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.