additional
Support
Documentation
Revised
Certification
of
Compliance
Test
Report
for
Boilers
70K,
30K,
and
28K
(in
its
entirety)
Temperature
and
velocity
summary
for
Boilers
70K
and
30K
Reilly
Industries,
Inc.
Boiler
MACT
NODA
Review
Boiler
28K
Phase
11
ID
No.
738
Comment
1
Source
Description,
Other
Sister
Facilities
­
Please
replace
'None'
with
Boiler
30K.
Comment
2
Source
Description,
Sootblowing
­
As
discussed
on
page
4
of
the
Phase
11
HWC
MACT
Data
Base
Report
dated
June
2000,
the
description
of
soot
blowing
as
provided
by
the
EPA
is
to
"identify
whether
soot
blowing
is
used,
as
well
as
the
duration
and
frequency".
Therefore,
Reilly
suggests
that
the
EPA
modify
the
Source
Description
section
of
the
database
to
include
the
following
fields
and
that
the
information
so
provided
be
incorporated
for
#738:

Soot
Blowing
Yes
Frequency
Four
times/
day
Duration
Five­
minutes/
soot
blow
event
Comment
3
Source
Description,
Stack
Characteristics
­
Reilly
suggests
that
the
EPA
expand
this
portion
of
the
database
to
be
inclusive
of
the
modeling
information
that
was
utilized
by
the
facility.
Failing
to
include
this
information,
which
is
readily
available
from
the
reports
used
thus
far
in
assembling
the
database,
will
not
allow
a
complete,
thorough,
and
consistent
review
between
the
facilities.
Specifically,
Reilly
requests
that
the
EPA
expand
this
section
to
include
the
shortest
distance
from
the
stack
to
the
property
line,
the
distance
of
the
stack
to
their
MEI
(maximum
exposed
individual
or
the
nearest
maximum
exposed
receptor),
the
terrain
type
for
the
facility
(simple,
intermediate,
or
complex),
the
land
use
of
the
facility
(rural
or
urban),
type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.),
and
the
dilution
factor
determined
for
the
stack.
This
information
will
be
vital
in
the
comparison
of
limits
established
for
short
stacks
positioned
near
property
lines
(actually
their
MEI)
versus
the
limits
established
for
taller
stacks
that
are
quite
some
distance
from
an
MEI.
Failing
to
consider
this
information
will
significantly
compromise
the
integrity
of
any
effort
used
to
establish
a
MACT
standard.
Testing
of
Boiler
28K
was
not
conducted
pursuant
to
the
Demonstration
of
Similarity
Report
dated
February
3,
2000
(a
copy
of
this
report
is
included
for
Agency
review).
The
results
below
for
Boiler
28K
were
obtained
in
part
by
reducing
the
results
from
the
testing
of
Boiler
3OK:

Shortest
distance
from
the
stack
to
the
property
line
64
m
Distance
of
the
stack
to
the
MEI
N/
A
Terrain
type
for
the
facility
(simple,
intermediate,
or
complex)
N/
A
Land
use
of
the
facility
(rural
or
urban)
N/
A
Type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.)
N/
A
llg/
M3/
g/
S
Dilution
factor
determined
for
the
stack
3.050073
N/
A
­
Similarity
was
demonstrated.
Therefore,
modeling
was
not
conducted
for
Boiler
28K.

Comment
4
Source
Description,
Permitting
Status
­
As
discussed
on
pages
2
and
5
of
the
Phase
11
HWC
MACT
Data
Base
Report
dated
June
2000,
the
permitting
status
of
the
BIFs
is
comprised
of
a
number
of
items.
Reilly
suggests
that
the
EPA
modify
this
section
of
the
database
to
be
more
precise
and
complete
in
its
inclusion
of
data.
Specifically,
Reilly
recommends
that
the
database
be
expanded
under
the
section
permitting
status
to
include
the
specific
status
and
limits
under
which
each
BIF
is
operating.
This
information
is
significant,
and
should
not
be
overlooked
when
evaluating
MACT
standards.
In
so
making
these
changes,
the
utility
of
the
database
will
be
greatly
enhanced.
Therefore,
the
database
at
a
minimum
should
be
expanded
to
include
the
DRE
standard
(40
CFR
266.104),
particulate
matter
(§
266@
105),
the
10
BIF
metals
(§
266.107),
and
HCI/
CI2
(§
266.107).
These
changes
can
be
readily
implemented
as
it
appears
that
the
EPA
already
made
a
simple
attempt
at
such.

The
DRE
standard
may
be
limited
to
the
following
choices:
(a)
DRE
standard,
(a4)
DRE
waiver,
(a5)
low
risk
waiver,
(b)
CO
Standard,
(c)
Alt
CO
Standard,
and
(d)
other.
For
metals,
the
following
categories
should
be
established:
Tier
1,
Tier
II,
Tier
III,
Adjusted
Tier
1,
and
Adjusted
Tier
I
with
testing
as
allowed
by
§266.106(
g).
The
HCI/
CI2
standard
would
have
these
categories:
Tier
1,
Tier
11,
Tier
111,
and
Adjusted
Tier
1.
Pursuant
to
the
Demonstration
of
Similarity
Report
dated
February
3,
2000,
the
results
below
for
Boiler
28K
were
obtained
by
reducing
the
results
from
the
testing
of
Boiler
30K
by
three
percent:

Section
Parameter
Standard
Limit
266.
x102/
103
Max.
Waste
Feed
Rate
2204
lb/
hr
104
Organic
emissions
Carbon
monoxide
100
ppmv
105
Particulate
matter
Ash
Feed
Rate
2954
g/
hr
106
Antimony
Adjusted
Tier
1
334
g/
hr
106
Arsenic
Adjusted
Tier
1
2.56
g/
hr
106
Barium
Adjusted
Tier
1
55,577
g/
hr
106
Beryllium
Adiusted
Tier
1
4.67
g/
hr
106
Cadmium
A
Tier
I
6.23
g/
hr
106
Chromium
Adjusted
Tier
I
w/
testing
3.76
g/
hr
106
Lead
A
Tier
I
100
g/
hr
106
Mercury
A
Tier
1
334
g/
hr
106
Silver
Adjusted
Tier
I
3335
g/
hr
106
Thallium
Adiusted
Tier
1
556
g/
hr
107
Chlorine/
Chlorides
Adjusted
Tier
I
4850
g/
hr
Reilly
encourages
the
EPA
to
expand
the
database
as
presented
above
to
include
the
performance
standards,
their
feed
rates,
and
the
basis
for
establishing
them.
Assembling
the
data
in
this
fashion
will
facilitate
a
much
more
efficient
and
thorough
assessment
and
development
of
a
viable
MACT
standard.

Comment
5
Please
remove
all
references
to
the
1996
Revised
Certification
of
Compliance
from
the
database
based
on
EPAs
request
to
use
the
data
from
the
most
recent
compliance
tests.
A
Demonstration
of
Similarity
between
Boiler
30K
and
Boiler
28K
was
approved
by
EPA
Region
5
before
the
performance
of
the
Trial
Bum.
Testing
of
Boiler
28K
was
not
conducted
during
the
Trial
Bum.
It
was
decided
that
the
limits
for
Boiler
28K
would
be
3%
lower
that
those
for
Boiler
30K.
Therefore,
Reilly
is
currently
operating
under
the
limits
established
pursuant
to
the
Demonstration
of
Similarity.
A
copy
of
this
report
is
provided
for
Agency
review.
Comment
6
Please
adjust
the
Summary
at
the
end
of
the
database
to
include
all
of
the
above
comments.

Reilly
Industries,
Inc.
Boiler
MACT
NODA
Review
Boiler
70K
Phase
11
ID
No.
735
Comment
I
Source
Description,
Capacity
­
92
should
read
91.8
(from
Combustor
Characteristics).
Please
adjust
on
Source
Description
Summary
Sheet
as
well.

Comment
2
Source
Description,
Sootblowing
­
As
discussed
on
page
4
of
the
Phase
11
HWC
MACT
Data
Base
Report
dated
June
2000,
the
description
of
soot
blowing
as
provided
by
the
EPA
is
to
"identify
whether
soot
blowing
is
used,
as
well
as
the
duration
and
frequency".
Therefore,
Reilly
suggests
that
the
EPA
modify
the
Source
Description
section
of
the
database
to
include
the
following
fields
and
that
the
information
so
provided
be
incorporated
for
#735:

Soot
Blowing
Yes
Frequency
Four
times/
day
Duration
five­
minutes/
soot
blow
event
Comment
3
Source
Description,
Stack
Characteristics
­
The
most
recent
gas
temperature
and
velocity
from
the
combined
1999
Trial
Bum/
RCOC
is
615'F
and
44.65
ft/
sec,
respectively.
A
copy
of
this
information
has
been
included
for
Agency
review.
Reilly
also
suggests
that
the
EPA
expand
this
portion
of
the
database
to
be
inclusive
of
the
modeling
information
that
was
utilized
by
the
facility.
Failing
to
include
this
information,
which
is
readily
available
from
the
reports
used
thus
far
in
assembling
the
database,
will
not
allow
a
complete,
thorough,
and
consistent
review
between
the
facilities.
Specifically,
Reilly
requests
that
the
EPA
expand
this
section
to
include
the
shortest
distance
from
the
stack
to
the
property
line,
the
distance
of
the
stack
to
their
MEI
(maximum
exposed
individual
or
the
nearest
maximum
exposed
receptor),
the
terrain
type
for
the
facility
(simple,
intermediate,
or
complex),
the
land
use
of
the
facility
(rural
or
urban),
type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.),
and
the
dilution
factor
determined
for
the
stack.
This
infon­
nation
will
be
vital
in
the
comparison
of
limits
established
for
short
stacks
positioned
near
property
lines
(actually
their
MEI)
versus
the
limits
established
for
taller
stacks
that
are
quite
some
distance
from
an
MEI.
Failing
to
consider
this
information
will
significantly
compromise
the
integrity
of
any
effort
used
to
establish
a
MACT
standard.
This
additional
information
is
prove
'ded
below
as
taken
from
our
January
24,
2000
RCOC
Report:

Shortest
distance
from
the
stack
to
the
property
line
82
meters
Distance
of
the
stack
to
the
MEI
350
meters
Terrain
type
for
the
facility
(simple,
intermediate,
or
complex)
intermediate
Land
use
of
the
facility
(rural
or
urban)
urban
Type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.)
ISCLT3
Dilution
factor
determined
for
the
stack
0.666575
jig/
ml/
g/
s
Reilly
also
feels
that
the
average
stack
gas
flow
rate
from
each
sample
train
should
be
included
here.
This
value
is
13,520
dscfm
and
was
averaged
from
each
sample
train
run
during
Test
Condition
I
of
the
1999
Trial
Bum.
Reilly
will
further
discuss
the
stack
gas
flow
rate
relative
to
the
MTEC
feedrate
calculations
in
comment
26.

Comment
4
Source
Description,
Permitting
Status
­
As
discussed
on
pages
2
and
5
of
the
Phase
11
HWC
MACT
Data
Base
Report
dated
June
2000,
the
pennitting
status
of
the
BIFs
is
comprised
of
a
number
of
items.
Reilly
suggests
that
the
EPA
modify
this
section
of
the
database
to
be
more
precise
and
complete
in
its
inclusion
of
data.
Specifically,
Reilly
recommends
that
the
database
be
expanded
under
the
section
pennitting
status
to
include
the
specific
status
and
limits
under
which
each
BIF
is
operating.
This
information
is
significant,
and
should
not
be
overlooked
when
evaluating
NMCT
standards.
In
so
making
these
changes,
the
utility
of
the
database
will
be
greatly
enhanced.
Therefore,
the
database
at
a
minimum
should
be
expanded
to
include
the
DRE
standard
(40
CFR
266.104),
particulate
matter
(§
266.105),
the
10
BIF
metals
(§
266.107),
and
HCI/
CI2
(§
266.107).
These
changes
can
be
readily
implemented
as
it
is
appears
that
the
EPA
already
made
a
simple
attempt
at
such
(see
comment
30).

The
DRE
standard
may
be
limited
to
the
following
choices:
(a)
DRE
standard,
(a4)
DRE
waiver,
(a5)
low
risk
waiver,
(b)
CO
Standard,
(c)
Alt
CO
Standard,
and
(d)
other.
For
metals,
the
following
categories
should
be
established:
Tier
1,
Tier
II,
Tier
111,
Adjusted
Tier
1,
and
Adjusted
Tier
I
with
testing
as
allowed
by
§266.106(
g).
The
HCI/
CI2
standard
would
have
these
categories:
Tier
1,
Tier
11,
Tier
III,
and
Adjusted
Tier
1.
Reilly
is
providing
the
following
table
of
this
information
as
it
pertains
to
#735,
as
taken
from
our
January
24,
2000
RCOC
Report:

Section
Parameter
Standard
Limit
Units
266.
x
102/
103
Max.
Waste
Feed
Rate
Operating
condition
3719
lb/
hr
104
Organic
emissions
Carbon
monoxide
100
ppmv
105
Particulate
matter
Ash
Feed
Rate
5001
g/
hr
106
Antimony
Adjusted
Tier
1
1620
g/
hr
106
Arsenic
Adjusted
Tier
1
12.42
g/
hr
106
Barium
Adjusted
Tier
1
270,037
g/
hr
106
Beryllium
Adjusted
Tier
I
22.68
g/
hr
106
Cadmium
Adjusted
Tier
I
30.24
g/
hr
106
Chromium
Adjusted
Tier
I
w/
testing
18.29*
g/
hr
106
Lead
Adjusted
Tier
1
486
g/
hr
106
Mercury
Adjusted
Tier
I
1620
g/
hr
106
Silver
Adjusted
Tier
1
16,202
g/
hr
106
Thallium
Adjusted
Tier
1
2700
g/
hr
107
Chlorine/
Chlorides
Adjusted
Tier
I
40,000**
g/
hr
*A
Mini­
Bum
Test
was
performed
on
Boiler
70K
to
identify
the
hexavalent
chromium
conversion
ratio.
This
demonstrated
conversion
ratio
of
24.5%
is
currently
being
used
by
Reilly
to
set
the
chromium
feed
rate
limits
for
each
of
the
boilers.
Dividing
the
original
Adjusted
Tier
I
feed
rate
screening
limit
of
4.48
g/
hr
by
the
conversion
ratio
of
24.5%
gives
a
speciated
chromium
feed
rate
of
18.29
g/
hr.

**
Using
emissions
testing
data,
Reilly
demonstrated
that
the
emissions
of
chlorine
were
less
than
one
percent
of
that
which
is
fed.
This
resulted
in
an
Adjusted
Tier
I
feed
rate
screening
limit
of
216,000
g/
hr
(Section
15.11
of
Trial
Bum
Report
for
Boiler
70K).
Reilly
and
the
Agency
agreed
upon
a
total
chlorine/
chloride
feed
rate
limit
of
40,000
gihr
rather
than
216,600
g/
hr
since
this
amount
of
feed
rate
was
not
needed.
Please
ad
ust
Total
Cl
to
reflect
this
change.

Reilly
encourages
the
EPA
to
expand
the
database
as
presented
above
to
include
the
performance
standards,
their
feed
rates,
and
the
basis
for
establishing
them.
Assembling
the
data
in
this
fashion
will
facilitate
a
much
more
efficient
and
thorough
assessment
and
development
of
a
viable
MACT
standard.

Comment
5
Please
remove
all
references
to
the
1996
Revised
Certification
of
Compliance
from
the
database
based
on
EPAs
request
to
use
the
data
from
the
most
recent
compliance
tests.
The
most
recent
compliance
test
report
is
dated
January
24,
2000
and
is
entitled
Revised
Certification
of
Compliance
Test
Report
for
Boilers
70K,
30K,
and
28K.
A
copy
of
this
report
has
been
included
for
Agency
review.

Comment
6
Source
Description,
Report
Name/
Date,
Numbers
I
and
2
­
Please
replace
the
Revised
Certification
of
Compliance
information
from
1996
with
the
following,
more
current,
Revised
Certification
of
Compliance
information.
Reilly
suggests
adding
'Cond'
in
front
of
Number
to
read
'Cond
Number'
in
order
to
avoid
confusion
and
keep
the
labeling
consistent
throughout
the
database.

Report
Name/
Date
Revised
Certification
of
Compliance
Test
Report
for
Boilers
70K,
30K,
and
28K
January
24,
2000
Report
Prepare
Compliance
Strategies
&
Solutions,
Inc.
Testing
Firm
Compliance
Strategies
&
Solutions,
Inc.,
METCO
Environmental,
Inc.,
and
B3
Systems,
Inc.

Cond
Number
I
Testing
Dates
October
21
­
23,
1999
Cond.
Description
CoC,
high
feed
rate
Content
PM,
CO,
HCI/
CI2
Cond
Number
2
Testing
Dates
October
19
­
20,
1999
Cond.
Description
CoC,
low
comb
temp
A
copy
of
this
report
is
included
for
Agency
review.

Comment
7
Report
Name/
Date
­
Please
remove
the
's'
from
Boilers
to
read
'Trial
Bum
Report
for
Boiler
70K,
February
3,
2000'.

Comment
8
Test
Condition
I
of
the
combined
Trial
Bum/
RCOC
was
performed
October
21
­
23,
1999.
Testing
was
not
performed
on
November
2,
1999
(Section
6.3.4
Trial
Bum
Report
for
Boiler
70K).
Please
update
on
the
PCDD/
PCDF
page
for
Condition
ID
735C3
as
well.

Comment
9
A
hexavatent
chromium
(Cr+
6
)
sampling
train
was
not
run
during
the
Trial
Bum.
This
sampling
train
was
run
during
the
Mini­
Bum
Test
of
Boiler
70K
performed
May
23,
2000.
Please
delete
the
reference
to
Cr+
6
testing
during
the
Trial
Bum
(see
comment
10).

Comment
10
Please
include
the
following
information
under
Source
Description,
Report
Name/
Date
and
Number:

Cond
Number
6
­
Mini­
Bum
Test
Testing
Dates
May
23,
2000
Cond
Description
High
Waste
Feed
Rate
Content
Cr
+6,
Co
A
copy
of
this
report
along
with
stack
gas
conditions
is
included
for
Agency
review.

Comment
11
Please
include
the
following
information
under
Source
Description,
Report
Name/
Date
and
Number:

Cond
Number
7
­
Trial
Bum
Retest
Testing
Dates
May
22,
2000
Cond
Description
Min
Comb
Chamb
Temp,
Min
Steam
Prod
Rate
Content
DRE
A
copy
of
this
report
along
with
stack
gas
conditions
is
included
for
Agency
review.

Comment
12
Stack
Gas
Emissions,
735C3
­
An
'nd'
should
be
added
to
the
C12
emission
rate
for
Run
3
(Table
14.3­
2
of
Trial
Bum
Report
for
Boiler
70K).

Comment
13
Stack
Gas
Emissions,
735C3
­
Our
records
indicate
that
the
stack
gas
flow
rates
for
the
PM
and
HCI/
CI2
train
are
13,834
dscfm,
14,036
dscfm,
and
14,035
dscfm
for
Runs
1,
2,
and
3,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
1,
Volume
1,
pg.
14).
Please
adjust
any
necessary
calculations
to
account
for
these
changes.

Comment
14
Stack
Gas
Emissions,
735C3
­
Our
records
indicate
that
the
Orsat
oxygen
contents
observed
during
the
PM
and
HCI/
CI2
sampling
train
are
3.6%,
3.0%,
and
3.0%
for
Runs
1,
2,
and
3,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
1,
Volume
1,
pg.
14).
The
numbers
input
into
the
database
are
the
values
recorded
by
the
CEMS
installed
in
the
stack
of
Boiler
70K.
Please
adjust
any
necessary
calculations
to
account
for
these
changes.

Comment
15
Stack
Gas
Emissions,
735C3
­
Our
records
indicate
that
the
stack
gas
temperatures
observed
during
the
PM
and
HCI/
CI2
sampling
train
are
622'F,
634'F,
and
632'F
for
Runs
1,
2,
and
3,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
1,
Volume
1,
pg.
14).

Comment
16
Please
add
the
most
recent
DRE
data
for
1,2­
Dichlorobenzene
gathered
during
the
Trial
Bum
Retest
conducted
May
22,
2000.
A
copy
of
the
Trial
Bum
Retest
Report
is
included
for
reference.

Comment
17
Stack
Gas
Emissions,
735C4
­
Our
records
indicate
that
the
Orsat
oxygen
contents
observed
during
the
DRE
test
condition
were
8.4%,
7.3%,
and
7.2%
for
Runs
1,
2,
and
3,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
2,
Volume
1,
pg.
6).
The
numbers
input
into
the
database
are
the
values
recorded
by
the
CEMS
installed
in
the
stack
of
Boiler
70K.
Please
adjust
any
necessary
calculations
to
account
for
these
changes.

Comment
18
Stack
Gas
Emissions,
735C5
­
Our
records
indicate
that
the
stack
gas
flow
rates
for
Test
Condition
3
are
6166
dscfm,
6321
dscfm,
and
6304
dscfm
for
Runs
1,
2,
and
3,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
3,
Volume
1,
pg.
4).

Comment
19
Our
records
indicate
that
the
Orsat
oxygen
contents
observed
during
Test
Condition
3
are
5.7%,
8.2%,
and
6.0%,
respectively
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
70K
Stack
Condition
3,
Volume
1,
pg.
4).
The
numbers
input
into
the
database
are
the
values
recorded
by
the
CEMS
installed
in
the
stack
of
Boiler
70K.

Comment
20
The
maximum
hourly
rolling
average
values
for
each
run
were
used
in
calculating
the
maximum
feed
rates
for
metals,
ash,
and
chlorine
for
both
the
Revised
Certification
of
Compliance
and
the
Trial
Bum.
The
minimum
hourly
rolling
average
values
for
each
run
were
used
in
establishing
the
minimum
limits
for
the
minimum
combustion
chamber
temperature
and
the
minimum
steam
production
rate.
The
average
of
these
maximum
and
minimum
values
was
used
to
establish
the
operating
limits
for
each
of
the
parameters.
The
numbers
input
into
the
database
seem
to
be
the
average
of
the
average
instead
of
the
average
of
the
maximum
or
minimum
values.
Please
adjust
these
values
to
reflect
the
average
of
the
maximum
and
minimum
values
as
appropriate.

Comment
21
Feedstreams,
735C3
­
The
maximum
waste
fuel
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
waste
fuel.
This
number
is
3719
lb/
hr
(Table
9.
1
­1
of
Trial
Bum
Report
for
Boiler
70K).
Using
this
number
in
the
calculation
provides
a
firing
rate
of
57.2
MMBtu/
hr.

The
maximum
city
gas
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
city
gas.
This
number
is
1055
lb/
hr
(Table
9.2­
1
of
Trial
Bum
Report
for
Boiler
70K).
Our
records
also
indicate
that
the
correct
heat
content
for
the
city
gas
is
21,214
Btu/
lb
(Table
4.2­
1
Trial
Bum
Plan
for
Boiler
70K).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
22.4
MMBtu/
hr.

Adding
the
firing
rates
of
the
waste
fuel
and
the
city
gas
provides
a
total
firing
rate
of
79.6
MMBtu/
hr.

Comment
22
Feedrates,
735C3
­
Our
records
indicate
that
the
maximum
ash
feed
rate
for
the
waste
fuel
is
nd
1687.01
g/
hr
(Table
11.2­
1
of
Trial
Bum
Report
for
Boiler
70K).

Comment
23
Feedrates,
735C3
­
Our
records
indicate
that
the
feedrate
for
mercury
under
the
waste
fuel
column
should
be
nd
0.07
g/
hr
(Table
11.4­
1
of
Trial
Bum
Report
for
Boiler
70K).

Comment
24
Feedrates,
735C3
­
Our
records
indicate
that
the
ash
spike
feedrate
is
3238.58
g/
hr
(Table
12.1­
1
of
Trial
Bum
Report
for
Boiler
70K).

Comment
25
Feedrates,
735C3
­
Our
records
indicate
that
the
ash
spike
feed
rates
for
antimony,
barium,
ando,
amercury
are
nd
0.002
g/
hr,
0.007
g/
hr,
and
nd
0.0003
g/
hr,
respectively
(Table
12.3­
1
of
TrialBum
Report
for
Boiler
70K).
0.
00
Comment
26
Reilly
is
noting
two
(2)
objections
to
the
presentation
of
the
MTEC
Feedrate
Calculations.
The
first
is
for
basing
MTEC
calculations
on
feed
rate
data
obtained
during
testing.
The
purpose
behind
most
all
of
the
testing
was
not
to
demonstrate
feed
rates
at
the
allowable
risk
based
levels
(Tier
1,
Adjusted
Tier
1,
etc.).
Instead,
the
feed
rate
data
presented
was
used
to
show
that
the
operations
were
taking
place
at
levels
well
enough
below
the
allowable
risk
based
limits.
Reilly
suggests
that
if
the
MTEC
Feedrate
Calculations
are
to
be
presented
as
part
of
the
database,
then
they
should
be
based
on
the
operating
limits
discussed
in
Comment
4.
Reilly's
second
objection
is
based
on
the
fundamental
intent
of
the
database
to
present
the
data.
Reilly
understands
that
the
database
is
not
intended
to
manipulate
or
analyze
data,
and
that
in
fact,
the
EPA
is
not
accepting
any
comments
towards
such
an
exercise.
Therefore,
Reilly
concludes
that
the
EPA's
decision
to
choose
feed
rate
data
for
MTEC
calculations
is
unfair
and
unjustified,
and
MTEC
calculations
should
be
dropped
from
the
database
at
this
time
in
their
entirety.
If
the
EPA
disagrees
with
this
second
objection,
then
at
a
minimum,
the
MTEC
should
be
expanded
to
include
calculations
based
on
the
allowable
feed
rates
presented
in
Comment
4
(our
first
objection).

Feedrates,
735C3
­
If
the
Agency
insists
on
calculating
the
MTEC,
please
use
the
correct
average
stack
gas
flow
rate
(13,968
dscfm)
and
the
correct
feedrates.

Comment
27
Feedrates,
735C4
­
The
minimum
waste
fuel
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
waste
fuel.
This
number
is
584.7
lb/
hr
(Table
9.1­
2
of
Trial
Bum
Report
for
Boiler
70K).
Using
this
number
in
the
calculation
provides
a
firing
rate
of
8.9
MMBtu/
hr.

The
minimum
city
gas
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
city
gas.
This
number
is
670.9
lb/
hr
(Table
9.2­
2
of
Trial
Bum
Report
for
Boiler
70K).
Our
records
also
indicate
that
the
correct
heat
content
for
the
city
gas
is
21,214
Btu/
lb
(Table
4.2­
1
of
Trial
Bum
Plan
for
Boiler
70K).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
14.2
MMBtu/
hr.

Adding
the
firing
rates
of
the
waste
fuel
and
the
city
gas
provides
a
total
firing
rate
of
23.1
MMBtuihr.

Comment
28
Feedrates,
735C5
­
Please
replace
the
average
waste
fuel
and
natural
gas
feed
rates
with
the
average
of
the
minimum
values.

Comment
29
Feedrates,
735C5
­
Density
and
heat
content
were
not
measured
during
Test
Condition
3.
The
numbers
input
into
the
database
are
for
Test
Condition
1.
Therefore,
an
accurate
firing
rate
for
the
waste
fuel
cannot
be
calculated
for
Test
Condition
3.
Please
delete.

The
minimum
city
gas
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
city
gas.
This
number
is
878.6
lb/
hr
(Table
9.2­
3
of
Tnal
Bum
Report
for
Boiler
70K).
Our
records
also
indicate
that
the
correct
heat
content
of
the
city
gas
is
21,214
Btu/
lb
(Table
4.2­
1
of
Trial
Bum
Plan
for
Boiler
70K).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
18.6
MMBtu/
hr.

Reilly
objects
to
the
use
of
an
F­
factor
determined
estimated
firing
rate.
Reilly
believes
that
the
firing
rates
should
be
based
only
on
data
generated
during
actual
testing
or
as
established
in
permits
or
RCOC
limits,
since
this
data
is
readily
available.
As
also
expressed
in
Comment
26,
Reilly
objects
to
any
manipulation
of
data
at
this
point
in
the
NODA
process.
Since
the
EPA
has
specifically
declined
to
consider
comment
on
data
assessment,
it
is
unfair
for
the
EPA
to
present
such
a
manipulation
of
the
data
at
this
time.

Comment
30
Reilly
objects
to
the
current
location
of
the
Adjusted
Tier
I
limits
presented
in
the
database.
Reilly
believes
that
these
limits
should
be
presented
in
their
entirety
under
Source
Description,
Permitting
Status
as
so
provided
in
Comment
4.

Comment
31
Please
adjust
the
Emissions
and
Feedrate
Data
Summary
Sheet
to
include
all
of
the
above
comments.

Reilly
Industries,
Inc.
Boiler
MACT
NODA
Review
Boiler
30K
Phase
11
ID
No.
737
Comment
1
Source
Description,
Unit
ID
Name/
No.
­
Please
insert
'Boiler'
in
front
of
30K
to
read
'Boiler
3OK'.

Comment
2
Source
Description,
Other
Sister
Facilities
­
Please
replace
'None'
with
'Boiler
70K
for
Cr
+6,

Comment
3
Source
Description,
Sootblowing
­
As
discussed
on
page
4
of
the
Phase
11
HWC
MACT
Data
Base
Report
dated
June
2000,
the
description
of
soot
blowing
as
provided
by
the
EPA
is
to
"identify
whether
soot
blowing
is
used,
as
well
as
the
duration
and
frequency".
Therefore,
Reilly
suggests
that
the
EPA
modify
the
Source
Description
section
of
the
database
to
include
the
following
fields
and
that
the
information
so
provided
be
incorporated
for
#737:

Soot
Blowing
Yes
Frequency
Four
times/
day
Duration
Five­
minutes/
soot
blow
event
Comment
4
Source
Description,
Stack
Characteristics
­
The
most
recent
gas
temperature
and
velocity
from
the
combined
Trial
Bum/
RCOC
is
664'F
and
24.28
ft/
sec,
respectively.
A
copy
of
this
information
has
been
included
for
Agency
review.
Reilly
also
suggests
that
the
EPA
expand
this
portion
of
the
database
to
be
inclusive
of
the
modeling
information
that
was
utilized
by
the
facility.
Failing
to
include
this
information,
which
is
readily
available
from
the
reports
used
thus
far
in
assembling
the
database,
will
not
allow
a
complete,
thorough,
and
consistent
review
between
the
facilities.
Specifically,
Reilly
requests
that
the
EPA
expand
this
section
to
include
the
shortest
distance
from
the
stack
to
the
property
line,
the
distance
of
the
stack
to
their
MEI
(maximum
exposed
individual
or
the
nearest
maximum
exposed
receptor),
the
terrain
type
for
the
facility
(simple,
intermediate,
or
complex),
the
land
use
of
the
facility
(rural
or
urban),
type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.),
and
the
dilution
factor
determined
for
the
stack.
This
information
will
be
vital
in
the
comparison
of
limits
established
for
short
stacks
positioned
near
property
lines
(actually
their
MEI)
versus
the
limits
established
for
taller
stacks
that
are
quite
some
distance
from
an
MEI.
Failing
to
consider
this
infon­
nation
will
significantly
compromise
the
integrity
of
any
effort
used
to
establish
a
MACT
standard.
This
additional
information
is
provided
as
taken
from
our
January
24,
2000
RCOC
Report:

Shortest
distance
from
the
stack
to
the
property
line
67
m
Distance
of
the
stack
to
the
MEI
95.2
m
Terrain
type
for
the
facility
(simple,
intermediate,
or
complex)
inten­
nediate
Land
use
of
the
facility
(rural
or
urban)
urban
Type
of
model
used
(i.
e.
ISCST3
or
ISCLT3,
etc.)
ISCLT3
Dilution
factor
determined
for
the
stack
3
.1
4
4
4
0
5
llg/
M3/
g/
S
Reilly
also
feels
that
the
average
stack
gas
flow
rate
from
each
sample
train
should
be
included
here.
This
value
is
7484
dscftn
and
was
averaged
from
each
sample
train
run
during
Test
Condition
I
of
the
1999
Trial
Bum.
Reilly
will
further
discuss
the
stack
gas
flow
rate
relative
to
the
MTEC
feedrate
calculations
in
comment
19.

Comment
5
Source
Description,
Permitting
Status
­
As
discussed
on
pages
2
and
5
of
the
Phase
11
HWC
MACT
Data
Base
­Report
dated
June
2000,
the
permitting
status
of
the
BIFs
is
comprised
of
a
number
of
items.
Reilly
suggests
that
the
EPA
modify
this
section
of
the
database
to
be
more
precise
and
complete
in
its
inclusion
of
data.
Specifically,
Reilly
recommends
that
the
database
be
expanded
under
the
section
permitting
status
to
include
the
specific
status
and
limits
under
which
each
BIF
is
operating.
This
information
is
significant,
and
should
not
be
overlooked
when
evaluating
MACT
standards.
In
so
making
these
changes,
the
utility
of
the
database
will
be
greatly
enhanced.
Therefore,
the
database
at
a
minimum
should
be
expanded
to
include
the
DRE
standard
(40
CFR
266.104),
particulate
matter
(§
266.105),
the
10
BIF
metals
(§
266.107),
and
HCI/
CI2
(§
266.107).
These
changes
can
be
readily
implemented
as
it
appears
that
the
EPA
already
made
a
simple
attempt
at
such
(see
comment
2
1).

The
DRE
standard
may
be
limited
to
the
following
choices:
(a)
DRE
standard,
(a4)
DRE
waiver,
(a5)
low
risk
waiver,
(b)
CO
Standard,
(c)
Alt
CO
Standard,
and
(d)
other.
For
metals,
the
following
categories
should
be
established:
Tier
1,
Tier
II,
Tier
III,
Adjusted
Tier
1,
and
Adjusted
Tier
I
with
testing
as
allowed
by
§266.106(
g).
The
HCI/
CI2
standard
would
have
these
categories:
Tier
I,
Tier
11,
Tier
III,
and
Adjusted
Tier
I.
Reilly
is
providing
the
following
table
of
this
information
as
it
pertains
to
#737,
as
taken
from
our
January
24,
2000
RCOC
Report:

Section
Parameter
Standard
Limit
Units
266.
x
102/
103
Max.
Waste
Feed
Rate
Operating
condition
2272
lb/
hr
104
Organic
emissions
Carbon
monoxide
100
PPMV
105
Particulate
matter
Ash
Feed
Rate
4039
g/
hr
106
Antimony
Adjusted
Tier
I
344
g/
hr
106
Arsenic
Adjusted
Tier
1
2.63
g/
hr
106
Barium
Adjusted
Tier
1
57,245
g/
hr
106
Beryllium
Adjusted
Tier
1
4.81
g/
hr
106
Cadmium
Adjusted
Tier
1
6.41
g/
hr
106
Chromium
Adjusted
Tier
I
w/
testing
3.88*
g/
hr
106
Lead
Adjusted
Tier
I
103
g/
hr
106
Mercury
Adjusted
Tier
1
344
g/
hr
106
Silver
Adjusted
Tier
1
3435
g/
hr
106
Thallium
Adjusted
Tier
I
572
g/
hr
107
Chlorine/
Chlorides
Adjusted
Tier
1
5000**
g/
hr
*A
Mini­
Bum
Test
was
performed
on
Boiler
70K
to
identify
the
hexavalent
chromium
conversion
ratio.
This
demonstrated
conversion
ratio
of
24.5%
is
currently
being
used
by
Reilly
to
set
the
chromium
feed
rate
limits
for
each
of
the
boilers.
Dividing
the
original
Adjusted
Tier
I
feed
rate
screening
limit
of
0.95
g/
hr
by
the
conversion
ratio
of
24.5%
gives
a
speciated
chromium
feed
rate
of
3.88
g/
hr.

**
Using
emissions
testing
data,
Reilly
demonstrated
that
the
emissions
of
chlorine
were
less
than
one
percent
of
that
which
is
fed.
This
resulted
in
an
Adjusted
Tier
I
feed
rate
screening
limit
of
45,800
g/
hr
(Section
15.11
of
Trial
Bum
Report
for
Boiler
30K).
Reilly
and
the
Agency
agreed
upon
a
total
chlorine/
chloride
feed
rate
limit
of
5,000
g/
hr
rather
than
45,800
g/
hr
since
this
amount
of
feed
rate
was
not
needed.
Please
adjust
Total
Cl
to
reflect
this
change.

Reilly
encourages
the
EPA
to
expand
the
database
as
presented
above
to
include
the
performance
standards,
their
feed
rates,
and
the
basis
for
establishing
them.
Assembling
the
data
in
this
fashion
will
facilitate
a
much
more
efficient
and
thorough
assessment
and
development
of
a
viable
MACT
standard.

Comment
6
Please
remove
all
references
to
the
1996
Revised
Certification
of
Compliance
from
the
database
based
on
EPAs
request
to
use
the
data
from
the
most
recent
compliance
tests.
The
most
recent
compliance
test
report
is
dated
January
24,
2000
and
is
entitled
Revised
Certification
of
Compliance
Test
Report
for
Boilers
70K,
30K,
and
28K.
A
copy
of
this
report
has
been
included
for
Agency
review.

Comment
7
Source
Description,
Report
Name/
Date,
Cond
Numbers
I
and
2
­
Please
replace
the
Revised
Certification
of
Compliance
information
from
1996
with
the
following,
more
current,
Revised
Certification
of
Compliance
information:
Report
Name/
Date
Revised
Certification
of
Compliance
Test
Report
for
Boilers
70K,
30K,
and
28K
January
24,
2000
Report
Prepare
Compliance
Strategies
&
Solutions,
Inc.
Testing
Firm
Compliance
Strategies
&
Solutions,
Inc.,
METCO
Environmental,
Inc.,
and
B3
Systems,
Inc.

Cond
Number
I
Testing
Dates
October
26
­
28,
1999
Cond.
Desc
ription
CoC,
high
feed
rate
Content
PM,
CO,
HCI/
CI2
Cond
Number
2
Testing
Dates
November
2
­
3
and
November
5,
1999
Cond.
Description
CoC,
low
comb
temp
Content
co
A
copy
of
this
report
is
included
for
Agency
review.

Comment
8
The
combined
Trial
Bum/
RCOC
test
dates
of
Boiler
30K
were
November
2
­
3
and
November
5,
1999
(Section
6.3
of
Trial
Bum
Report
for
Boiler
30K).
Please
update
on
the
PCDD/
PCDF
page
for
Condition
ID
737C4
as
well.

Comment
9
Please
include
the
following
information
under
Source
Description,
Report
Name/
Date
and
Condition
Number:

Cond
Number
5
­
Trial
Bum
Retest
Testing
Dates
May
24
­
25,
2000
Cond
Description
Min
Comb
Chamb
Temp,
Min
Steam
Prod
Rate
Content
DRE
A
copy
of
this
report
along
with
the
stack
gas
conditions
is
included
for
Agency
review.

Comment
10
73
7C3
Trial
Bum
­
Run
3
for
HC
should
'be
<
0.
I
(nd)
(Section
14.
1
0
of
Trial
Bum
Report
for
Boiler
30K).

Comment
11
Our
records
indicate
that
the
stack
gas
flow
rates
for
the
PM
and
HCI/
CI2
sampling
train
run
during
the
combined
1999
Trial
Bum/
RCOC
are
7509
dscftn,
7711
dscfm,
and
7578
dscfm
for
Runs
1,
2,
and
3,
respectively.
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30KV/
Stack
Condition
1,
Volume
1,
October
1999,
pg.
14.)
Please
adjust
any
necessary
calculations
to
account
for
these
changes.

Comment
12
The
PM
and
HCI/
CI2
sampling
train
run
during
the
combined
1999
Trial
Bum/
RCOC
oxygen
contents
are
4.2%,
4.8%,
and
4.8%
for
Runs
1,
2,
and
3,
respectively.
(Source
Emissions
SurveyVI'of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Condition
1,
Volume
1,
October
1999,
pg.
14.)
The
numbers
input
into
the
database
under
737C3
Trial
Bum
Sampling
Train
I
are
the
readings
from
the
CEMS
installed
in
the
stack
of
Boiler
30K.
Please
adjust
any
necessary
calculations
toaccount
for
these
changes.

Comment
13
Our
records
indicate
that
the
stack
temperatures
measured
during
the
PM
and
HCI/
CI2
samplingV,
train
run
during
the
combined
1999
Trial
Bum/
RCOC
are
649'F,
666'F,
and
676F
for
Runs
1,
2,
and
3,
respectively.
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Condition
1,
Volume
1,
October
1999,
pg.
14.)

Comment
14
Our
records
indicate
that
the
sampling
train
oxygen
contents
during
Test
Condition
2
of
the
combined
1999
Trial
Bum/
RCOC
are
7.8%,
6.6%,
and
6.2%
for
Runs
1,
2,
and
3,
respectively.
V/
(Source
Emissions
Survey
of
Reilly
Industries,
Inc.
Boiler
30K
Stack
Condition
2,
Volume
1,
October
1999,
pg.
6.)
The
numbers
input
into
the
database
under
737C4
Trial
Bum
Sampling
Train
I
are
the
readings
from
the
CEMS
installed
in
the
stack
of
Boiler
30K.
Please
adjust
any
necessary
calculations
to
account
for
these
changes.

Comment
15
Please
add
the
most
recent
DRE
data
for
1,2­
Dichlorobenzene
gathered
during
the
Trial
Bum
Retest
conducted
May
24
­
25,
2000.
A
copy
of
the
Trial
Bum
Retest
Report
is
included
for
reference.

Comment
16
737C3
Trial
Bum
­
The
data
for
heat
content
and
density
were
switched
and
input
under
the
inappropriate
Test
Conditions.
The
numbers
should
be
input
as
follows:

Test
Condition
1
­
737C3
Heat
Content
and
Density
Parameter
Average
Heat
Content
(Btu/
lb)
15,281
Density
(g/
mL)
0.9880
Test
Condition
2
­
737C4
Heat
Content
and
Density
Parameter
Average
Heat
Content
(Btu/
lb)
15,270
Density
(g/
mL)
0.9893
Comment
17
Feedstreams,
737C3
­
The
maximum
waste
fuel
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
waste
fuel.
This
number
is
2272
lb/
hr
(Table
9.1­
1
of
Trial
Bum
Report
for
Boiler
30K).
The
correct
heat
content
is
15,281
Btu/
lb
(see
comment
16
above).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
34.7
MMBtu/
hr.

The
maximum
city
gas
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
city
gas.
This
number
is
225.6
lb/
hr
(Table
9.2­
1
of
Trial
Bum
Report
for
Boiler
30K).
Our
records
also
indicate
that
the
correct
heat
content
for
the
city
gas
is
21,214
Btu/
lb
(Table
4.2­
1
Trial
Bum
Plan
for
Boiler
30K).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
4.8
MMBtu/
hr.

Adding
the
firing
rates
of
the
waste
fuel
and
the
city
gas
provides
a
total
firing
rate
of
39.5
MMBtu/
hr.

Reilly
objects
to
the
use
of
an
F­
factor
determined
estimated
firing
rate.
Reilly
believes
that
the
firing
rates
should
be
based
only
on
data
generated
during
actual
testing
or
as
established
in
permits
or
RCOC
limits,
since
this
data
is
readily
available.
As
also
expressed
in
Comment
19,
Reilly
objects
to
any
manipulation
of
data
at
this
point
in
the
NODA
process.
Since
the
EPA
has
specifically
declined
to
consider
comment
on
data
assessment,
it
is
unfair
for
the
EPA
to
present
such
a
manipulation
of
the
data
at
this
time.

Comment
18
Feedrates,
737C4
­
The
minimum
waste
fuel
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
waste
fuel.
This
number
is
335.6
lb/
hr
(Table
9.1­
2
of
Trial
Bum
Report
for
Boiler
30K).
The
correct
heat
content
is
15,270
Btu/
lb
(see
comment
16
above).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
5.1
MMBtu/
hr.

The
minimum
city
gas
feed
rate
should
be
used
to
calculate
the
firing
rate
of
the
city
gas.
This
number
is
304.6
lb/
hr
(Table
9.2­
2
of
Trial
Bum
Report
for
Boiler
30K).
Our
records
also
indicate
that
the
correct
heat
content
for
the
city
gas
is
21,214
Btu/
lb
(Table
4.2­
1
of
Trial
Bum
Plan
for
Boiler
30K).
Using
these
numbers
in
the
calculation
provides
a
firing
rate
of
6.5
MMBtu/
hr.

Adding
the
firing
rates
of
the
waste
fuel
and
the
city
gas
provides
a
total
firing
rate
of
11.6
MMBtu/
hr.

Reilly
objects
to
the
use
of
an
F­
factor
determined
estimated
firing
rate.
Reilly
believes
that
the
firing
rates
should
be
based
only
on
data
generated
during
actual
testing
or
as
established
in
permits
or
RCOC
limits,
since
this
data
is
readily
available.
As
also
expressed
in
Conunent
19,
Reilly
objects
to
any
manipulation
of
data
at
this
point
in
the
NODA
process.
Since
the
EPA
has
specifically
declined
to
consider
comment
on
data
assessment,
it
is
unfair
for
the
EPA
to
present
such
a
manipulation
of
the
data
at
this
time.

Comment
19
Reilly
is
noting
two
(2)
objections
to
the
presentation
of
the
MTEC
Feedrate
Calculations.
The
first
is
for
basing
MTEC
calculations
on
feed
rate
data
obtained
during
testing.
The
purpose
behind
most
all
of
the
testing
was
not
to
demonstrate
feed
rates
at
the
allowable
risk
based
levels
(Tier
1,
Adjusted
Tier
1,
etc.).
Instead,
the
feed
rate
data
presented
was
used
to
show
that
the
operations
were
taking
place
at
levels
well
enough
below
the
allowable
risk
based
limits.
Reilly
suggests
that
if
the
MTEC
Feedrate
Calculations
are
to
be
presented
as
part
of
the
database,
then
they
should
be
based
on
the
operating
limits
discussed
in
Comment
5.
Reilly's
second
objection
is
based
on
the
fundamental
intent
of
the
database,
to
present
the
data.
Reilly
understands
that
the
database
is
not
intended
to
manipulate
or
analyze
data,
and
that
in
fact,
the
EPA
is
not
accepting
any
comments
towards
such
an
exercise.
Therefore,
Reilly
concludes
that
the
EPA's
decision
to
choose
feed
rate
data
for
MTEC
calculations
is
unfair
and
unjustified,
and
MTEC
calculations
should
be
dropped
from
the
database
at
this
time
in
their
entirety.
If
the
EPA
disagrees
with
this
second
objection,
then
at
a
minimum,
the
MTEC
should
be
expanded
to
include
calculations
based
on
the
allowable
feed
rates
presented
in
Comment
5
(our
first
objection).

Trial
Bum
­
If
the
Agency
insists
on
calculating
the
MTEC,
The
correct
stack
gas
flow
rate
is
7599
dscfm.

Comment
20
The
maximum
hourly
rolling
average
values
for
each
run
were
used
in
calculating
the
feed
rates
for
metals,
ash,
and
chlorine
for
both
the
Revised
Certification
of
Compliance
and
the
Trial
Bum.
The
minimum
hourly
rolling
average
values
for
each
run
were
used
in
establishing
the
limits
for
the
minimum
combustion
chamber
temperature
and
the
minimum
steam
production
rate.
The
average
of
these
maximum
and
minimum
values
was
used
to
establish
the
operating
limits
for
each
of
the
parameters.
The
numbers
input
into
the
database
seem
to
be
the
average
of
the
average
instead
of
the
average
of
the
maximum
or
minimum
values.
Please
adjust
these
values
to
reflect
the
average
of
the
maximum
and
minimum
values
as
appropriate.

Comment
21
Reilly
objects
to
the
current
location
of
the
Adjusted
Tier
I
limits
presented
in
the
database.
Reilly
believes
that
these
limits
should
be
presented
in
their
entirety
under
Source
Description,
Permitting
Status
as
so
provided
in
Comment
5.

Comment
22
PCDD/
PCDF
737C4
­
Run
3
OCDD
should
read
8.61E­
06
and
2,3,7,8­
TCDF
should
read
nd
8.89E05
(Table
14.6­
6
of
Trial
Bum
Report
for
Boiler
30K).

Comment
23
Please
adjust
the
Emissions
and
Feedrate
Data
Summary
Sheets
to
include
all
of
the
above
comments.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.
Also,
responses
are
provided
as
appropriate
through
some
of
the
above
comments.
Note
that
most
of
these
issues
are
also
addressed
in
the
above
Sections
3
and
4.

5.15
Ticona
Polymers,
Inc.
(Phase
II
ID
#
1018)

Ticona
(16)

SOURCE
DESCRIPTION
Soot
Blowing
In
regards
to
soot
blowing,
Boiler
16
has
the
capability
of
soot
blowing.
Soot
blowing
typically
occurs
six
(6)
times
per
day
and
has
a
duration
of
0.0486
hours
per
soot
blow
event.

Stack
Characteristics
In
regards
to
stack
characteristics
during
dispersion
modeling,
Ticona
obtained
the
worse
case
results
from
the
minimum
combustion
temperature
condition
of
the
Trial
Bum/
Risk
Burn
performed
in
June,
1998.
Hence,
the
data
for
the
stack
characteristics
should
be:

Diameter
(ft):
2.1
Height
(ft):
45
Gas
Velocity
(ft/
sec):
25.8
Gas
Temperature
(F):
576
Response:
The
intent
was
to
represent
the
gas
velocity
and
temperature
as
some
generally
representative
value.
The
temperature
will
be
changed
as
requested.

Permitting
Status
In
regards
to
permitting
status,
Ticona
manages
all
metals
(with
the
exception
of
chromium)
and
chlorine
under
Adjusted
Tier
I.
Chromium
is
managed
under
Tier
III.

In
regards
to
the
Report
Name/
Date
under
Permitting
Status,
the
report
is
entitled:

Trial
Bum/
Risk
Burn
Report
Boiler
16
Celanese
Engineering
Resins,
Inc.
September
1998
The
report
was
prepared
by
TRC
Environmental
Corporation
(TRC).
TRC
was
also
responsible
for
performing
the
testing
on
June
23­
25,
1998.

Condition
10
(1018C10)
In
regards
to
Condition
Description
and
Condition
Content
under
Condition
10
of
the
Permitting
Status,
Condition
10
is
better
described
as
the
maximum
combustion
temperature
condition
during
the
1996
Certification
of
Compliance
(CoC)
performed
on
Boiler
16.
The
1996
CoC
maximum
combustion
temperature
condition
data
was
submitted
with
the
1998
Trial
Burn/
Risk
Burn
Report
as
"data
in
lieu
of
trial
burn".
The
1996
CoC
was
submitted
in
its
entirety
as
an
appendix
in
the
1998
Trial
Burn/
Risk
Burn
Report.

In
addition,
the
content
of
Condition
10
is
better
described
by
saying
that
the
feed
analysis
included
all10
BIF
metals
(not
chromium
only),
chlorides,
and
ash.
Particulate
matter,
carbon
monoxide,
and
hexavalent
and
total
chromium
were
measured
in
the
stack
exhaust.

Condition
12
(1018C12)

In
regards
to
Condition
Description
under
Condition
12
of
the
Permitting
Status,
Condition
12
is
better
described
as
the
risk
burn
condition
at
maximum
liquid
waste
feedrates
and
minimum
natural
gas
flowrate.

STACK
GAS
EMISSIONS
Condition
1018C10
The
maximum
hourly
rolling
average
carbon
monoxide
(CO)
concentration
for
Run
1
of
Condition
1018C10
is
0.6
ppmv
corrected
to
7%
oxygen
and
not
0.06
ppmv
as
reported
in
the
NODA
database.
Consequently.
the
Condition
Average
for
CO
(MHRA)
under
Condition
1018C10
is
10.9
ppmv
instead
of
10.7
ppmv
as
reported
in
the
NODA
database.
Please
reference:
Table
2.3
Boiler
16
Process
Operating
Conditions
During
BIF
Test
­
Condition
No.
3
in
the
Appendix
entitled
Condition
1018C10.

The
Sampling
Train
1
for
PM
was
reported
as
not
being
available
for
Condition
1018C10.
This
information
can
be
found
in
the
1996
CoC
which
was
submitted
as
an
appendix
in
the
1998
Trial
Burn/
Risk
Burn
Report.
As
a
convenience,
please
reference:
Table
2.19
PM
Sampling
Train
Parameters
and
Stack
Conditions
­
Test
Condition
3
in
the
Appendix
entitled
Condition
1018C10.

The
Sampling
Train
for
hexavalent
chromium
was
reported
as
not
being
available
for
Condition
1018C10.
This
information
can
be
found
in
the
1996
CoC
which
was
submitted
as
an
appendix
in
the
1998
Trial
Burn/
Risk
Burn
Report.
As
a
convenience,
please
reference:
Table
2.22
Hexavalent
and
Total
Chromium
Sampling
Train
Parameters
and
Stack
Conditions
­
Test
Condition
3
in
the
Appendix
entitled
Condition
1018C10.

Condition
1018C11
Condition
1018C11
is
the
minimum
temperature
condition
of
the
1998
Trial
Bum/
Risk
Burn
Report.
One
of
the
primary
purposes
of
this
condition
is
to
demonstrate
the
necessary
Destruction
Removal
Efficiency
(DRE).
Ticona
selected
toluene
and
chlorobenzene
as
the
two
principal
organic
hazardous
constituents
(POHCs)
to
measure
in
the
feed
and
in
the
spike
material
fed
to
Boiler
16.
In
addition,
the
stack
exhaust
was
tested
to
determine
the
concentrations
of
the
two
POHCs
so
that
the
DRE
could
then
be
determined.
The
NODA
did
not
report
the
total
amount
of
the
two
POHCs
that
was
fed
to
Boiler
16
instead
it
only
presented
the
contribution
attributable
to
the
waste
feed
burned
in
Boiler
16.
The
total
feedrates
(feed
+
spike)
and
the
emission
rates
of
the
POHCs
can
be
found
in
the
1998
Trial
Burn/
Risk
Burn
Report.
As
a
convenience,
please
reference:
Table
4­
7
Destruction
Removal
Efficiency
Results
in
the
Appendix
entitled
Condition
1018C11.

FEEDSTREAMS
Condition
1018C10
The
only
feed
stream
that
was
described
for
Condition
1018C10
was
the
liquid
waste
stream
fed
to
Boiler
16.
In
addition
to
the
liquid
waste
stream,
Ticona
fed
natural
gas,
an
ash
modifier;
and
particulate
matter
and
hexavalent
chromium
spike
feeds
to
Boiler
16.
Ticona
adds
Fuelsolv
FS850
(ash
modifier)
along
with
the
liquid
waste
stream
to
enhance
the
particulate
matter
characteristics
in
the
case
where
particulate
is
generated
as
a
solid
in
the
firebox
chamber.
The
ash
modifier
is
ratioed
to
the
liquid
waste
feedrate
and
the
liquid
waste
ash
content.
On
average,
0.13
gallons
per
hour
of
the
ash
modifier
is
added
continuously
to
the
liquid
waste
stream.
The
stream
feedrates
and
their
respective
ash,
chlorine
and
metals
feed
rates
may
be
found
in
the
1996
CoC
which
was
submitted
as
an
appendix
in
the
1998
Trial
Burn/
Risk
Bum
Report.
As
a
convenience,
please
reference:
Table
2.7
Liquid
Waste
Feed
Stream
Characterization
and
Constituent
Feed
Rates
Test
Condition
No.
3:
Table
2.10
Ash
Modifier
Feed
Stream
Characterization
and
Constituent
Feed
Rates
Test
Condition
No.
3;
and
Table
2.13
Total
Feed
Rates
of
Ash,
Chlorine,
and
Metals
to
Boiler
16
­
Condition
No.
3
in
the
Appendix
entitled
Condition
1018C10.

The
Stack
Gas
Flowrate
and
Oxygen
Content
for
Condition
1018C10
was
reported
as
not
being
available.
In
feet,
the
stack
gas
flowrate
and
the
oxygen
content
were
actually
collected
in
both
the
particulate
matter;
and
the
hexavalent
and
total
chromium
sampling
trains
during
the
1996
CoC.
As
a
convenience,
please
reference:
Table
2.19
PM
Sampling
Train
Parameters
and
Stack
Conditions
­
Test
Condition
3
and
Table
2.22
Hexavalent
and
Total
Chromium
Sampling
Train
Parameters
and
Stack
Conditions
­
Test
Condition
3
in
the
Appendix
entitled
Condition
1018C10.

Condition
1018C11
The
only
feed
stream
that
was
described
for
condition
1018C11
was
the
liquid
waste
stream
fed
to
Boiler
16.
In
addition
to
this
stream,
Ticona
fed
natural
gas,
and
an
ash
modifier
at
a
feedrate
of
~499
grams
per
hour
to
Boiler
16.
The
ash
modifier
is
described
above
in
Condition
1018C10.

...(
section
removed
and
addressed
in
Section
4.8
(feedrate
non­
detect
calculation
unclear)
Firing
Rate
In
regards
to
the
firing
rate
calculation
for
Condition
1018C12,
the
natural
gas
firing
rate
contribution
was
not
included.
During
this
condition,
12.05
thousand
standard
cubic
feet
per
hour
(mscfh)
of
natural
gas
was
fed
to
Boiler
16.
This
feed
rate
accounts
for
~12.5
million
BTU
per
hour
(MMBTU/
hr)
of
additional
firing
rate
capacity
based
on
an
estimated
heating
value
of
1040
BTU/
scf
for
natural
gas.
The
total
firing
rate
for
Boiler
16
during
Condition
1018C12
is
approximately
67.5
MMBTU/
hr
when
considering
the
liquid
waste
and
natural
gas
feedrates.

In
addition,
Boiler
16
is
always
operated
with
a
minimum
of
at
least
12­
15
mscfh
of
natural
gas.
The
natural
gas
feedrates
during
Conditions
1018C10
and
1018C11
is
available
in
the
1998
Trial
Burn/
Risk
Burn
Report.

Feedrate
MTEC
Calculations
Once
the
discrepancies
recommended
above
in
the
FEEDSTREAMS
section
for
Condition
1018C12
are
implemented
regarding
the
corrections
to
the
barium
and
mercury
feedrates
in
the
liquid
waste
stream
and
the
antimony
feedrate
in
the
ash
modifier
as
well
as
the
addition
of
"nd"
(non­
detect)
to
the
thallium
feedrate
in
the
liquid
waste
stream
and
the
antimony
feedrate
in
the
ash
modifier,
the
Feedrate
MTEC
calculations
should
then
be
mathematically
correct.

BIF
Tier
I
Feedrates
The
BIF
Tier
I
feedrate
limits
were
initially
submitted
in
Volume
8
of
the
1998
Trial
Burn/
Risk
Burn
Report.
Since
then,
the
BIF
Tier
I
feedrate
limits
were
subsequently
revised
and
resubmitted
to
the
Texas
Natural
Resource
Conservation
Commission
in
August
1999.
For
convenience,
the
BIF
Tier
I
feedrate
limits
are
documented
below
in
grams
per
hour
and
in
micrograms
per
dry
standard
cubic
meter
(ug/
dscm)
using
the
same
basis
as
used
for
the
Feedrate
MTEC
Calculations.

Constituent
BIF
Tier
I
Feedrate
(grams/
hour)
BIF
Tier
I
Feedrate
(ug/
dscm)

Chlorine
531.37
22099.5
Antimony
398.52
16574.3
Barium
66420.66
2762406.9
Lead
119.56
4972.4
Mercury
106.27
4419.7
Silver
3985.24
165744.4
Thallium
398.52
16574.3
Arsenic
0.45
18.7
Beryllium
0.47
19.5
Cadmium
0.47
19.5
Hexavalent
chromium
is
managed
under
Tier
III.
During
Condition
1018C10,
Ticona
demonstrated
that
at
a
spiked
chromium
feedrate
of
13.66
g/
hr
that
it
could
meet
its
emission
rate
limit
of
0.77
g/
hr.
Similarly,
Ticona
demonstrated
during
Condition
1018C10
that
at
a
spiked
ash
feedrate
of
3844
g/
hr
that
it
could
meet
the
BIF
PM
limit
of
0.08
grains/
dscf.
The
1996
CoC
maximum
combustion
temperature
condition
data
(Condition
1018C10)
was
submitted
with
the
1998
Trial
Burn/
Risk
Burn
Report
as
"data
in
lieu
of
trial
burn".
The
1996
CoC
was
submitted
in
its
entirety
as
an
appendix
in
the
1998
Trial
Burn/
Risk
Burn
Report.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.16
Rubicon
Inc.
(Phase
II
ID
#
812,
813,
814,
and
815)

Rubicon
(17)

Comments
on
NODA
Phase
II
Database
Rubicon
Inc.

These
comments
will
be
for
the
following
sources,
812,
813,
814,
and
815
as
identified
in
the
NODA
Phase
II
Database.
Comments
will
be
organized
for
each
source
by
each
spreadsheet
for
that
source.

General
Comment
Overall
the
accuracy
of
the
database
is
good
with
respect
to
Rubicon's
sources,
812,
813,
814,
and
815.
The
only
discrepancies
noted
were
incorrect
entries
of
data
or
missing
information.

Source
812
­
TDI
Boiler,
Rubicon
Inc.

Source
Spreadsheet
­
812
Database
Combustor
Characteristics:
Waste
heat
boiler,
30
MMBtu/
hr,
installed
1985,
25,000
lb/
hr
steam
@
215
psig
Comment
1
A
more
accurate
description
for
Combustor
Characteristics
is:
Turbulent
burner
chamber,
closed
coupled
to
a
watertube
waste
heat
boiler,
30
MMBtu/
hr,
installed
1985,
25,000
lb/
hr
steam
@
215
psig.

Requested
Action:
Update
the
Combustor
Characteristics
with
this
description.

Database
Stack
Height:
(blank)

Comment
2
The
stack
height
for
this
source
is
100
ft.

Requested
Action:
Update
the
stack
height
to
read
100
ft.

Database
Permit
Status:
Tier
I
adjusted
except
Cr+
6
Comment
3
The
permit
status
should
be
the
following:
Permit
Status;
Tier
I
adjusted
except
Cr+
6
and
HCl/
Cl2.

Requested
Action:
Update
the
permit
status
to
reflect
this
change.

Feed
Spreadsheet
­
812
Database
812C2,
Run
5,
LUWA
Bottoms
Total
Chorine
feed
rate:
265
lbs/
hr.

Comment
4
The
reported
number
for
812C2,
Run
5,
LUWA
Bottoms
Total
Chorine
feed
rate
is
267
lbs/
hr.
This
is
found
in
Table
2­
12
of
the
TDI
Boiler
Compliance
Trial
Burn
Report
submitted
on
December
29,
1997.

Requested
Action;
Update
812C2,
Run
5,
LUWA
Bottoms
Total
Chorine
feed
rate
to
the
reported
number
of
267
lbs/
hr.

Database
812C2,
Average
LUWA
Bottoms
Measured
Chorine
feed
rate:
95
lbs/
hr.

Comment
5
The
reported
number
for
812C2,
Average
LUWA
Bottoms
Measured
Chorine
feed
rate
is
96.8
lbs/
hr.
This
is
found
in
Table
2­
12
of
the
TDI
Boiler
Compliance
Trial
Burn
Report
submitted
on
December
29,
1997.

Requested
Action:
Update
812C2,
Average
LUWA
Bottoms
Measured
Chorine
feed
rate
to
the
reported
number
of
96.8
lbs/
hr.

Database
The
812C2
LUWA
Bottoms
Chromium
feed
rate
for
all
three
runs
are
listed
below:

812C2
Run
2
Run
4
Run
5
Avg
Stream
Description
LUWA
bottoms
LUWA
bottoms
LUWA
bottoms
LUWA
bottoms
Chromium
lb/
hr
5.00E­
03
5.00E­
03
5.00E­
03
5.00E­
03
Comment
6
The
reported
812C2
LUWA
Bottoms
Chromium
feed
rate
for
all
three
runs
are:

812C2
Run
2
Run
4
Run
5
Avg
Stream
Description
LUWA
bottoms
LUWA
bottoms
LUWA
bottoms
LUWA
bottoms
Chromium
lb/
hr
5.36E­
03
5.48E­
03
5.15E­
03
5.33E­
03
This
is
found
in
Table
2­
12
of
the
TDI
Boiler
Compliance
Trial
Burn
Report
submitted
on
December
29,
1997.

Requested
Action:
Update
812C2
LUWA
Bottoms
Chromium
feed
rate
to
the
reported
numbers
for
this
condition.

...(
section
removed
and
addressed
in
Section
4.9)

Process
Spreadsheet
­
812
Database
812C1
Scrubber
L/
G
Ratio
gal/
kcaf?

Comment
8
The
units
for
Scrubber
L/
G
Ratio
are
lb/
lb.

Requested
Action:
Update
the
unit
for
Scrubber
L/
G
to
lb/
lb.

Database
812C2
Scrubber
L/
G
Ratio
gal/
kcaf?

Comment
9
See
Comment
8
Database
813C3
Scrubber
L/
G
Ratio
gal/
kcaf?

Comment
10
See
Comment
8
...(
section
removed
and
addressed
in
Section
4.9)

Source
813
­Aniline
II
Boiler,
Rubicon
Inc.

Source
Spreadsheet
813
Database
Combustor
Characteristics:
Steam
of
25,000
lb/
hr
@
350
psig
Comment
12
A
more
accurate
description
for
Combustor
Characteristics
is:
Turbulent
burner
chamber
closed
coupled
to
a
water
tube
waste
heat
boiler
and
economizer,
Steam
of
25,000
lb/
hr
@
350
psig.

Requested
Action:
Update
the
Combustor
Characteristics
with
this
description.

Database
Stack
Velocity
ft/
min
Comment
13
The
units
for
stack
velocity
should
be
ft/
sec.

Requested
Action:
Update
the
units
for
stack
velocity
to
ft/
sec.

Database
Permitting
Status:
(blank)

Comment
14
The
permitting
status
for
this
unit
is
Adjusted
Tier
I.

Requested
Action:
Update
the
permit
status
to
reflect
this
change.

Emission
Spreadsheet
­
813
Database
813C1
Run
4
there
is
no
indication
of
Soot
Blowing
Comment
15
During
Run
4
of
813C1
there
were
6
minutes
of
Soot
Blowing
as
reported
in
Section
3.2
of
the
Aniline
II
Compliance
Trial
Burn
Report
Submitted
on
December
29,
1997.

Requested
Action:
Update
the
database
to
reflect
this
information.

Feed
Spreadsheet
­
813
Database
813C1
Average
Condition
Hydrogen
feed
rate:
105
lbs/
hr
Comment
16
The
reported
value
for
the
Average
Condition
Hydrogen
feed
rate
is
106
lbs/
hr.
This
is
found
in
Tables
2­
1
through
2­
3
of
the
Aniline
II
Boiler
Compliance
Trial
Burn
Report
submitted
on
December
29,
1997.

Requested
Action:
Update
the
Average
Condition
Hydrogen
feed
rate
to
the
reported
value.

...(
section
removed
and
addressed
in
Section
4.9)

Source
814­
DPA
I
Superheater,
Rubicon
Inc.

Source
Spreadsheet
­
814
Database
Combuster:
Boiler
Comment
19
A
better
description
for
this
unit
is
Process
Heater/
Boiler.
The
primary
function
of
the
DPA
I
Superheater
is
to
superheat
a
raw
material
used
in
the
production
of
Diphenylamine.
This
unit
does
produce
steam
but
only
a
small
portion
of
the
total
heat
input
is
utilized
for
steam
production.

Requested
Action:
Update
the
Combustor
section
to
reflect
this
description.

Database
Stack
Height:
(blank)

Comment
20
The
Stack
Height
for
this
source
is
75
ft.

Requested
Action:
Update
the
stack
height
to
read
75
ft.

Database
Velocity
ft/
min
Comment
21
See
Comment
13.

Emissions
Spreadsheet
­
814
Database
The
values
for
stack
gas
flow
rate,
moisture
and
temperature
from
the814C2
(B
run
)
are
listed
below.

814C2
(B
Runs)
1B
2B
3B
Cond
Avg
Sampling
Train
1
PCDD
PCDF
Stack
Gas
Flowrate
dscfm
5254
5561
5518
5444
Moisture
%
60.9
57.1
59.7
59.2
Temperature
°F
697
678
685
687
Comment
22
The
reported
values
for
stack
gas
flow
rate,
moisture
and
temperature
from
the
814C2
(B
runs)
are
listed
below:

814C2
(B
Runs)
1B
2B
3B
Cond
Avg
Sampling
Train
1
PCDD
PCDF
Stack
Gas
Flowrate
dscfm
5207
5273
5416
5299
Moisture
%
60.41
60.07
59.38
59.95
Temperature
°F
682
678
685
681.7
These
Values
are
found
in
Table
3­
35
of
the
Risk
Assessment
Trial
Burn
Report
Submitted
on
December
29,
1997.

Requested
Action:
Update
the
stack
gas
flow
rate,
moisture
and
temperature
from
the
814C2
(B
runs)
to
the
reported
values.

Feed
Spreadsheet­
814
Database
The
values
for
the
ash
feed
rate
from
the
814C2
(
A
runs)
are
listed
below:

Comment
23
The
reported
values
for
the
ash
feed
rate
from
the
814C2
(A
runs)
are
listed
below:

814C2
(A
runs)
Run
3A
Run
4A
Run
5A
Cond.
Avg.

Ash
lb/
hr
1.09
1.17
1.14
1.13
These
values
are
found
in
Tables
2­
1
through
2­
3
of
the
Risk
Assessment
Trial
Burn
Report
Submitted
on
December
29,
1997.

Requested
Action:
Update
the
ash
feed
rate
from
the
814C2
(A
runs)
to
the
reported
values.

...(
section
removed
and
addressed
in
Section
4.9)

Source
815
­
DPA
II
Superheater,
Rubicon
Inc.

Source
Spreadsheet­
815
Database
Combuster:
Boiler
Comment
26
A
better
description
for
this
unit
is
Process
Heater/
Boiler.
The
primary
function
of
the
DPA
I
Superheater
is
to
superheat
a
raw
material
used
in
the
production
of
Diphenylamine.
This
unit
does
produce
steam
but
only
a
small
portion
of
the
total
heat
input
is
utilized
for
steam
production.

Requested
Action:
Update
the
Combustor
section
to
reflect
this
description.

Database
Combustor
Characteristics:
Turbulent
burner
chamber
Comment
27
A
more
accurate
description
for
this
unit
is
Turbulent
burner
chamber,
separate
tube
banks.
Requested
Action:
Update
the
Combustor
Characteristics
with
this
description.

Database
Stack
velocity
ft/
min
Comment
28
See
Comment
13
Database
Stack
Height:
(blank)

Comment
29
The
stack
height
for
this
unit
is
80.5
ft.

Requested
Action:
Update
the
stack
height
to
read
80.5
ft.

Feed
Spreadsheet
­
815
Database
The
firing
rate
for
815C1
is
stated
as
17.0
MMBTU/
hr
Comment
30
The
reported
firing
rate
for
815C1
is
15.7
MMBTU/
hr
as
shown
in
Tables
2­
1
through
2­
3
of
the
DPA
II
Compliance
Trial
Burn
Report
submitted
on
December
29,
1997.

Requested
Action:
Update
the
firing
rate
for
815C1
to
the
reported
value.

...(
section
removed
and
addressed
in
Section
4.9)

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.17
Equistar
Chemicals,
LP.
(Phase
II
ID
#
774)

Equistar
(18)

Information
from
the
1998
BIF
recertification
report
was
used
to
develop
the
proposed
NESHAP
database;
however,
some
information
is
missing
or
has
not
been
accurately
entered
into
the
database
and
has
been
revised.
These
changes
include:

Inclusion
of
Boiler
Nos.
1,2
and
4
as
sister
facilities

Addition
of
exhaust
stack
characteristics

Correction
of
gas
flowrate
and
addition
of
percent
moisture
and
gas

temperature
of
sampling
train
1
and
stack
gas
flowrate.


Correction
of
mass
feedrate
of
liquid
hazardous
waste
and
metal
feedrates
and
addition
of
heating
value
for
the
natural
gas
stream
for
both
operating
conditions
774C1
and
774C2.

The
values
from
the
"Feedrate
MTEC
Calculations"
contained
in
the
774C1
section
for
each
of
the
ten
BIF
metals,
ash,
chlorine,
SVM
and
LVM
have
not
been
corrected
for
the
revised
information
and
will
need
to
be
recalculated.

As
instructed
in
the
Federal
Register,
enclosed
are
an
original
and
two
copies
of
the
comment
response
which
include
a
copy
of
the
Certificate
of
Compliance
forms
and
pages
containing
the
additional
information
from
the
1998
BIF
recertification
report.
Also,
a
diskette
containing
the
revised
NODA
electronic
file
using
Microsoft
Excel
97®
has
also
been
enclosed
with
each
comment
package.

Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.18
Dow
Chemical
(Phase
II
ID
#
729,
851,
730,
733,
786,
788,
842,
843,
844,
845,
848,
849,
2017,
2018,
2020)

The
Dow
Chemical
Company
(19)

The
Dow
Chemical
Company
appreciates
this
opportunity
to
provide
comments
on
the
database
the
United
States
Environmental
Protection
Agency
(EPA)
presented
in
the
Notice
of
Data
Availability
(NODA)
for
Future
Phase
11
Combustion
Rulemaking
found
at
65FR
39581
dated
June
27,
2000.
It
is
Dow's
understanding
that
this
is
the
database
the
Agency
will
use
to
propose
the
National
Emission
Standards
for
Hazardous
Air
Pollutants
(NESHAPS)
for
hazardous
waste
burning
boilers,
halogen
acid
furnaces,
and
sulfuric
acid
recovery
furnaces.
We
appreciate
the
EPA
efforts
to
develop
reasonable
regulations
and
are
pleased
to
be
able
to
contribute
our
thoughts
and
concerns.
Dow
has
reviewed
the
information
for
its
Facilities
included
in
the
database
and
offer
comments
on
the
accuracy
and
completeness
of
the
database.
Enclosed
are
an
original
and
two
copies
of
Dow's
comments.
We
appreciate
EPA
consideration
of
Dow
comments.

In
reviewing
the
database
presented
in
the
NODA,
Dow
has
identified
a
number
of
inaccuracies
and
suggested
corrections
to
eliminate
those
inaccuracies.
To
facilitate
the
Agency's
review
we
have
provided
general
comments
followed
by
detail
findings
that
are
sorted
by
the
facility
EPA
phase
11
identification
number
and
specific
spreadsheets.
In
general
our
comments
are:

1)
Dow
agrees
with
EPA
concept
of
a
complete
and
accurate
database,
however
reviewing
of
a
database
of
this
size
is
a
large
undertaking
and
60
days
was
not
enough
time
to
provide
the
level
of
review
necessary
to
assure
completeness
and
accuracy.
Therefore,
Dow
suggests
that
the
agency
informally
continue
to
accept
comments,
with
full
EPA
review,
from
industry
on
the
existing
database
thirty
(30)
additional
days
after
the
end
of
the
comment
period
(until
September
28,
2000).
During
this
additional
30
days,
Dow
submit
the
missing
data
for
one
of
its
facilities
impacted
by
the
phase
II
rulemaking
that
is
not
included
in
the
database
and
pages
of
reports
supporting
our
findings
that
are
inconsistent
with
what
is
currently
in
the
database.
Due
to
the
shortness
of
the
comment
period,
we
could
not
provide
all
this
data
with
these
comments,
but
the
data
will
be
sent
so
it
can
be
include
the
database.

Response:
As
discussed
above
in
response
to
commenter
No.
24
(the
American
Chemistry
Council)
in
Section
2,
the
comment
period
will
not
be
extended.
This
is
primarily
due
to
the
extremely
simple
data
base
setup
and
structure
to
allow
for
easy
review.
However,
EPA
will
do
its
best
to
fully
consider
all
comments
received
after
the
comment
period
close
date.
Note
that
stakeholders
will
be
able
to
review
and
comment
on
the
data
base
again
when
the
rule
is
proposed.

Dow
I.
D.
Name:
Symtet
RAF
EPA
I.
D.
Number:
CAD076528678
Facility
Location:
Pittsburg
CA
Data
Submittal
Date(
s):
July
5,
2000
(trial
bum)

2)
Dow
is
concerned
that
the
database
may
be
difficult
to
use
for
the
purpose
of
setting
standards
if
the
data
is
not
collected
in
a
consistent
manner.
Due
to
the
diversity
of
the
units
impacted
by
the
potential
rulemaking,
there
are
different
goals
for
the
various
performance
tests.
Therefore,
the
performance
tests
are
performed
in
significantly
different
ways.
We
found
several
inconsistencies
in
how
information
was
collected
and
inputted
into
the
database.
For
example,
the
use
of
significant
figures
and
exclusion
of
pemitted
feedrate
limits
are
two
of
these
inconsistencies.
It
is
important
that
well­
defined
ground
rules
are
established
for
the
consistent
collection
and
imputing
of
information
into
the
database.

Response:
Although
we
intended
to
collect
on
compliance
test
(i.
e.,
trial
burn
or
CoC
testing)
data
for
the
Phase
II
data
base,
we
acknowledge
that
some
test
conditions
are
actually
risk
burns
where
emissions
may
be
representative
of
normal
emissions
rather
than
the
worst­
case
emissions
of
a
compliance
test.
Further,
data
in
a
compliance
test
for
one
pollutant
may
represent
worst­
case
emissions
(i.
e,
the
emissions
and
other
data
were
used
to
demonstrate
compliance
with
an
emission
standard
and
establish
operating
limits)
while
data
in
that
same
test
may
represent
normal
emissions
for
another
pollutant
(e.
g.,
emissions
of
the
the
pollutant
may
been
measured
even
thought
the
source
complied
with
Tier
I
feedrate
limits
for
the
pollutant
and
did
not
operating
under
worst­
case
conditions
for
that
pollutant).
Accordingly,
we
have
now
classified
the
emissions
data
for
each
test
condition
as
worst­
case
versus
normal.

We
disagree
with
the
commenter,
however,
that
there
are
inconsistencies
in
how
information
was
collected
and
incorporated
in
the
data
base.
Procedures
for
collecting
the
data
and
incorporating
the
data
into
the
data
base
are
fully
consistent
and
well
defined
in
the
report
accompanying
the
release
of
the
data
base.
Also,
as
discussed
in
response
to
commenter
No.
24,
permitted
feedrate
limits
were,
in
fact,
included
in
the
data
base;
and
the
use
of
significant
figures
is
consistent
and
sufficient
within
the
accuracy
of
the
overall
data.
Dow
looks
forward
to
working
with
EPA
on
the
development
of
this
Phase
II
Hazardous
Waste
Combustion
rule
and
welcomes
the
opportunity
to
share
it's
knowledge
and
experience
to
help
develop
a
workable
and
meaningful
program.
Please
give
us
a
call
if
you
have
any
questions
on
these
comments
or
if
we
can
be
of
further
assistance.

Sincerely,

Nathaniel
R.
Butler
Paul
Bork
Environmental
Associate
Legal
Department
Environmental
Services
517/
636­
4399
(517)
636­
3711
517/
638­
9636
fax
Comments
of
The
Dow
Chemical
Company
on
F
­
2000
­
RC2A
­
FFFFF
Corrections
for
Dow
Allyns
Point
Facility
(Phase
II
ID
Number
729)

Source
Description
Spreadsheet:

Row
4
­
Tbe
EPA
ID
Number
is
incorrect
it
should
be
CTDO01159730
not
CTDO01159731
Corrections
for
Dow
Pittsburgh
Facility
(Phase
11
ID
Number
851)

Source
Description
Spreadsheet:

Row
22
­
The
stack
is
listed
as
being
12
inches
in
diameter,
however
it
is
reduced
to
8
inches
two
feet
from
the
top.

Row
23
­
The
stack
height
is
listed
incorrectly
as
25.58
feet.
The
actual
height
is
74.5
feet
above
grade.

Stack
Gas
Emission
Spreadsheet:


Cell
G8
­
This
value
was
recorded
incorrectly,
0.6
should
be
changed
to
0.5.


Cell
I8
­
This
value
was
recorded
incorrectly,
0.6
should
be
changed
to
0.5.

Cell
GI
8
­
The
wrong
data
cell
was
used
in
the
formula
to
calculate
this
value.
Cell
G
1
4
the
value
for
hexavalent
chromium
should
have
been
used
instead
of
cell
G
1
2,
the
value
of
arsenic.

Cell
II
8
­
The
wrong
data
cell
was
used
in
the
formula
to
calculate
this
value.
Cell
114
the
value
for
hexavalent
chromium
should
have
been
used
instead
of
cell
II
2,
the
value
of
arsenic.

Cell
E27
­
The
wrong
data
cell
was
used
in
the
formula
to
calculate
this
value.
Cell
E
I
I
the
value
for
chlorine
should
have
been
used
instead
of
cell
E20,
the
value
of
arsenic.
Cell
G27
­
The
wrong
data
cell
was
used
in
the
formula
to
calculate
this
value.
Cell
GI
I
the
value
for
chlorine
should
have
been
used
instead
of
cell
G20,
the
value
of
arsenic.

Cell
127
­
The
wrong
data
cell
was
used
in
the
formula
to
calculate
this
value.
Cell
I
the
value
for
chlorine
should
have
been
used
instead
of
cell
I20,
the
value
of
arsenic.

The
values
in
cells
E32,
G32
and
I32
are
incorrect
and
should
be
changed
to
5.56E06,
5.78E­
06
and
5.47E­
06,
respectively.

The
values
in
cells
E37,
G37
and
137
are
incorrect
and
should
be
changed
to
1.33E05,
1.63E
­05
and
1.91E­
05,
respectively.

The
values
in
cells
E7
1,
G71
and
171
are
incorrect
and
should
be
changed
to
3.9
1
E06,
4.14E­
06
and
3.96E­
06,
respectively.

The
values
in
cells
E76,
G76
and
176
are
incorrect
and
should
be
changed
to
1.
19E05
1.36E­
05
and
1.
I
6E­
05,
respectively.

Cell
B80
­
The
units
should
be
"dscftm"
rather
than
"scftm"

The
values
in
cells
E93,
G93
and
193
are
incorrect
and
should
be
changed
to
0.000014,
0.0000014,
0.000015,
respectively.

Row
96
is
a
duplicate
of
row
93,
values
for
chromium;
row
96
needs
to
be
deleted.

Row
103
­
The
values
for
nickel
are
incorrect
because
of
the
extra
row
for
chromium.
After
the
deletion
of
the
current
row
96
the
nickel
values
will
move
from
row
97
to
become
the
new
row
96
which
will
correct
the
values
in
row
103.

The
values
in
cells
E130,
G130,
I130
and
K130
are
incorrect
and
should
be
changed
to
1097,
1098,
1051
and
1082,
respectively.

The
values
in
cells
E132,
G132,
I132
and
K132
are
incorrect
and
should
be
changed
to
4.1,
3.9,
3.6
and
3.9,
respectively.

The
values
in
cells
E133,
G133,
I133
and
K133
are
incorrect
and
should
be
changed
to
157,
152,
145
and
151,
respectively.

Feedstream
Spreadsheet:

The
barium
emission
value
used
in
the
formula
to
calculate
the
value
in
ce1
ID14
of
0.148
is
incorrect
and
should
be
changed
to
0.184.

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.
PCDD/
PCDF
Spreadsheet:

The
value
listed
in
cell
J32
is
incorrect
and
should
be
changed
to
61.6.

Corrections
for
Dow
Hanging
Rock
Facilitv
(Phase
II
ID
Number
730)

Feedstream
Spreadsheet:

The
tier
I
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Torrance
Facility
(Phase
II
ID
Number
733)

Source
Description
Spreadsheet:

The
date
of
the
certification
of
compliance
test,
August
1992,
should
be
added
to
cell
29B.

Corrections
for
Freeport
Facility
(Phase
11
ID
Number
786)

Feedstream
Spreadsheet:

The
values
in
cells
D7,
D78
and
D99
are
incorrect
and
should
be
changed
to
5381.3,
4135.7
and
4918,
respectively.

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
ID
Number
788)

Feedstream
Spreadsheet:

The
units
for
density
were
incorrectly
recorded
in
cell
B
I
I
1
as
lb./
gal
and
should
be
changed
to
g/
ml.

The
values
in
cells
D119,
D123,
D124,
F116,
F120
and
F126
are
incorrect
and
should
be
changed
to
0.07,
0.2,
1.3,
0.8,
0.8
and
0.8,
respectively
The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
ID
Number
842)

Feedstream
Spreadsheet:

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facilit­
y
(Phase
11
ID
Number
843)
Feedstream
Spreadsheet:

The
value
recorded
in
cell
D77
for
the
feedrate
of
Heavy
Oil
is
incorrect
and
should
be
changed
to
3086.7.

The
tier
I
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
II
ID
Number
844)

Feedstream
Spreadsheet:

The
tier
I
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
II
ID
Number
845)

Feedstream
Spreadsheet:

The
values
recorded
in
cells
D72
and
F72
are
incorrect
and
should
be
changed
to
2476
and
2805,
respectively.

The
tier
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
ED
Number
848)

Feedstream
Spreadsheet:

The
value
recorded
in
cells
D78
is
in
correct
and
should
be
changed
to
l541.

The
tier
III
constituent
permitted
feedrate
limit
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
E[)
Number
849)

Feedstream
Spreadsheet:

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
IID
Number
2017)

Stack
Gas
Emission
Spreadsheet:

The
value
recorded
in
cell
E7
is
incorrect
and
should
be
0.0062.

Feedstream
Spreadsheet:

The
values
recorded
in
cells
D8,
DI3,
D94
and
E94
are
in
correct
and
should
be
changed
to
27,
2840,
2015
and
1524,
respectively.

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
ID
Number
2018)

Feedstream
Spreadsheet:

The
values
recorded
in
cells
D29
and
D43
are
incorrect
and
should
be
changed
to
34.9
and
0.22,
respectively.

The
tier
I
and
III
constituents
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Corrections
for
Freeport
Facility
(Phase
11
ID
Number
2020)

Feedstream
Spreadsheet:

The
tier
III
constituent
permitted
feedrate
limits
should
be
added
to
this
spreadsheet.

Response
Responses
to
these
specific
data
base
issues
are
contained
in
the
attached
data
base
correction
summary
Table
3.
We
agree
with
most
of
the
suggested
changes.
Note
that
Tier
I
and
III
feedrate
limits
have
been
added
where
available.

5.19
General
Electric
(Phase
II
ID
#
766)

GE
(20)

This
e­
mail
contains
a
comment
from
General
Electric
Company
("
GE")
on
EPA's
June
27,
2000
"Notice
of
data
availability
for
future
Phase
11
combustion
rulemaking"
published
at
65
Federal
Register
39,581.
This
e­
mail
supplements
the
written
comments
dated
August
21,
2000
that
GE
has
already
filed.
In
the
"source"
worksheet
of
workbook
766.
xls
(for
the
GE
Plastics
facility
in
Selkirk,
NY),
the
"Permifting
Status"
is
shown
as
"Tier
I
A
for
metals
and
chlorine".
This
is
incorrect.
The
limits
for
metals
and
chlorine
are
adjusted
Tier
I
feed
rate
screening
limits
established
pursuant
to
40
CFR
266.106(
e).
Thus,
this
entry
should
be
changed
to
read
"Adjusted
Tier
I
for
all
metals
and
chlorine".

Please
contact
either
Stephen
Capone
(Manager,
Air
Regulatory
Programs
for
GE
Plastics,
413­
448­
7609)
or
me
(812­
831­
4688)
if
you
have
any
questions.
Thank
you.

Regards,
Alphonse
McMahon
Counsel­
EHS
Programs,
GE
Plastics
al.
mcmahon@
gep.
ge.
com
Response
No
change
is
made.
We
do
not
understand
what
is
wrong
with
the
NODA
data
base
entry.
Tier
IA
implies
that
adjusted
Tier
I
feedrate
limits
are
used
to
set
metals
and
chlorine
limits.
This
is
what
is
suggested
as
the
change.

5.20
DSM
(Phase
II
#
754,
756)

DSM
Elastomers
Americas,
DSM
Copolymer,
Inc
(21)

DSM
Elastomers
Americas
is
pleased
to
provide
the
following
comments
on
this
NODA
for
Phase
11
MACT
combustion
rulemaking
for
hazardous
waste
boilers
and
industrial
furnaces:

The
database
containing
our
1997
risk
bum
results
does
not
illustrate
natural
gas
data
that
we
submitted
to
the
United
States
Environmental
Protection
Agency
Region
VI,
AR/
LA
RCRA
Permits
Section
(6PD­
A).
We
conducted
a
second
test
on
our
hazardous
waste
boiler
using
just
natural
gas
tested
under
USEPA
risk
bum
protocol
but
without
supplemental
hazardous
waste
fuel.
This
test
showed
no
appreciable
difference
in
results
between
the
two
bums
and
shows
an
excellent
baseline
for
comparison
between
firing
media.
We
feel
that
the
Agency
should
include
this
data
because
it
has
been
considered
in
determination
of
permitted
conditions
for
our
Louisiana
facility
and
it
shows
expected
results
in
the
stack
effluent
in
both
tests
by
Compounds
of
Potential
Concern
(COPCs).

In
our
hazardous
waste
boiler
operations,
we
utilize
a
90/
10
ratio
of
natural
gas
to
hazardous
waste
fuel
rate.
We
feel
that
scaling
emissions
detected
in
the
1997
risk
bum
according
to
the
natural
gas
to
hazardous
waste
ratio
should
be
strongly
considered
by
the
Agency.
The
attached
document
is
Section
3.10
of
our
Risk
Bum
Final
Report
submitted
to
the
United
States
Environmental
Protection
Agency
Region
VI,
AR/
LA
RCRA
Permits
Section
(6PD­
A).
This
section
demonstrates
a
comparison
between
results
from
burning
hazardous
waste
versus
buming
just
natural
gas.
The
natural
gas
data
is
contained
under
the
Baseline
Data
columns.
This
comparison
plus
the
feed
ratios
should
be
considered
strongly
by
the
Agency
during
permit
determinations.

Response:
Test
data
from
burning
natural
gas
only
is
not
of
direct
interest
in
this
rulemaking,
which
concerns
the
performance
of
systems
burning
hazardous
wastes.
We
are
not
sure
how
it
could
be
used
or
is
appropriate
for
determining
the
performance
of
boilers
burning
hazardous
wastes.
Also,
we
are
not
sure
how
scaling
emissions
from
natural
gas
and
hazardous
waste
is
appropriate,
particularly
given
that
emissions
from
hazardous
waste
is
directly
available.

The
BIF
facilities
in
Louisiana
are
currently
being
evaluated
by
the
United
States
Environmental
Protection
Agency­
Region
VI
for
unacceptable
risk
associated
with
exposure
to
emissions
from
hazardous
waste
boilers
and
industrial
furnaces.
Those
facilities
who
chose
to
assume
Tier
I
emission
limits
for
BIF
metals
where
detection
limits
have
not
be
low
enough
(either
by
testing
or
by
the
Tier
I
emission
limit)
to
meet
the
risk
assessment
protocol
values.
For
those
non­
detect
metals
in
the
waste
stream
the
reported
method
detection
limit
from
the
laboratory
is
being
calculated
into
a
reliable
detection
limit
by
USEPA
Region
VI
and
used
in
the
analysis.
For
certain
non­
detect
metals
this
practice
is
causing
unacceptable
risk
in
the
final
analysis.
Since,
the
Phase
I
HWCMACT
standards
were
based
upon
a
risk
assessment
analysis
DSM
Elastomers
Americas
feels
that
the
Agency
needs
to
adequately
address
the
detection
limit
problem
found
with
non­
detect
metals
in
the
waste
feed
analysis
before
developing
emission
standards
for
boilers
and
industrial
furnaces
that
balance
science
with
safety
of
the
neighbors
surrounding
our
plants.

Response:
Procedures
for
handling
non­
detect
feedrate
measurements
in
assessing
the
protectiveness
of
the
MACT
standards
will
be
given
consideration
at
a
later
date.
We
currently
plan
to
consider
stack
gas
emissions
measurements
assuming
that
non­
detects
are
present
at
one­
half
of
the
reported
detection
limit.
If
feedrate
measurements
are
used
to
assess
the
protectiveness
of
the
MACT
standards,
procedures
used
for
handling
non­
detects
will
be
presented
for
review
and
comment
in
the
proposed
rule..

Thank
you
for
allowing
us
the
opportunity
to
provide
comments
on
the
data
that
will
be
used
for
developing
MACT
emissions
standards
for
hazardous
waste
boilers
and
industrial
furnaces.
If
you
have
any
questions
please
give
me
a
call
at
(225)
267­
3466.

5.21
Union
Carbide
(Phase
II
#
753,
907,
908,
910)

Union
Carbide
Corporation
(22)

Union
Carbide
Corporation
(UCC)
is
pleased
to
submit
comments
on
the
Environmental
Protection
Agency's
(EPA)
June
27,
2000
notice
of
data
availability
for
future
Phase
11
combustion
rulemaking.

UCC
is
a
global
chemical
manufacturer
and
has
a
number
of
facilities
in
the
United
States
that
will
be
impacted
by
this
future
combustion
rule.
As
such,
we
are
very
interested
in
seeing
the
Agency
produce
a
sound
facility
database
to
be
used
for
rulemaking.
We
have
attached
a
series
of
comments
on
data
tables
presented
in
the
NODA,
and
are
also
submitting
corrected
copies
of
spreadsheets
containing
data
on
UCC's
four
boilers
subject
to
these
rules.
One
boiler,
No.
53
at
our
Texas
City,
TX
plant,
is
new
and
presently
undergoing
trial
burn
tests.
We
will
be
submitting
a
copy
of
the
draft
trial
burn
report
in
a
separate
mailing.

If
there
are
any
questions
on
these
comments,
please
contact
me
at
504­
783­
4568
or
Mr.
W.
Y.
Wang
at
304­
747­
5279.

Attachments
(6)
Very
truly
yours,

P.
F.
Normand,
P.
E.
Waste
Issue
Manager
Union
Carbide
Corporation
ATTACHMENT
I
RESPONSE
TO
EPA
REQUEST
FOR
COMMENTS
ON
ACCURACY
AND
COMPLETENESS
OF
THE
DATABASE
UCC's
comment
is
mainly
for
deletion
of
two
old
boilers
and
for
inclusion
of
one
new
boiler:

1.
Phase
11
Database
Table
1.
Universe
of
Phase
11
HWC
Sources
(Listed
by
Phase
11
ID
No.):

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler.
This
Boiler
15
is
no
Ionger
in
service
and
has
been
closed.
See
others
below.

UCC
requests
inclusion
in
database
and
a
Phase
II
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).

2.
Phase
11
Database
Table
2.
Universe
of
Phase
11
HWC
Sources
(Listed
by
Facility
Name):

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler.
This
Boiler
15
is
no
longer
in
service
and
has
been
closed.

UCC
requests
inclusion
in
database
and
a
Phase
11
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).

3.
Phase
11
Database
Table
3.
Universe
of
Phase
11
HWC
Sources
(Listed
by
General
Source
Type):

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler
under
"steam
boilers".
This
Boiler
15
is
no
longer
in
service
and
has
been
closed.

UCC
requests
inclusion
in
database
and
a
Phase
11
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).

4.
Phase
li
Database
Table
4.
"SisteC
'(
Data­
in­
Lieu)
Units
(Listed
by
Phase
ll
ID
No.):

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler.
This
Boiler
15
is
no
longer
is
no
longer
in
service
and
has
been
closed.

UCC
requests
inclusion
in
database
and
a
Phase
11
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).
There
is
no
sister
unit
for
Boiler
53.

UCC
requests
deletion
of
Boiler
4
under
Phase
l[
ID
No.
910
boiler.
Boiler
4
is
no
longer
for
hazardous
waste
service.
5.
Phase
11
Database
Table
5.
Phase
11
BIF
Population
Characterization:

UCC
requests
revision
of
Table
5
to
reflect
changes
of
UCC
and/
or
non­
UCC
boiler
data.
6.

Phase
11
Database
Table
6.
Boilers:

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler.
This
Boiler
15
is
no
longer
in
service
and
has
been
closed.

UCC
requests
inclusion
in
database
and
a
Phase
11
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).
This
new
boiler
uses
fuel
gas
as
auxiliary
fuel.

Under
the
Phase
11
ID
908
boiler,
UCC
requests
the
change
of
auxiliary
fuel
from
"Coal
(pulverized)"
to
'Coal
(pulverized)/
Natural
gas".

7.
Phase
11
Database
Data
and
Information
File
for
Individual
Sources
on
Source
Description
Sheet,
Emission
Data
Sheet,
Feed
Stream
Data
Sheet,
Process
Data
Sheet,
PCDD/
PCDF
Sheet,
Emissions
and
Feedrate
Data
Summary
Sheet,
and
Source
Description
Summary
Sheet:

UCC
requests
deletion
of
Phase
11
ID
No.
907
boiler.
This
Boiler
15
is
no
longer
for
hazardous
waste
service.

UCC
requests
deletion
of
Boiler
4
under
Phase
ll
iD
No.
910
boiler.
Boiler
4
was
listed
as
a
sister
unit
for
Boiler
5.
Boiler
4
is
no
longer
for
hazardous
waste
service.

UCC
requests
inclusion
in
database
and
a
Phase
II
ID
No.
for
a
new
watertube
boiler
(Unit
ID
Boiler
53)
at
the
Union
Carbide
Corporation
Texas
City
site
(EPA
ID
No.
TXDOOO461533).
The
complete
COC
and
trial
burn
data
has
just
become
available
in
August
2000.
Data
and
information
file
for
this
new
boiler
is
shown
in
the
attachment
in
the
similar
format
as
those
for
the
other
UCC
boilers.

UCC
requests
minor
revisions
on
the
Phase
II
ID
No.
753,
908,
and
910
boilers,
as
shown
in
the
attached
files.

**
Remaining
attachments
are
copies
of
excel
file
spreadsheets
and
new
trial
burn
emissions
test
report
from
a
new
hazardous
waste
burning
boiler
at
the
Union
Carbide
Texas
City
TX
plant.**

Response
The
new
facility
test
report
for
the
new
facility
just
starting
to
burn
hazardous
waste
has
been
entered
under
a
new
facility
ID
No.
2021.

Unit
ID
No.
907
has
been
reclassified
as
no
longer
burning
waste.
The
sister
unit
Boiler
No.
4
under
ID
No.
920
has
been
removed
(Boiler
No.
4
is
no
longer
burning
hazardous
wastes).

Other
minor
changes
were
made
as
noted
or
discovered
in
the
supplied
revised
attached
files.

5.22
Rohm
and
Haas
(Phase
II
Unit
ID
Nos.
740,
741)

Rohm
and
Haas
(23)

Provided
comments
to
unit
ID
Nos.
740
and
741
on
modified
Excel
spreadsheets
Response
EPA
has
reviewed
the
requested
data
base
edits.
Responses
to
these
requested
changes
or
additions
are
documented
in
Table
3.

5.23
Solutia
(Phase
II
ID
No.
232)

Solutia
Inc.
(L1)

Enclosed
please
find
an
original
plus
two
copies
of
our
comments
on
the
Notice
of
Data
Availability
(NODA)
published
by
EPA
on
6­
27­
2000
in
the
Federal
Register.
Our
principal
comment
is
that
a
portion
of
the
reported
Dioxin/
Furan
stack
emissions
from
our
1997
BIF
Trial
Bum
appear
to
be
incorrectly
reported
in
the
EPA
data
base
and
we
respectfully
request
that
the
EPA
data
base
be
corrected.
The
total
PCDD/
PCDF
Toxic
Equivalent
(TEQ)
values
appear
to
be
correctly
reported,
while
the
total
PCDD/
PCDF
values
appear
to
be
in
error
as
follows:

PCDD/
PCDF
Trial
Bum
PCDD/
PCDF
EPA
BIF
NESHAP
Solutia
1997
Trial
Bum
Test
Condition
Reporting
Basis
Average
Condition
Data
Average
Condition
Data
1
Total
TEQ
ng/
dscm
0.0092
0.0092
@7%
02
1
Total
ng/
dscm
@7%
02
0.0846
0.136
2
Total
TEQ
ng/
dscm
0.0016
0.0016
@7%
02
2
Total
ng/
dscm
@7%
02
1
0.0294
1
0.0350
9­
6­
2000
The
attached
Tables
4­
36,
4­
38,
4­
39,
&
4­
40
are
copies
of
the
Solutia
reported
PCDDIPCDF
Trial
Bum
Results
for
Test
Condition
1.
The
attached
Tables
4­
37,
4­
41,
4­
42,
&
4­
43
are
copies
of
the
Solutia
reported
PCDD/
PCDF
Trial
Bum
Results
for
Test
Condition
2.
If
you
have
any
questions
or
need
any
additional
information,
please
contact
me
at
281­
228­
4762.

Sincerely,

Thomas
M.
Moran,
P.
E.
Senior
Environmental
Specialist
Enclosures:
Solutia
Trial
Bum
Report
Tables:
4­
36,
4­
38,
4­
39,
4­
40,
4­
37,
4­
41,
4­
42,
&
4­
43.

Response
No
changes
are
made.
The
total
PCDD/
PCDF
values
as
reported
and
calculated
by
EPA
in
the
NODA
are
correct
and
based
on
handling
non­
detect
measurements
(those
at
the
detection
limit)
at
one­
half
of
the
detection
limit.
The
total
PCDD/
PCDF
levels
shown
by
Solutia
in
the
comment
above
are
based
on
the
use
of
the
full
detection
limit
(as
opposed
to
the
TEQ
values,
which
are
based
on
use
of
one­
half
of
the
detection
limit
­­
this
is
why
the
commenters
TEQ
values
are
identical
to
the
NODA
values
­­
i.
e.,
both
were
based
on
the
use
of
one­
half
of
the
detection
limit).

5.23
Eastman
L2
(Eastman)

Unit
717
is
no
longer
burning
hazardous
waste.

Response
This
information
has
been
added
to
the
data
base.
Table
1.
List
of
NODA
Data
Base
Commenters
and
Identification
Numbers
Comment
Submittal
Docket
ID
No.
Commenter
Name
Phase
II
ID
No.
Impacted
1
Arch
Chemicals,
Inc.
1008
2
Merck
&
Co.,
Inc.
780,
781
3
Exxon
Chemical
Co.
822
4
Westvaco
818
5
General
Electric
Plastics
Co.
764,
765,
766
6
Eastman
Chemical
Company,
Texas
Operations
854
7
Mallinckrodt,
Inc.
778,
1000
8
DuPont/
Dow
Elastomers
853
9
Merck
&
Co.,
Inc.
780,
781
10
Celanese
Ltd.,
Bay
City
721
(1013,
1014,
1018­
no
comments
received)

11
Eastman
Chemical
Company
(Kingsport,
Tennessee)
717,
719,
1011,
1012
12
Celenese
Ltd.,
Clear
Lake
Plant
720
13
Georgia
Gulf
855,
2000
14
Lyondell
Chemical
1002,
1003,
1004
15
Reilly
Industries
735,
737,
738
16
Ticona
Polymers,
Inc.
1018
17
Rubicon
Inc.
812,
813,
814,
815
18
Equistar
Chemicals,
LP
774
19
Dow
729,
851,
730,
733,
786,
788,
842,
843,
844,
845,
848,
849,
2017,
2018,
2020
20
General
Electric
764,
765,
766
21
DSM
754,
756
22
Union
Carbide
753,
907,
908,
910,
2021
23
Rohm
and
Haas
Company
740,
741
24
American
Chemistry
Council
No
specific
ones
L1
Solutia
232
L2
Eastman
717
O1
Sun
O2
Rhodia
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Nothing
Comments
from
company
only
Received
specific
comments
on
unit
Phase
II
ID
No.
Facility
Name
City
State
EPA
ID
No.
Comb
Type
APCS
y
2006
3V
Inc.
Georgetown
SC
SCD980500052
Firetube
boiler
None
y
2007
Air
Products
Manufacturing
Corp.
Wichita
KS
KSD007237746
Boiler
None
y
763
Albermarle
Corp.
Orangeburg
SC
SCD043384072
Boiler
FF
y
828
Angus
Chemical
Company
Sterlington
LA
LAD020597597
Watertube
boiler
None
y
1008
Arch
Chemicals,
Inc.
(Olin)
Beaumont
TX
TXD008097487
Sulfuric
Acid
Recovery
Furnace
WHB/
QT/
DT/
SO3CON
y
1002
ARCO
Chemical
Co.
(Lyondell)
Channelview
TX
TXD083472266
Boiler
None
y
1003
ARCO
Chemical
Co.
(Lyondell)
Channelview
TX
TXD083472266
Hot
oil
heater
None
y
1004
ARCO
Chemical
Co.
(Lyondell)
Channelview
TX
TXD083472266
Hot
oil
heater
None
y
1017
Aristech
Chemical
Corp.
Pasadena
TX
TXD980808778
Boiler
None
y
911
Aristech
Chemical
Corporation
Haverhill
OH
OHD005108477
Watertube
boiler
None
y
912
Aristech
Chemical
Corporation
Haverhill
OH
OHD005108477
Watertube
boiler
None
y
834
BASF
Geismar
LA
LAD040776809
Combustor/
waste
heat
boiler
None
y
835
BASF
Geismar
LA
LAD040776809
Watertube
boiler
None
y
836
BASF
Geismar
LA
LAD040776809
Watertube
boiler
None
y
833
BASF
Corporation
Freeport
TX
TXD008081697
Boiler
None
y
1016
BASF
Corporation
Beaumont
TX
TXD067261412
?
None
y
840
Bayer
(Monsanto
Co.
Port
Plastic
Plant)
Addyston
OH
OHD004233003
Watertube
boiler
None
y
785
Borden
Chemicals
and
Plastics
(BCP)
Geismar
LA
LAD003913449
Halogen
Acid
Furnace
GC/
HE/
QC/
AT/
WS
y
1013
Celanese
Pampa
TX
TXD007376700
Watertube
boiler
FF
y
1014
Celanese
Pampa
TX
TXD007376700
Watertube
boiler
FF
y
721
Celanese
Ltd
Bay
City
TX
TXD026040709
Watertube
boiler
None
y
1018
Celanese
Ltd
Bishop
TX
TXD008113441
Watertube
boiler
None
y
720
Celanese
Ltd.,
Chemical
Group
Clear
Lake
Plant
Pasadena
TX
TXD078432457
Boiler
None
y
901
Diversified
Scientific
Services,
Inc.
Kingston
TN
TND982109142
Firetube
boiler
SD/
FF/
PBS/
RH/
HEPA
y
733
Dow
Chemical
Co.
Torrance
CA
CAD009547050
Process
heater
None
y
2001
Dow
Chemical
Co.
Plaquemine
LA
LAD008187080
Firetube
boiler
HClABS/
CWS
y
2002
Dow
Chemical
Co.
Plaquemine
LA
LAD008187080
Firetube
boiler
Q/
HClABS/
CWS
y
2003
Dow
Chemical
Co.
Plaquemine
LA
LAD008187080
Firetube
boiler
Q/
HClABS/
CWS
y
730
Dow
Chemical
Co.
Hanging
Rock
Plant
Ironton
OH
OHD039128913
Process
heater
None
y
786
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
DQ/
HCLABS/
VS/
CLW
y
788
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
MGCLREC/
VS/
SEP/
D
y
842
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
HCLABS/
WS
y
843
Dow
Chemical
Company
Freeport
TX
TXD008092793
Watertube
boiler
None
y
844
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
HCLABS/
WS
y
845
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
Q/
HCLABS/
VS/

y
848
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
HClABS/
CWS
y
849
Dow
Chemical
Company
Freeport
TX
TXD008092793
Firetube
boiler
VS/
WS
y
2017
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
Q/
HClABS/
VE/
C
y
2018
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
VS/
Q/
HCLABS/
V
y
2020
Dow
Chemical
Company
Freeport
TX
TXD008092793
Halogen
Acid
Furnace
WHB/
VS/
WS
y
851
The
Dow
Chemical
Company
Pittsburg
CA
CAD076528678
Halogen
Acid
Furnace
Q/
HClABS/
WS
Page
1
of
6
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Nothing
Comments
from
company
only
Received
specific
comments
on
unit
Phase
II
ID
No.
Facility
Name
City
State
EPA
ID
No.
Comb
Type
APCS
y
729
Dow
Chemical
U.
S.
A.
Allyn's
Point
Facility
Gales
Ferry
CT
CTD001159731
Process
heater
None
y
754
DSM
Chemicals
North
America,
Inc..
Augusta
GA
GAD051011609
Boiler
None
y
756
DSM
Copolymer
Inc.
Addis
LA
LAD059130831
Watertube
boiler
None
y
853
Dupont
Dow
Elastomers
LaPlace
LA
LAD001890367
Halogen
Acid
Furnace
WQ/
3STGHClABS/
S/
C
y
2013
E.
I.
Du
Pont
De
Nemours
&
Company,
Inc.
Victoria
TX
TXD008123317
Boiler
?

y
2016
E.
I.
Du
Pont
De
Nemours
&
Company,
Inc.
Victoria
TX
TXD008123317
Boiler
?

y
2012
E.
I.
Du
Pont
Nemours
&
Company,
Inc.
Victoria
TX
TXD008123317
Boiler
?

y
759
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
TXD008123317
Boiler
?

y
760
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
TXD008123317
Boiler
None
y
761
E.
I.
duPont
de
Nemours
&
Co.,
Inc.
Orange
TX
TXD008123317
Boiler
None
y
717
Eastman
Chemical
Company
Kingsport
TN
TND003376928
Watertube
boiler
(suspension
fired)
SDA/
ESP
y
1009
Eastman
Chemicals
Co.
­
Arkansas
Eastman
Div
Batesville
AR
ARD089234884
Watertube
boiler
(stoker)
ESP
y
719
Eastman
Chemicals
Co.
­
Tennessee
Eastman
Div
Kingsport
TN
TND003376928
Watertube
boiler
(spreader
stoker)
ESP
y
1011
Eastman
Chemicals
Co.
­
Tennessee
Eastman
Div
Kingsport
TN
TND003376928
Watertube
boiler
(spreader
stoker)
ESP
y
1012
Eastman
Chemicals
Co.
­
Tennessee
Eastman
Div
Kingsport
TN
TND003376928
Watertube
boiler
(spreader­
stoker)
ESP
y
854
Texas
Eastman
Division
Eastman
Chemical
CompanLongview
TX
TXD007330202
Halogen
Acid
Furnace
QT/
ABS/
WS
y
2014
Environmental
Purification
Industries
Toledo
OH
OHD986983237
Boiler
None
y
2015
Environmental
Purification
Industries
Toledo
OH
OHD986983237
Hot
oil
heater
None
y
774
Equistar
Chemicals,
LP
­
Channelview
Complex
Channelview
TX
TXD058275769
Watertube
boiler
None
y
822
Exxon
Chemical
Co.
(no
longer
burns
haz
waste)
Baton
Rouge
LA
LAD000778381
Boiler
None
y
811
Fina
Oil
&
Chemical
Co.
La
Porte
TX
TXD086981172
Watertube
boiler
VS
y
764
GE
Plastics,
Mt.
Vernon
IN
Facility
Mount
Vernon
IN
IND006376362
Watertube
boiler
None
y
765
GE
Plastics,
Mt.
Vernon
IN
Facility
Mount
Vernon
IN
IND006376362
Watertube
boiler
None
y
766
General
Electric
Plastics
Selkirk
NY
NYD06683023
Hot
oil
heater
None
y
855
Georgia
Gulf
Plaquemine
LA
LAD057117434
Halogen
Acid
Furnace
WHB/
4STGHClABS/
C
y
2000
Georgia
Gulf
Corp.
Plaquemine
LA
LAD057117434
Watertube
boiler
None
y
1015
Georgia
Gulf
Corporation
Pasadena
TX
TXD093565653
Hot
oil
heater
None
y
767
Goodyear
Tire
and
Rubber
Company
Beaumont
TX
TXD008077190
Watertube
boiler
None
y
820
Hercules
Inc.
­
Jefferson
Plant
West
Elizabeth
PA
PAD000606285
Watertube
boiler
None
y
821
Hercules
Inc.
­
Jefferson
Plant
West
Elizabeth
PA
PAD000606285
Watertube
boiler
None
y
1005
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
TXD008076846
Boiler
None
y
1006
Huntsman
Corp.
(formerly
Texaco)
Port
Neches
TX
TXD000201202
Watertube
package
boiler
None
y
1007
Huntsman
Polymers
Odessa
TX
TXD980626014
Boiler
None
y
771
Kalama
Chemical
(BF
Goodrich)
Kalama
WA
WAD092899574
Watertube
boiler
FF
y
772
Lonza,
Inc.
Pasadena
TX
TXD084970169
Boiler
None
y
1001
Lonza,
Inc.
Pasadena
TX
TXD084970169
Boiler
None
y
778
Mallinckrodt
Inc.
Raleigh
NC
NCD042091975
Watertube
boiler
None
y
1000
Mallinckrodt
Inc.
Raleigh
NC
NCD042091975
Watertube
boiler
None
y
780
Merck
&
Co.,
Inc
Rahway
NJ
NJD001317064
Watertube
boiler
None
y
781
Merck
&
Co.,
Inc
Rahway
NJ
NJD001317064
Watertube
boiler
None
y
724
Merichem
Company
Houston
TX
TXD008106999
Boiler
Q/
ME
Page
2
of
6
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Nothing
Comments
from
company
only
Received
specific
comments
on
unit
Phase
II
ID
No.
Facility
Name
City
State
EPA
ID
No.
Comb
Type
APCS
y
776
Monsanto
(Nutrasweet
Kelco
Co.)
Augusta
GA
GAD981237118
Firetube
boiler
QC/
WS
y
777
Monsanto
(Nutrasweet
Kelco
Co.)
Augusta
GA
GAD981237118
Firetube
boiler
QC/
WS
y
735
Reilly
Industries,
Inc.
Indianapolis
IN
IND000807107
Watertube
boiler
None
y
737
Reilly
Industries,
Inc.
Indianapolis
IN
IND000807107
Watertube
boiler
None
y
738
Reilly
Industries,
Inc.
Indianapolis
IN
IND000807107
Watertube
boiler
None
y*
2004
Rhodia
(formerly
Rhone­
Poulenc
Basic
Chemical
CoBaton
Rouge
LA
LAD008161234
Sulfur
Acid
Recovery
Unit
Wet
ESP
y*
2019
Rhodia
(formerly
Rhone­
Poulenc
Basic
Chemical
CoBaton
Rouge
LA
LAD008161234
Sulfur
Acid
Recovery
Unit
WESP
y*
1010
Rhodia
(Rhone­
Poulenc)
Houston
TX
TXD008099079
Sulfuric
Acid
Regeneration
Furnace
WHB/
QT/
CC/
WESP/
D
y*
856
Rhodia
Inc.
Hammond
IN
IND001859032
Sulfuric
Acid
Recovery
Furnace
WHB/
QT/
GC/
WESP/
S
y
819
Rhone­
Poulenc
AG
Company
Charleston
WV
WVD005005509
Watertube
boiler
ESP
y
740
Rohm
and
Haas
Deer
Park
TX
TXD065096273
Watertube
boiler
None
y
739
Rohm
and
Haas
Company
Bristol
PA
PAD002292068
Watertube
boiler
None
y
741
Rohm
and
Haas
Company
Knoxville
TN
KYD006390017
Watertube
boiler
None
y
812
Rubicon,
Inc
Geismar
LA
LAD008213191
Boiler
Q/
WS
y
814
Rubicon,
Inc
Geismar
LA
LAD008213191
Boiler
None
y
815
Rubicon,
Inc
Geismar
LA
LAD008213191
Boiler
None
y
813
Rubicon,
Inc.
Geismar
LA
LAD008213191
Boiler
FF
y
743
Schenectady
International
Freeport
TX
TXD010797389
Boiler
None
y
744
Shell
Deer
Park
Refining
Company
Deer
Park
TX
TXD067285793
Watertube
boiler
None
y
745
Shell
Deer
Park
Refining
Company
Deer
Park
TX
TXD067285793
Watertube
boiler
None
y
232
Solutia
(Chocolate
Bayou
Plant)
Alvin
TX
TXD001700806
Boiler
None
y
746
Sterling
Chemicals,
Inc.
Texas
City
TX
TXD008079527
Firetube
boiler
None
y*
2008
Sun
Company,
Inc.
(R
&
M)
Frankford
Plant
Philadelphia
PA
PAD002312791
Watertube
boiler
None
y
753
Union
Carbide
Corp.
Hahnville
LA
LAD041581422
Watertube
boiler
None
y
907
Union
Carbide
Corporation
South
Charleston
WV
WVD005005483
Watertube
boiler
ESP
y
908
Union
Carbide
Corporation
South
Charleston
WV
WVD005005483
Watertube
boiler
ESP
y
910
Union
Carbide
Corporation
Texas
City
TX
TXD000461533
Watertube
boiler
None
y
769
Velsicol
Chemical
Corp.
Chestertown
MD
MDD001890060
Firetube
boiler
None
y
2009
Velsicol
Chemical
Corp.
Chestertown
MD
MDD001890060
Hot
oil
system
process
heater
None
y
2010
Velsicol
Chemical
Corp.
Chestertown
MD
MDD001890060
Hot
Oil
System
Process
Heater
None
y
2011
Velsicol
Chemical
Corp.
Chestertown
MD
MDD001890060
Hot
Oil
System
Process
Heater
None
y
2005
Vulcan
Materials
Co.
Geismar
LA
LAD092681824
Halogen
Acid
Furnace
WHB/
QT/
WS
y
818
Westvaco
DeRidder
LA
LAD010390599
Watertube
boilers
ESP
Page
3
of
6
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Phase
II
ID
No.
2006
2007
763
828
1008
1002
1003
1004
1017
911
912
834
835
836
833
1016
840
785
1013
1014
721
1018
720
901
733
2001
2002
2003
730
786
788
842
843
844
845
848
849
2017
2018
2020
851
Waste
Type
Aux
Fuel
Unit
ID
Name/
No.
Sister
Units
Capacity
(MMBtu/
hr)

Liq
Natural
gas,
No.
2
fuel
oil
Unit
No.
1
(or
No.
2?)
None
34.0
Liq
Natural
gas
COEN
boiler
None
12.4
Liq
?
Unit
No.
4
None
25.0
Liq
Natural
gas,
hydrogen
No.
7
Boiler
No.
4
Boiler
150.0
Liq
Natural
gas
and
process
gas
Sulfuric
acid
regeneration
furnace
None
200.0
Liq
Natural
gas,
propane
purge
Utility
Boiler
3
Utility
Boilers
1
and
2
?

Liq
Natural
gas
F­
57180
Hot
Oil
Heater
None
138.0
Liq
Natural
gas,
process
vapors
F­
65630
Hot
Oil
Heater
None
138.0
Liq
Natural
gas
Boiler
F­
8
None
100.0
Liq
Natural
gas
or
fuel
oil
Unit
2001­
UA
Units
UB,
UC
(2
other
identical
units)
190.0
Liq
Natural
gas
or
No.
6
fuel
oil
Unit
2001­
UE
None
182.0
Liq
Natural
gas
Amines
None
15.0
Liq
Natural
gas
No.
3
Boiler
None
285.0
Liq
Natural
gas
No.
6
Boiler
None
300.0
Liq
?
Neol
Boiler
None
48.9
Liq
?
WOD
K541
None
12.8
Liq
Natural
gas
Boiler
No.
4
None
48.0
Liq
?
VCR
Process
Unit
None
30.0
Liq
Coal
(pulverized),
still
solids
Boiler
No.
9
None
740.0
Liq
Coal
(pulverized),
still
solids
Boiler
No.
10
None
1000.0
Liq
Natural
gas
Boiler
No.
4
Boiler
No.
5
408.8
Liq
Natural
gas
Boiler
No.
16
None
63.1
Liq
Natural
gas
MH5A
None
50.0
Liq
Propane
DSSI
Mixed
Waste
Industrial
Boiler
System
None
15.0
Liq
Natural
gas
U­
305
U­
304
(identical)
9.8
Liq
Natural
gas
F­
410
F­
420
identical
unit
40.0
Liq
Natural
gas
R­
4
None
45.0
Liq
Natural
gas
R­
750
None
15.0
Liq
Natural
gas
Unit
R­
1
Unit
R­
3
identical
unit
9.0
Liq
Natural
gas
Unit
R­
30
None
31.0
Liq
Natural
gas
B­
824
None
88.0
Liq
Natural
gas
Unit
FTB­
400
None
28.0
Liq
Natural
gas
B­
902
B­
901,
B­
903
229.0
Liq
Natural
gas
F­
2AB
None
35.0
Liq
Natural
gas
F­
210
None
50.2
Liq
Natural
gas
F­
11
None
24.0
Liq
Natural
gas
F­
820AB
None
32.0
Liq
Natural
gas
Unit
FTB­
401
Unit
FTB­
402
42.0
Liq
Natural
gas
Unit
FTB­
603
None
50.2
Liq
Natural
gas
F­
2820
None
40.0
Liq
Natural
gas
MS
HAF
None
5.
2
Page
4
of
6
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Phase
II
ID
No.
729
754
756
853
2013
2016
2012
759
760
761
717
1009
719
1011
1012
854
2014
2015
774
822
811
764
765
766
855
2000
1015
767
820
821
1005
1006
1007
771
772
1001
778
1000
780
781
724
Waste
Type
Aux
Fuel
Unit
ID
Name/
No.
Sister
Units
Capacity
(MMBtu/
hr)

Liq
and
solid
No.
2
fuel
oil
Boiler
Unit
A
None
9.
0
Liq
Natural
gas
H­
002
Boiler
H­
2002
Boiler
162.0
Liq
Natural
gas
No.
3
boiler
None
268.0
Liq
Natural
gas
HCl
Recovery
Unit
None
48.0
Liq
?
Boiler
Nos.
3
&
4
None
1000.0
Liq
?
Boiler
No.
1
None
400.0
Liq
Natural
gas
Boiler
No.
7
Boiler
No.
8
250.0
Liq
Natural
gas
Boiler
No.
7
Boiler
No.
5
300.0
Liq
Natural
gas
Boiler
No.
8
None
350.0
Liq
Natural
gas
ADN
North
ADN
South
600.0
Liq
Coal
(pulverized)
Unit
No.
30
(HWTU­
5,
at
Site
B­
325)
None
780.0
Liq
Coal
Boiler
No.
3
Boiler
No.
2
100.0
Liq,
sludge
Coal
Boiler
No.
24
Boiler
No.
23
501.0
Liq,
sludge
Coal
Boiler
No.
20
Boiler
Nos.
18
and
19
196.0
Liq
Coal,
biosludge
Boiler
No.
22
Boiler
No.
21
216.0
Liq
Natural
gas
RCRA
BIF
Unit
(Halogen
Acid
Furnace)
None
30.0
Vapors
Natural
gas
WHB
Unit
No.
1
None
8.
0
Vapor
Natural
gas
WHB
Unit
No.
2
None
8.
0
Liq
Natural
gas
Boiler
No.
3
None
83.6
Liq
Natural
gas
C­
Boiler
D­
Boiler
identical
50.0
Liq
Natural
gas
Train
A
Waste
Heat
Boiler
Train
B
Waste
Heat
Boiler
70.0
Liq
Natural
gas
Boiler
H530A
(Unit
1)
None
75.0
Liq
Natural
gas
Boiler
H530B
(Unit
2)
None
75.0
Liq
Natural
gas
A/
P
Hot
Oil
Heater
None
180.0
Liq
Natural
gas
IN­
662
None
70.0
Liq,
tar
Natural
gas,
fuel
oil
Nebraska
Boiler
None
190.0
?
Natural
gas
Hot
Oil
Heater
No.
1
None
250.0
Liq
Natural
gas
Boiler
B­
103
Boilers
B­
101,
B­
102,
B­
104,
B­
105
(a
100.0
Liq
Fuel
oil
Boiler
No.
3
Boiler
No.
4
30.0
Liq
Fuel
oil
Boiler
No.
5
None
40.0
Liq
Fuel
gas,
sponge
oil
Boiler
#
1
(6­
BB­
1)
Boiler
#
2
(6­
BB­
2)
549.0
Liq
Natural
gas
and
process
vapors
PO/
MTBE
steam
generator
#
1
(H­
K2­
001)
Unit
#
2
(H­
K2­
002)
­
identical
225.0
Liq
Natural
gas
C­
Boiler
None
300.0
Liq
Natural
gas
U­
3
Boiler
None
50.0
Liq
Natural
gas
Boiler
B­
4001B
B­
4001A
­­
identical
unit
39.0
Liq
Natural
gas
Boiler
B­
4001C
None
39.0
Liq
Natural
gas
Boiler
No.
1
None
19.0
Liq
Natural
gas
Boiler
No.
2
None
30.0
Liq
Natural
gas
Boiler
No.
7
None
134.0
Liq
Natural
gas
Boiler
No.
8
None
156.0
Liq
Natural
gas
Boiler
No.
4
None
68.0
Page
5
of
6
Table
2.
Universe
of
Phase
II
Sources
and
Status
of
Comments
Received
Phase
II
ID
No.
776
777
735
737
738
2004
2019
1010
856
819
740
739
741
812
814
815
813
743
744
745
232
746
2008
753
907
908
910
769
2009
2010
2011
2005
818
Waste
Type
Aux
Fuel
Unit
ID
Name/
No.
Sister
Units
Capacity
(MMBtu/
hr)

Liq
Natural
gas
Boiler
1
­
WHRU
1
None
66.0
Liq
Natural
gas
Boiler
2
­
WHRU
2
None
26.0
Liq
Natural
gas
Boiler
70K
None
92.0
Liq
Natural
gas
30K
None
39.3
Liq
Natural
gas
Boiler
28K
None
36.8
Liq
Natural
gas
Unit
1
None
140.0
Liq
Natural
gas
Unit
2
?
250.0
Liq,
sludge
Natural
gas
Regeneration
Unit
No.
2
None
200.0
Liq
Natural
gas
Sulfuric
Acid
Recovery
Unit
No.
4
None
250.0
Liq
Natural
gas
Boiler
No.
3
Boiler
No.
4
1131.2
Liq
Natural
and
process
gas
HT­
1
Thermal
Oxidizer
None
335.0
Liq
No.
6
fuel
oil,
natural
gas
Boiler
No.
7
Boiler
Nos.
6
and
8
120.0
Liq
Natural
gas,
No.
2
fuel
oil
Unit
No.
100
None
248.0
Liq
Natural
gas
TDI
boiler
None
30.0
Liq
Natural
gas
DPA
I
Superheater
None
20.0
Liq
Natural
gas
DPA
II
superheater
None
20.0
Liq
None
Aniline
II
boiler
None
40.0
?
Natural
Gas
B­
503
None
30.0
Liq
Natural
gas
F­
UT­
100
F­
UT­
110
600.0
Liq
Natural
gas
F­
UT­
130
None
600.0
Liq
Natural
gas;
vent
gas
(propane)
Boiler
30H5
Boiler
31H4
(identical)
600.0
Liq
Natural
gas
and
process
gas
Waste
Oxidation
Boiler
A
None
180.0
Liq
Natural
gas
Boiler
No.
2
Boiler
No.
1
(Phase
II
ID
No.
900)
200.0
Liq
Gas/
oil
Boiler
31
None
241.0
Liq
Coal
(pulverized)
Boiler
15
None
204.0
Liq
Coal
(pulverized)
Boiler
25
None
323.0
Liq
Fuel
gas
Boiler
5
Boiler
4
(identical)
200.0
Liq
No.
6
fuel
oil
Unit
No.
4
(Cleaver
Brooks
Boiler)
None
Liq
No.
6
fuel
oil
Hot
Oil
System
Unit
No.
1
None
10.0
Liq
No.
6
fuel
oil
Hot
Oil
System
Unit
No.
2
None
14.0
Liq
No.
6
fuel
oil
Hot
Oil
System
Unit
No.
3
None
14.0
Liq
?
F­
1
Unit
None
20.0
Liq,
residues
Tall
oil
pitch
and
heads
fuel,
fuel
Boilers
No.
2
and
3
(common
ESP
and
stack)
None
86.0
Page
6
of
6
Table
3.
Responses
to
Requests
for
Data
Base
Changes
Comment
ID
No.
Phase
II
ID
No.
Commentators
Requested
Action
NODA
Data
Base
Value
Action
Taken
1
1008
Supplemental
fuel
=
natural
gas.
No
process
gas
fired.
Supplemental
fuel
=
natural
gas
and
process
gas
Modified
as
requested
1
1008C1
Total
spike
feed
rate
=
305
lb/
hr
226.4
lb/
hr
Verified
that
data
base
value
was
incorrect;
recalculated
at
298.9
lb/
hr;

used
commenters
value.

1
1008C1
Additional
feed
stream
data
provided:
Sulfur
firing
rate
=
45.
7
MMBtu/
hr.
Estimated
firing
rate
=
145
MMBtu/
hr
No
data
for
sulfur
firing
rate.

Estimated
total
firing
rate
=
187.1
MM
Btu/
hour
Added
as
requested
1
1008
New
and
more
BIF
Tier
I
and
Tier
III
feedrate
limits
BIF
feed
rate
limits:
Tier
I:
Ba
=

284,407
g/
hr,
Ag
=
17,055
g/
hr;
No
feed
limits
available
for
the
Tier
III
metals
Added
and
modified
as
requested
2
780
Additional
Stack
Characteristics
provided:

Diameter
=
10
ft,
Height
=
235
ft
,
Gas
Velocity
=
5.
8
ft/
sec.
Added
data
2
781
Additional
Stack
Characteristics
provided:

Diameter
=
10
ft,
Height
=
235
ft,
Gas
Velocity
=
5.8
ft/
sec.
Added
data
2
781C2
Testing
Dates
=
October
18­
19,
1999
October
19­
20,
1999
Modified
as
requested
3
822
No
longer
burning
hazardous
waste
as
of
May
17,
1999
Currently
burning
hazardous
waste
Marked
as
no
longer
burning
hazardous
waste
4
818
Capacity
=
65
MMBtu/
hr
is
the
boiler
design
rating.
Capacity
=
86
MM
Btu/
hr
Heat
input
from
test
data
Capacity
defined
as
max
heat
input;

no
change.

4
818
Soot
blowing
is
used.
Modified
as
requested
4
818
Stack
Characteristics:
Stack
diameter
=
8
ft,

Stack
height
=
250
ft.
Data
added
4
818
Haz.
waste
description
=
Flammable
liquid
(waste
code
D001)
Haz.
waste
description
=
Resinate
filer
cake,
HC920/
spage
oil,
acrylic
process
spent
organics
and
overheads
Modified
as
requested
4
818C10
Report
Content
=
volatiles,
semi­
vol,
TOC.
Report
Content
=
Non
D/
F
organics
(no
PM,
chlorine,
metals,
etc.)
Modified
as
requested
4
818C10
BIF
feed
rate
limit
for
Cl
=
21,000
BIF
feed
rate
limit
for
Cl
=
29,000
Modified
as
requested
4
818C11
Report
Details:
Report
name
=
Recertification
Test
Report,
Testing
Dates=
June
29­
30,1995,

Technical
scope
and
measurements
=
D/
F,

Report
preparer
=
Westvaco,
Testing
firm
=

Emission
Testing
Services,
Inc
Report
Details:
Report
name
=
1998
Risk
Burn
Report,
Testing
Dates
=

June/
July
1995,
Technical
scope
and
measurements
=
D/
F,
PM,
Report
preparer
=
?,
Testing
firm
=
?
Modified
as
requested
4
818C11
COC
stack
test
conditions:
Gas
flowrate
=74,852
dscfm,
CO
=
1.5
ppmv
O2
=
13.1
%
,
Moisture
=
5.24
%
,

Temperature
=
357
o
F
Not
available
Data
added
4
818C11
Provided
actual
gas
sample
volumes
and
oxygen
levels
for
PCDD/
PCDF
sampling
train
Estimated
values
based
on
best
available
information
Updated
using
correct
info
as
provided
by
commenter
4
818C12
Report
Details:
Technical
scope
and
measurements
=
D/
F,
PM
;
Report
preparer
=

Walk,
Haydel
&
Associates,
Testing
firm
=

TRC
Environmental
Corp.
Not
available
Data
added
4
818C13
New
Condition;
Recertification
of
Compliance
Test
Report;
Testing
Dates
=
June
24­
26,

1998;
Contents
=
Feed,
Stack
gas
parameters,

and
D/
F
data
Report
submitted
with
comment,

contained
new
condition,
added
new
data
4
818C14
New
Condition;
Air
Quality
Compliance
Test;

Testing
Date
=
July
5,
1995;
Contents
=
PM,

CO,
THC,
and
Stack
gas
parameters.
New
Condition,
added
new
data
5
764C1
765C1
766C1
Test
conditions
are
under
"normal"
conditions
Conditions
identified
as
being
conducted
under
maximum
waste
and
ash
feed
levels
No
change
made.
CoC
testing
not
done
under
"normal"
conditions.
5
764C1
765C1
More
recent
updated
BIF
feed
rate
limits
provided
Old
feedrate
limits
shown.
Modified
as
requested
5
764
765
Stack
Characteristics:
Temperature
=
529
o
F,

Diameter
=
5
ft,
Velocity
=
63.
7
ft/
s.
Also
note,

boilers
have
a
common
stack
Data
added
5
764
765
Should
add
"Adjusted"
Tier
I
for
all
metals,

chlorine
Tier
I
for
all
metals,
chlorine
Modified
as
requested
5
764C1R3
Sootblowing
corrected
PM
emissions
=
0.0398
gr/
dscf
Uncorrected
PM
emissions
level
shown
=
0.0662
gr/
dscf
No
change.
Sootblowing
corrected
test
condition
average
shown
correctly.

5
764C1
Liquid
waste
thermal
feedrate
=
70.7
MM
Btu/
hr
Feedrate
=
74
MM
Btu/
hr
Modified
as
requested
5
764C1
Ash
feedrate
=
6.126
lb/
hr
Feedrate
=
5.99
lb/
hr
Modified
as
requested,
although
insignificant
difference
5
764C1
Stack
gas
conditions
should
be:
Gas
flowrate=
18,657
dscfm;
O2
=
8.1%
Stack
gas
conditions
estimated
based
on
total
thermal
feedrate
using
standard
F­
factor
approach
and
typical
estimated
oxygen
level.
Gas
flowrate
=
17,037.2
dscfm;
O2
=
7%
Modified
as
requested
5
765C1R3
Sootblowing
corrected
PM
emissions
=
0.0411
gr/
dscf
Uncorrected
PM
emissions
shown
=

0.0808
gr/
dscf
No
change.
Sootblowing
corrected
test
condition
average
shown
correctly.

5
765C1
Liquid
waste
thermal
feedrate
=
72
MM
Btu/
hr,
Ash
feedrate
=
5.626
lb/
hr
Liquid
waste
thermal
feedrate
=
72.
8
MM
Btu/
hr,
Ash
Feedrate
=
5.
6
lb/
hr
Modified
as
requested,
although
insignificant
differences
5
765C1
Stack
gas
conditions
should
be:
gas
flowrate=
17,518.7
dscfm;
O2
=
5.5
%
Stack
gas
conditions
estimated
based
on
total
thermal
feedrate
and
typical
estimated
oxygen
level
using
standard
F­
factor
approach;
Gas
flowrate
=

16,475.3
dscfm;
O2
=
7%
Modified
as
requested
5
766
EPA
ID
#
NYD066832023
EPA
ID
#
NYD06683023
Modified
as
requested
5
766
Soot
blowing
is
used.
Wasn't
used
during
compliance
testing,
but
is
used
under
normal
operations.
Sootblowing
status
identified
as
"None"
based
on
that
used
in
compliance
testing.
Modified
as
requested.
Note
that
sootblowing
must
be
used
during
compliance
testing
if
used
during
normal
operations.

5
766
Natural
gas
is
primary
boiler
fuel.
Permitted
to
burn
either
#2
or
6
as
auxiliary
Natural
gas
identified
as
supplemental/
auxiliary
fuel
Added
that
fuel
oil
No.
2
and
No.
6
may
also
be
used
as
non­
waste
fuels.

6
854
Source
Descriptions
should
be
modified:

Facility
name
=
Eastman
Chemical
Company,

Texas
Operations;
Haz.
waste
description
=

Liquid
hazardous
waste;
Additional
stack
parameters
provided:
Stack
height
=
63
ft,
Gas
temp
=
187F,
Velocity
=
44.1
ft/
s;
Permitting
Status
=
Adjusted
BIF
Tier
I.
Facility
name
=
Texas
Eastman
Division;
Haz.
waste
description
=

By­
product
liquid
feed;
Gas
temp
=

190F,
Velocity
=
45
ft/
s;
Permitting
Status
=
BIF
Tier
I
for
all
metals
Information
added
or
modified
as
requested
6
854C1
Several
Feedstream
inputs
should
be
modified
slightly:
Liq
waste
heat
content
=
1150
Btu/
lb;

vent
gas
heat
content
=
92.
3
Btu/
dscf;
Chlorine
in
Liq
waste
=
813
lb/
hr;
Chlorine
in
Vent
gas
=
29.
2
lb/
hr;
POHC
Chlorine
spike
=
4.
7
lb/
hr
Liq
waste
heat
content
=
1200
Btu/
lb;

vent
gas
heat
content
=
100
Btu/
dscf;

Chlorine
in
Liq
waste
=
815
lb/
hr;

Chlorine
in
Vent
gas
=
28
lb/
hr;
POHC
Chlorine
spike
=
4.
6
lb/
hr
Modified
as
requested,
although
insignificant
differences
6
854C1
Dioxins
and
furan
catches
should
correct
for
field
blanks.
Data
base
included
uncorrected
dioxins
and
furan
catches.
Convention
is
to
report
uncorrected
dioxins
and
furan
catches
(not
corrected
for
field
blank).

6
854C2
Sampling
Train
1
­
HCl/
Cl2,
Run
1
and
Run
2.

Switch
stack
gas
flowrate,
O2,
moisture
and
temperature.
Switched
as
requested
6
854C2
Several
Feedstream
inputs
should
be
modified
slightly:
Liq
waste
Firing
Rate
=
9.
3
MMBtu/
hr;
Liq
waste
Heating
Value
=
2144
Btu/
lb.
Liq
waste
Firing
Rate
=
9.4
MMBtu/
hr
;
Liq
waste
Heating
Value
=
2167
Btu/
lb.
Modified
as
requested
7
778
Source
Descriptions
should
be:
Combustor
Characteristics
=
John
Zink
LoNOx
burner
;

Supplemental
Fuel
add,
during
start­
up
and
shutdown;
Capacity
(MMBtu/
hr)
=
18.6;

Permitting
Status
=
Adjusted
Tier
1
for
all
BIF
metals
and
chlorine/
chlorides;
Recertification
of
Compliance
Test
=
8/
27/
98.
Source
Descriptions
read:
Combustor
Characteristics
=
John
Zinc
LoNOx
burner;
Supplemental
Fuel
=
Natural
gas
(start
up
only);
Capacity
(MMBtu/
hr)
=
19
;
Permitting
Status
=

Tier
I
metals,
chlorine
(IA
for
Cr);

Recertification
of
Compliance
Test
Report
=
9/
27/
98
Modified
as
requested
7
778C10
Calculations
of
the
Cr
+6
should
equal:
7.81,

7.12,
and
5.02
ug/
dscm
@
7%
O2
for
runs
2,
3,

and
3(
soot
correction)
respectfully.
Cr
+6
values:
7.4,
6.8
ug/
dscm
@
7%
O2
for
runs
2,
and
3
(soot
correction).
Cr
+6
recalculated:
7.82,
7.12,
and
5.08
ug/
dscm
@
7%
O2
for
runs
2,
3,

and
3(
soot
correction).

7
778C10
K083
liquid
waste
feed
rates
should
be
modified:
Chlorine
50.7
(g/
hr)
Mercury
<
0.03
(g/
hr)
Lead
<
0.2
(g/
hr)
Cadmium
<
0.2
(g/
hr)

Arsenic
<
0.
2
(g/
hr)
Beryllium
<
0.
2
(g/
hr).
K083
liquid
waste
feed
rates
reported
as:
Chlorine
50.
9
(g/
hr)
Mercury
<

0.02
(g/
hr)
Lead
<
0.1
(g/
hr)
Cadmium
<
0.1
(g/
hr)
Arsenic
<
0.1
(g/
hr)

Beryllium
<
0.
1
(g/
hr).
Modified
as
requested,
although
insignificant
differences
7
1000
Source
Descriptions
should
be:
Combustor
Characteristics
=
John
Zink
LoNOx
burner
;

Capacity
(MMBtu/
hr)
=
30.
3;
Permitting
Status
=
Adjusted
Tier
1
for
all
BIF
metals
and
chlorine/
chlorides;
Content
of
Condition
1
included
Cr+
6
emissions
tests.
Source
Descriptions
read:
Combustor
Characteristics
=
John
Zinc
LoNOx
burner;
Capacity
(MMBtu/
hr)
=
30
;

Permitting
Status
=
Tier
I
metals,

chlorine
(IA
for
Cr).
Modified
as
requested
7
1000C1
CO
MHRA
should
be
modified
to:
Runs
3,
5,

and
6
are
3.8
ppmv,
9.9
ppmv,
and
9.8
ppmv,

respectively
CO
MHRA
reported
as:
7.1,
3.9,
3.8
ppmv
Modified
as
requested
7
1000C1
Stack
gas
flow
rates
should
be
modified
to:

4100
dscfm,
4200
dscfm,
and
4400
dscfm
Stack
gas
flow
rates
reported
as:
4000,

4300,
4100
dscfm
Modified
as
requested,
although
differences
are
insignificant
7
1000C1
Ash
and
Chlorine
liquid
waste
feed
rates
should
be
modified:
95.62
and
10.5
g/
hr
Ash
and
Chlorine
feed
rates
reported
as:
95.7
g/
hr,
10.6
g/
hr
Modified
as
requested,
although
differences
are
insignificant
7
1000C1
Stack
gas
conditions
from
Cr+
6
sampling
train
omitted.
Data
added
8
853
New
trial
burn
and
supplemental
trial
burn
Added
new
data
(2
new
test
conditions,
853C11,
853C12)
8
853
APCS
characteristics
­­
3
stage
HCl
and
vent
scrubbers
use
water,
Dynawave
scrubber
uses
caustic
Added
as
requested
8
853
Supplemental
fuel
­­
natural
gas
used
only
during
startup,
shutdown;
not
during
normal
operations
Added
as
requested
8
853
Stack
diameter
at
top
is
1.5
ft
3
ft
stack
diameter
Changed
as
requested
8
853
Permitting
status
­­
Tier
I
adjusted
for
all
metals
except
Cr,
Tier
III
for
Cr
and
Cl
Added
as
requested
8
853C10
Total
waste
feedrate
=
4331
lb/
hr
Feedrate
estimated
at
3886
lb/
hr
based
on
measured
stack
gas
flowrate.
Not
available
in
test
report.
Changed
as
requested
8
853C10
Firing
rate
=
48.2
MMBtu/
hr
Estimated
firing
rate
at
43.3
MMBtu/
hr
based
on
measured
stack
gas
flowrate.
Changed
as
requested
8
853C10
Viscosity
=
<
6
cps
Viscosity
=
6
cps
Added
as
requested
8
853C10
Process
information
included
in
attachments
Information
provided
was
not
relevant
for
database
8
853C10
No
spiking;
all
"other"
and
"spike"
%'s
should
be
zero
Values
left
blank
No
change.
A
blank
value
indicates
that
no
spiking
took
place.
Also,
a
blank
value
in
the
"other"
column
indicates
no
contribution
from
the
"other"
streams.

9
780
Source
Descriptions
should
be
modified:

Permitting
Status
=
under
interim
status;
Soot
blowing
=
one
10
min.
soot
blowing
cycle
(Condition
1
run
3).
Permitting
Status
=
Tier
I
metals
and
chlorine;
Soot
blowing
=
one
soot
blowing
cycle
(10
min.)
(Cond
2
run
3).
Modified
as
requested
9
780C1
Several
flowrates/
feed
rates
should
be
modified:
gas
flowrate
run
3,
27555
dscfm,

liquid
solvent
feedrate
1191.9
kg/
hr,
ash
feedrate
1236
g/
hr,
chlorine
feedrate
596
g/
hr.
Flowrates/
feed
rates
read:
gas
flowrate
27550
dscfm,
liquid
solvent
feedrate
1195.5
kg/
hr,
ash
feedrate
1300
g/
hr,

chlorine
feedrate
595
g/
hr.
Modified
as
requested,
although
differences
are
insignificant
9
780C2
Several
feed
rates
should
be
modified:
liquid
solvent
feedrate
231.6
kg/
hr,
thermal
feedrate
4.3
MMBtu/
hr.
Feed
rates
read:
Liquid
solvent
feedrate
234
kg/
hr,
thermal
feedrate
4.5
MMBtu/
hr.
Modified
as
requested.
Dependant
cell,
total
thermal
feedrate,
also
commented
on.

9
781
Source
Description
should
be
modified:

Permitting
Status
=
under
interim
status.
Permitting
Status
=
Tier
I
metals
and
chlorine.
Modified
as
requested.

9
781C1
Several
flowrates/
feed
rates
should
be
modified:
run
1,
gas
flowrate
27383
dscfm,

liquid
solvent
feedrate
1181.3
kg/
hr,
thermal
feedrate
21.7
MMBtu/
hr,
ash
feedrate
1732
g/
hr,
chlorine
feedrate
591
g/
hr,
lead
feedrate
0.118
g/
hr.
Flowrates/
feed
rates
read:
Gas
flowrate
273383
dscfm,
liquid
solvent
feedrate
1185.5
kg/
hr,
thermal
feedrate
21
MMBtu/
hr,
ash
feedrate
1790
g/
hr,

chlorine
feedrate
586
g/
hr,
lead
feedrate
0.13
g/
hr.
Modified
as
requested,
although
differences
are
insignificant
10
721
Source
Description
should
be
modified:

combustor
rating
=
350,000
lb/
hr­
steam,

additional
combustor
characteristics
provided;

Soot
blowing
discontinued;
Additional
haz.

waste
description
info;
Stack
characteristics:

height
50.
5
ft,
velocity
28
ft/
sec;
Permitting
status
adjusted
Combustor
rating
=
35,000
lb/
hr­
steam;

Permitting
status
=
Tier
I
for
metals
and
chlorine.
Information
added
or
modified
as
requested
10
721C10
Should
not
the
Mercury
(Hg)
Total
reflect
the
fact
that
BOTH
feeds
had
"nd"
and
mark
"nd"

as
well?
Emissions
and
feedrate
data
summary
sheet
provides
relative
amount
of
the
feedrate
derived
from
non­
detects
10
721C10
Condition
description
should
read
"Risk
burn;

typical
feedrate."
Risk
burn;
max
feed
rate
Modified
as
requested
10
720
Stack
Characteristics
and
several
firing
rates
provided:
Height
=
133
ft;
5.1
MMBtu/
hr
liquid
waste
methanol,
3.
3
MMBtu/
hr
vent
gas,

27.
0
MMBtu/
hr
natural
gas,
Total
firing
rate
of
35.4
MMBtu/
hour,
Design
firing
rate
of
MH5A
is
~68
MMBtu/
hr.
Information
added
or
modified
as
requested
13
855
Change
facility
name
to
Georgia
Gulf
Chemicals
and
Vinyls,
LLC
Georgia
Gulf
Changed
as
requested
13
855
Change
Haz
Waste
Description
to
Liquid
wastes
­
Heavy
ends
from
the
distillation
of
ethylene
dichloride
in
ethylene
dichloride
production
(K019)
Liquid
wastes
­
vinyl
chloride
monomer
light
ends
(K022,
K019)
Changed
as
requested
13
855
The
stack
gas
temperature
is
104.39F
Added
13
855
The
stack
gas
velocity
is
59
ft/
s
Added
13
855
The
unit's
classification
has
been
changed
from
incinerator
to
HAF
Classified
as
a
HAF,
although
noted
that
permitted
as
an
incinerator;

expected
to
be
renewed
as
a
HAF
Updated
13
855
Report
preparer
is
Environmental
Science
&

Engineering,
Inc.
Added
13
855
Change
the
condition
description
number
12
to
be
the
same
as
number
13
Trial
burn
­
Heavy
liquid
waste
feed
Changed
as
requested
13
855
Request
to
calculate
various
condition
averages
Do
not
calculate
condition
averages
here
No
change
13
855
Changes
to
POHC
feedrate
and
DREs
No
changes.
No
signficant
differences.

13
855
Change
the
feedrate
for
Cr
(mg/
L)
is
0.
9
The
feedrate
for
Cr
is
1
mg/
L
No
significant
difference,
although
changed
as
requested
13
855C12,
C13
Change
the
gas
flowrate
of
C12
and
C13
to
the
average
of
runs
1­
6
Gas
flowrate
is
average
of
runs
4­
6
Separate
the
avg
gas
flow
rate
of
C12
and
C13
into
two
cond.
The
gas
flowrate
of
C12
(run
1­
3)
is
11316.9
dscfm.
The
gas
flowrate
of
cond.
13
(run
4­
6)
is
9951
dscfm
13
855C12,
C13
Also
change
waste
feedrate,
O2,
steam
production,
natural
gas
feed,
boiler
exit
temp.,

liquor
pH,
water
feed,
liquor
feed
of
C12
and
C13
to
average
of
runs
1­
6
Levels
shown
as
average
of
runs
4­
6
Separate
into
two
individual
conditions
as
noted
above.

13
2000
Change
facility
name
to
Georgia
Gulf
Chemicals
and
Vinyls,
LLC
Georgia
Gulf
Changed
as
requested
13
2000
Change
the
waste
description
to
Liquid
wastes
­
Distillation
bottom
tars
from
the
production
of
phenol/
acetone
from
cumene
(K022)
Liquid
wastes
­
Methanol
and
acetone/
phenols
production
byproducts
(K022),
distillation
tars/
oil
VCM.
Changed
as
requested
13
2000
Change
the
stack
characteristics:
Diameter
(6.7
ft),
Height
(100
ft),
Gas
velocity
(50
ft/
sec),

and
Gas
temperature
(460F)
Diameter
(4.75
ft),
Height
(42
ft),
Gas
Velocity
(35.
6
ft/
sec)
and
Gas
temperature
(475.7
oF)
Changed
as
requested
13
2000
Misspelled
acetophenone
acetephenone
Changed
as
requested
13
2000
Request
calculation
of
condition.
averages
No
change.
Unnecessary
to
calculate
13
2000C2
Change
the
gas
flowrate
of
C2,
sampling
train
1
(PM).
Run
1
is
26895.1
dscfm,
run
2
is
29069.7
dscfm,
run
3
is
26223.1
dscfm
Flowrate
of
26524
dscfm
was
estimated
Changed
as
requested
13
2000
Remove
the
MTEC
calculation
for
Cr+
6
stack
gas
emissions.
Move
to
feedrate
section.
Converted
a
mass
emissions
rate
to
a
stack
gas
concentration.
No
change.
A
conversion
from
a
mass
rate
(g/
hr)
to
a
stack
gas
concentration
is
standard
procedure.

13
2000C1
Change
viscosity
to
1073
cSt
Viscosity
is
1787.7
cSt
Changed
as
requested
13
2000C1
Request
various
changes
to
feedrates
No
changes
made.
They
do
not
make
a
significant
difference.

13
2000
Request
adding
the
estimated
firing
rate
for
Mixed
Oil
Not
calculated
No
change.
Only
calculate
the
Estimated
Firing
Feedrate
for
total
feedrates
based
on
stack
gas
flowrate
and
O2,
not
per
individual
feedstream.

13
2000
Chlorine
MTEC
calculation
references
the
wrong
cell
Changed
as
requested
13
2000
Requests
minor
changes
for
the
values
and
units
of
Be,
acetophenone
and
Viscosity
Changed
as
requested
13
2000
Change
OCDF
in
run
2
to
0.29
OCDF
=
0.00029
Changed
as
requested
13
2000
Inconsistent
procedure
for
reporting
the
Heat
Input
Rate
(MM
Btu/
hr)
in
summary
sheet.
For
2000C1
and
2000C2,
based
on
waste
feedrate
and
heating
value.

For
2000C3,
2000C4,
based
on
F

factor
estimation.
As
clearly
discussed
in
the
database
report,
we
use
the
one
that
is
considered
as
most
representative
after
calculation
both
on
an
estimated
basis
using
an
F­
factor
approach
for
the
total
heat
input,
and
based
on
reported
feedrate
input
rates
and
heating
values.

13
2000
Inconsistent
procedure
for
handling
data
at
the
detection
limit.
Using
half
detection
limit
values
for
SVM,
LVM
calculations
and
in
summary
sheet.
Everywhere
else
report
full
detection
limits.
See
the
database
report
for
procedures
for
handling
the
non
detects.

13
2000
Should
use
the
average
of
multiple
simultaneous
sampling
trains
in
summary
sheet.
Using
values
from
only
one
sampling
train.
No
change.
Have
chosen
to
represent
the
test
condition
by
the
sampling
train
that
was
run
over
the
longest
time
duration,
as
discussed
in
the
database
report.

14
1002,
1003,
1004
Add
new,
more
recent,
CoC
test
conditions
which
were
provided
Added
2
new
CoC
test
conditions
for
each
facility
14
1002,
1003,
1004
Facility
operator
name
has
changed
from
Arco
Chem
to
Lyondell
Chemical
Arco
Chemical
Made
change
15
735
Capacity
=
92
MM
Btu/
hr
Capacity
=
91.8
MM
Btu/
hr
No
change
made;
insignificant
difference.

15
735
Sootblowing
­­
Yes;
4
times/
day;
5
minutes/
event
Sootblowing
yes;
4
times/
day
Added
15
735
Stack
gas
temp
=
615F,
velocity
=
44.7
ft/
sec
Added
15
Add
risk
modeling
information
such
as
dilution
factor,
land
use,
etc.
Not
added
to
database
at
this
time.

Will
condsider
later
when
proceeding
on
risk
assessment
15
Expand
permitting
status
to
include
PM,
DRE,

CO,
waste
feed
limits,
etc.
Not
necessary.

15
735C1,
C2
and
737
C1
and
C2
Remove
old
data
(735
and
737
C1
and
C2
for
1996
CoC)
that
is
not
most
recent
testing
Older
data
included
in
database
At
this
point,
old
data
will
be
kept
in
the
database.
It
will
likely
not
be
used
for
any
MACT
setting
purposes.

15
735
Remove
"s"
from
Boilers
in
Report
Name/
Date
Changed
15
735C3
Testing
dates
from
Oct
21­
23
Testing
data
from
Oct
21­
22
and
Nov
22
Changed
15
735C3
Cr+
6
testing
done
during
earlier
mini
burn
Cr+
6
testing
part
of
C3
Moved
15
735C6
Add
new
data
from
mini
burn
Added
new
test
condition
15
735C7
Add
new
data
from
trial
burn
retest,
which
includes
DRE
for
dichlorobenzene
Added
new
test
condition
15
735C3R3
Cl2
stack
gas
emissions
is
"nd"
Added
15
735C3,
C5,
737C3,
C4
Supplied
gas
flowrates
for
PM/
Cl
train
that
were
missing
Not
available
in
copy
of
test
report
Added
15
735C3,
C4,
C5,
737C3,
C4
Use
Orsat
O2
values,
not
CEMS
as
reported
Only
had
CEMS
O2
levels
Replaced
as
suggested
with
supplied
Orsat
O2
values;
although
note
that
values
are
not
significantly
different
15
735C3
Stack
gas
temps
should
be
622,
634
and
632
Stack
gas
temps
of
613,
616,
619
No
significant
difference
15
Should
report
max
or
min
hourly
rolling
averages
for
process
operating
parameters
Report
average
of
each
test
run
for
process
operating
parameters,
not
max
or
min
hourly
rolling
averages
No
change.
Average
of
each
run
is
most
appropriate
at
this
point.

15
735C3,
C4
Max
fuel
feedrates
should
be
used
to
calculate
firing
rates
Average
fuel
feedrates
used.
No
change.
Although,
note
that
difference
between
the
average
and
max
is
not
significant.

15
735C3
Corrections
to
various
ash,
and
metals
feedrates
No
changes.
Differences
not
significant;
for
example,
ash
in
fuel
of
1687.01
vs
1686.7
g/
hr.
15
Objects
to
location
of
Tier
I
feedrate
limits
No
change.
Location
is
unimportant.

15
737
Add
"Boiler"
to
unit
ID
Name
Unit
ID
Name
as
"30K"
Added
15
737
Sister
Facilites
­­
Boiler
70K
for
Cr+
6
Sister
Facilities
­­
none
No
change.
Boiler
70K
has
its
own
performance
data
(unit
ID
No.
735)

15
737C5
Add
new
trial
burn
retest
data
report
Added
new
data
under
test
condition
737C5
15
737C3
HC
under
R3
should
be
nd
HC
is
listed
as
nd
No
change.
Note
that
reporting
a
"nd"
for
a
CEMS
HC
measurement
is
not
appropriate
or
standard
practice.

15
737C4R3
OCDD
­
8.61e­
6;
2,3,7,8­
TCDF
­
8.89e­
5
nd
OCDD
exact
same
as
requested,
TCDF
­­
need
to
add
nd
Added
nd
to
TCDF.
No
significant
impact
on
TEQ
level
15
738
Sister
Facilities
­­
"Boiler
30K"
Unit
737
(Boiler
30K)
is
used
to
represent
Unit
738
(Boiler
28K).

28K
is
a
sister
of
30K.
Thus
data
from
738
will
not
be
used.
At
this
time
though
it
will
remain
in
the
database.

16
1018
Source
Description
should
be
modified:

Additional
soot
blowing
information
provided;

Several
dispersion
characteristics:
Stack
height
=
45
ft,
stack
velocity
=
25.
8
ft/
sec,
gas
temp
=

576F;
Permitting
status
=
All
metals
except
Cr
Adjusted
Tier
I,
Cr
under
Tier
III
Soot
blowing
not
described
in
detail,

stack
height
and
velocity
not
included
in
database.
Temp
measurements
for
two
conditions:
1018C11
=
576,

1018C12=
725
Information
added
or
modified
as
requested.

16
1018
BIF
Feedrates
provided
Previously
not
available
Data
added
16
1018C10
Condition
is
better
described
as
the
maximum
combustion
temperature
condition;
Condition
content
=
Feed
analysis:
10
BIF
metals
(not
chromium
only),
chlorides,
and
ash.
PM,
CO,

and
Cr+
6
and
total
Cr
emissions.
Trial
burn;
max
combustion
temp;
PM,

CO,
Cr+
6,
feed
analysis
for
chromium
and
ash
Modified
as
requested
16
1018C12
Condition
is
better
described
as
the
risk
burn
condition
at
maximum
liquid
waste
feedrates
and
minimum
natural
gas
flowrate
Risk
burn;
max
liquid
waste
fuel
Modified
as
requested
16
1018C10
CO
MHRA
for
Run
1
=
0.6ppmv
7%
O2
0.06
ppmv
7%
O2
Modified
as
requested.
Dependant
cells
also
commented
on.

16
1018C10
Sampling
train
parameters
for
PM,
hexavalent
and
total
chromium
train
provided;
Information
not
available
Data
added
16
1018C10
Additional
feed
stream
data
providedfor
:

natural
gas,
ash
modifier.
Only
liquid
waste
feed
analysis
shown
Data
added
16
1018C11
POHC
total
feedrates
(feed
and
spike)

provided
Data
added
16
1018C11
1018C12
Additional
feed
stream
data
provided
for
natural
gas
Data
added
16
1018C12
Metals
feedrate
condition
averages
should
be
modified:
Ba
<
10,
Hg
<
0.2,
Tl
<
24
Ba
<
15.9,
Hg
<
0.267,
Tl
=
24
Modified
calculations
to
be
consistent
in
handling
of
non­
detect
runs
when
calculating
condition
averages
17
812
More
accurate
description
of
Combustor
Characteristics=
Turbulent
burner
chamber,

closed
coupled
to
a
watertube
waste
heat
boiler,
30
MMBtu/
hr
installed
1985,
25,000
lb/
hr
steam
@
215
psig.
Combustor
Characteristics
=
Waste
heat
boiler,
30
MMBtu/
hr,
installed
1985,
25,000
lb/
hr
steam
@
215
psig
Modified
as
requested
17
812
Source
Description
should
be
modified:
Stack
Height
=
100
ft,
Permit
status
=
Tier
I
adjusted
except
Cr+
6
and
HCl/
Cl2.
Permit
Status
=
Tier
I
adjusted
except
Cr+
6
Information
added
or
modified
as
requested
17
812C2
Several
feed
rates
should
be
modified:
Run
5,

LUWA
Bottom
total
chlorine
feedrate
=
267
lb/
hr,
Chromium
feedrates
=
5.36E­
3,
5.48E­
3,

5.15E­
3lb/
hr
Run
5,
LUWA
Bottom
total
chlorine
feedrate
265
lb/
hr,
Chromium
feedrates
=
5.0E­
3,
5.0E­
3,
5.0E­
3lb/
hr
Modified
as
requested
17
812C1
812C2
812C3
Units
for
Scrubber
L/
G
Ratio
are
lb/
lb
Units
for
Scrubber
L/
G
Ratio
=

gal/
kcaf?
Modified
as
requested
17
813
More
accurate
description
of
Combustor
Characteristics
=Turbulent
burner
chamber
closed
coupled
to
a
water
tube
waste
heat
boiler
and
economizer,
Steam
of
25,000
lb/
hr
@
350
psig.
Combustor
Characteristics
=
Steam
of
25,000
lb/
hr
@
350
psig
Modified
as
requested
17
813
Source
Description
should
be
modified:
Stack
velocity
78.
9
ft/
sec,
Permit
status=
Tier
I
adjusted,
Sootblowing
=
6
min
during
813C1
run
4.
Stack
velocity
78.
9ft/
min,
No
previous
info
on
permit
status
or
soot
blowing.
Information
added
or
modified
as
requested
17
813C1
Average
hydrogen
feedrate
should
be
modified
=
106lb/
hr.
Average
hydrogen
feedrate
=
105
lb/
hr.
Modified
as
requested
17
814
More
accurate
description
of
Combustor
=

Process
Heater/
Boiler;
Primary
function
to
superheat
a
raw
material
used
in
Diphenylamine
production.
Only
a
small
portion
of
the
total
heat
input
is
utilized
for
steam
production.
Combustor
=
Boiler.
Modified
as
requested
17
814
Source
Description
should
be
modified:
Stack
Height
=
75ft
,
Stack
velocity
54.
1ft/
sec.
No
previous
info
on
Stack
Height,

Stack
velocity
54.
1ft/
min.
Information
added
or
modified
as
requested.

17
814C2
Modify
sampling
train
parameters(
B
run):

stack
gas
flowrate,
moisture,
and
temperature.
Modified
as
requested,
although
insignificant
differences
17
814C2
Each
(B
run)
Ash
feedrate
should
be
modified:

1.09,1.17,1.14
lb/
hr.
Ash
feedrates:
2.32,2.03,2.23
lb/
hr
Modified
as
requested
17
815
More
accurate
description
of
Combustor
=Process
Heater/
Boiler;
Primary
function
to
superheat
a
raw
material
used
in
Diphenylamine
production.
Only
a
small
portion
of
the
total
heat
input
is
utilized
for
steam
production.
Combustor
=
Boiler.
Modified
as
requested
17
815
More
accurate
description
of
Combustor
Characteristics
=
Turbulent
burner
chamber,

separate
tube
banks
Combustor
Characteristics
=
Turbulent
burner
chamber.
Modified
as
requested.
17
815
Source
Description
should
be
modified:
Stack
Height
=
80.5ft
,
Stack
velocity
34.
1ft/
sec.
Stack
Height
=
41.5
ft,
Stack
velocity
=

34.1
ft/
min.
Modified
as
requested
17
815C1
Firing
rate
=
15.7
MMBTU/
hr.
Firing
rate
=
17.0
MMBTU/
hr.
Modified
as
requested
18
774
Source
Description
should
be
modified:
Boiler
Nos.
1,
2
and
4
sister
facilities.
Other
Sister
Facilities
=
none.
Modified
as
requested
18
774
Additional
stack
parameters
provided:
Stack
diameter
=
6.5
ft,
stack
height
=
63
ft,
Gas
temp
=
441F,
Velocity
=
52.9
ft/
sec
Data
added
18
774C1
Sampling
train
parameters
for
PM
provided;

Gas
flowrate
=
51467
dscfm,
Moisture
=

15.6%,
Gas
Temp
=
441F
Data
added
18
774C1
Two
feed
rates
should
be
modified:
Ag
feedrate
in
T­
303
feed
0.17
g/
hr,
Tl
feedrate
in
T­
303
feed
0.34
g/
hr.
Ag
feedrate
in
T­
303
feed
2.06
g/
hr,
Tl
feedrate
in
T­
303
feed
0.17
g/
hr.
Modified
as
requested
18
774C1
774C2
Additional
feed
stream
data
provided:
IPOH
feedrate
=
2182843
g/
hr,
Natural
gas
heating
value
=
25089
Data
added
19
729
Incorrect
EPA
ID
No.
(EPA
CTD001159730)
CTD001159731
Changed
19
851
Stack
diameter
=
8"
at
top;
stack
height
=
74.5
ft
above
grade
Changed
19
851C1
R1
and
R2
HC
=
0.5
ppmv
HC
=
0.6
ppmv
Corrected
19
851C1
Miscalculations
of
arsenic,
chromium,
nickel,

and
chlorine
stack
gas
emissions
concentrations
Corrected
19
851
Incorrect
POHC
emissions
rates
Corrected
19
851C1
Incorrect
Cr
stack
gas
emission
rates
Corrected
19
851
Incorrect
PCDD/
PCDF
sampling
train
parameters
Corrected
19
851
Incorrect
Ba
feedrate
Corrected
19
851
Incorrect
2,3,6,7,8­
HpCDD
entry
Corrected
(61.6
vs
61.1)

19
786,
788,
843,
845,
2017,
2018
Couple
of
incorrect
feedrates
No
change.
Feedrates
doublechecked
and
are
OK.

19
Many
Dow
facilities
Missing
Tier
I
and
III
feedrate
limits
Not
provided.
Will
add
when
available.

19
2017C1
R1
PM
=
0.0062
R1
PM
=
0.0054
No
change.
PM
of
0.0054
is
correct
at
7%
O2.
Although,
R2
and
R3
were
incorrectly
given
at
stack
gas
conditions.
These
are
correct
with
levels
at
7%
O2.

22
907
Boiler
No.
15
(ID
No.
907)
is
no
longer
in
service.
Has
been
closed.
Unit
identified
as
no
longer
burning
hazardous
waste
22
910
Sister
unit
Boiler
No.
4
is
no
longer
burning
hazardous
waste
Changed
as
requested
22
908
Burns
both
pulverized
coal
and
natural
gas
as
supplemental
fuels
Coal
as
supplemental
fuel
Added
22
753
Very
small
changes
to
BIF
Tier
I
feedrate
limits
No
change;
insignificant
difference
23
740
Source
Descriptions
should
be
modified:

Facility
Name
=
Rohm
and
Haas
Texas,

Incorporated;
Combustor
=
Furnace
with
watertube
boiler;
Stack
Characteristics:

Diameter
(ft)
=
9,
Height
(ft)
=
144
Rohm
and
Haas;
Watertube
boiler;

Diameter
(ft)
=
9.2,
Height
(ft)
=
150
Modified
as
requested
23
740
Feedrate
MTEC
Calculations
Chlorine
(nd)
=
3613
Lead
(nd)
=
12.3
Cadmium
(nd)
=
6.2
Chromium
(nd)
=
6.2
Feedrate
MTEC
Calculations
Chlorine
(nd)
=
3605
Lead
(nd)
=
11.7
Cadmium
(nd)
=
5.8
Chromium
(nd)
=
5.8
Commenter
used
less
signifigant
figure
and
calculated
MTEC
incorrectly;
no
changes
made.

23
740
SVM
[Cd
&
Pb]
=
17.5
LVM
[As,
Be
&
Cr
(Total)]
=
124
SVM
[Cd
&
Pb]
=
8.8
LVM
[As,
Be
&
Cr
(Total)]
=
62
No
change.
SVM
and
LVM
calculation
non­
detect
value(
s)
is
divided
by
2
(use
of
"one­
half"
of
the
detection
limit).

23
740
Total
Estimated
Firing
Rate
=
101.5
MM
Btu/
hr
Estimated
based
on
total
thermal
feedrate
using
standard
F­
factor
approach.
212.5
MM
Btu/
hr
Modified
as
requested.

23
741
Source
Descriptions
should
be
modified:

Facility
Location
=
Louisville,
KY;
Should
add
"Adjusted"
Tier
I
for
all
metals,
chlorine
Knoxville,
TN;
Tier
I
for
all
metals,

chlorine
Modified
as
requested.

23
741
Stack
Characteristics:
Diameter
(ft)
=
6.5;

Requested
footnote
for
gas
velocity
and
temperature.
"At
sample
location
on
stack
which
has
a
diameter
of
7.83
feet."
Data
added.

23
741
Report
Details:
Report
preparer
=
Focus
Environmental,
Inc.;
Testing
firm
=
TRC
Environmental
Corporation;
Content
=
PM,

CO
in
stack
gas;
metals,
chlorine
and
ash
in
feedstreams
Report
Details:
Report
preparer
=
TRC
Environmental
Corporation;
Testing
firm
=
Focus
Environmental,
Inc.;

Content
=
PM,
CO
in
stack
gas;
metals,

chlorine
in
feedstreams
Modified
as
requested
23
741
PM
emission
rate
(g/
hr):
Run
1
=
5,339;
Run
2
=
5,796;
Run
3
=
8,387;
Corrected
Soot
Blowing
Avg
=
5,857
PM
emission
rate
(g/
hr):
Run
1
=

5,430;
Run
2
=
5,820;
Run
3
=
8,294;

Corrected
Soot
Blowing
Avg
=
not
reported
Modified
as
requested,
although
insignificant
differences.
Soot
corrected
average
verified
and
updated.
23
741
Minor
Changes
Recommended:

Main
gun
feedrate
(lb/
hr)
=
9,
302
Side
gun
feedrate
(lb/
hr)
=
3,
091
Natural
gas
heating
value
(Btu/
scf)
=

1,022
Gas
feedrate
(dscfh)
=
50,400
Antimony
feedrate
(g/
hr)
=
17.
1
Arsenic
feedrate
(g/
hr)
=
14.1
Lead
feedrate
(g/
hr)
=
56.2
Thallium
feedrate
(g/
hr)
=
112
Combustion
Temperature
(
o
F)
=
2,117
Steam
Production
Rate
(lb/
hr)=
154,300
Main
gun
feedrate
(lb/
hr)
=
9,
300
Side
gun
feedrate
(lb/
hr)
=
3,
100
Natural
gas
heating
value
(Btu/
scf)
=

1,000
Gas
feedrate
(dscfh)
=
50,000
Antimony
feedrate
(g/
hr)
=
17
Arsenic
feedrate
(g/
hr)
=
14
Lead
feedrate
(g/
hr)
=
56
Thallium
feedrate
(g/
hr)
=
110
Combustion
Temperature
(
o
F)
=
2,100
Steam
Production
Rate
(lb/
hr)=
152,000
Modified
as
requested
23
741
New
feed
information:

Main
gun
heating
value(
Btu/
hr)=
11,
000
Side
gun
heat
value(
lb/
hr)
=
17,
000
Spiking
feedrate
(lb/
hr)
=
31
Spiking
heating
value
(Btu/
lb)
=
8,
393
Spiking
estimated
firing
rate
(MM
Btu/
hr)
=
0.3
Data
added.

23
741
Chlorine
feedrate
(g/
hr)
=
1,691
Barium
feedrate
(g/
hr)
=
1.1
Hazardous
waste
estimated
firing
rate
(MM
Btu/
hr)
=
154.9
Chlorine
feedrate
(g/
hr)
=
1,900
Barium
feedrate
(g/
hr)
=
11
Hazardous
waste
estimated
firing
rate
(MM
Btu/
hr)
=
165.5
Modified
as
requested.

23
741
Feedrate
MTEC
Calculations
Mercury
MTEC
(ug/
dscm)
(nd)
=
4
Beryllium
MTEC
(ug/
dscm)
(nd)
=
7
etc.
Mercury
MTEC
(ug/
dscm)
(nd)
=
3
Beryllium
MTEC
(ug/
dscm)
(nd)
=
8
Modified
feedrates.
Note
that
commenter
calculation
excluded
oxygen
correction.

23
741
Feedrate
MTEC
Calculations
SVM
[Cd
&
Pb]
(ug/
dscm)
=
800
LVM
[As,
Be
&
Cr
(Total)]
(ug/
dscm)
=
755
Feedrate
MTEC
Calculations
SVM
[Cd
&
Pb]
(ug/
dscm)
=
347
LVM
[As,
Be
&
Cr
(Total)]
(ug/
dscm)

=
340
No
change.
SVM
and
LVM
calculation
non­
detect
value(
s)
is
divided
by
2
(use
of
"one­
half"
of
the
detection
limit).
Appendix
III.
Data
Summary
Sheet
Acronym
List
B
Baseline
Comm
Commercial
incinerator
HW
Hazardous
waste
IB
In­
between
MB
Mini
burn
N
No
spiking
N
Normal
NA
Not
appropriate
NE
Not
evaluated
OS
Onsite
incinerator
PT
Performance
Test
RB
Risk
Burn
RT
Research
testing
SRE
System
removal
efficiency
TB
Trial
Burn
U
Unknown
WC
Worst
case
Y
Yes
spiking
Air
Pollution
Control
Device
Acronyms
AA
Acid
absorber
AB
Afterburner
ABS
Absorber
(packed
bed
scrubber)
BH
Baghouse
C
Cyclone
CA
Carbon
adsorber
CB
Carbon
bed
CCS
Counter
current
scrubber
CFS
Cross
flow
scrubber
CHEAF
Mist
eliminator
filter
CI
Carbon
injection
CS
Caustic
scrubber
CSC
Caustic
scrubber
DA
Dilution
air
DI
Dry
injection
scrubbing
DM
Demister
DS
Dry
scrubber
ES
Entrainment
separator
ESP
Electrostatic
precipitator
FF
Fabric
filter
GC
Gas
cooler
GS
Gas
subcooler
HE
Heat
exchanger
HES
High
energy
scrubber
HEPA
High
efficiency
particulate
air
filter
HTHE
High
temperature
heat
exchanger
HS
Hydrosonic
scrubber
IDF
Induced
draft
fan
IWS
Ionizing
wet
scrubber
LTHE
Low
temperature
heat
exchanger
MC
Multiple
cyclones
ME
Mist
eliminator
OS
Orifice
scrubber
PB
Packed
bed
scrubber
PBS
Packed
bed
scrubber
PCS
Packed
column
scrubber
PT
Packed
tower
scrubber
PTWS
Packed
tower
wet
scrubber
Q
Quench
QC
Quench
column
QS
Quench
separator
QS
Quench
system
QT
Quench
tower
RJS
Reverse
jet
scrubber
S
Scrubber
(wet)
SC
Scrubber
(wet)
SC
Spray
column
SD(
A)
Spray
dryer
adsorber
SP
Separator
SS
Spray
saturator
ST
Spray
tower
VS
Venturi
scrubber
WCS
Packed
bed
water
scrubber
WESP
Wet
electrostatic
precipitator
WHB
Waste
heat
boiler
WS
Wet
scrubber
