The commenter reviewed and approved net output monitoring plans for NOX Budget facilities under the NOX SIP Call, finding that most facilities' and units' determination of net output was straightforward, but that a small subset of facilities faced facility-specific issues complicating determination of net output. For complicated situations, the standard 40 CFR part 75 monitoring petition process could be used to work through complex situations. Certainly, new units should be required to use net output, because they can easily design and install systems to report net output.
Response to Comment 18: As noted elsewhere in this document, the EPA is finalizing gross output as the format of the output-based limits.
Comment 19: Commenter 18426 states that links and relationships need to be established between each surrogate and its respective group of HAP. Each surrogate emission limit needs to satisfy the legal standard for using a surrogate pollutant for a group of HAP. SO2 does not meet the criteria for surrogacy because acid gas HAP are not invariably present in the surrogate pollutant of SO2 and control of SO2 is not the only means by which facilities achieve reductions in emissions of acid gas HAP. PM does meet the criteria to be a surrogate for non-Hg metallic HAP. Since metals preferentially partition and are of concern in the fine fraction, selecting a surrogate that does not reflect the concentration of the fine fraction nor have a health-based standard does not appear appropriate. Filterable PM as a surrogate for total PM as listed in the proposed rule does not work because emissions of the condensable PM portion are influenced by fuel characteristics as opposed to proper operation of a control device. The type and amount of metallic HAP in fuels such as coal and oil can be highly variable, and, therefore, not extremely predictable. For this reason, alternative individual non-Hg metallic HAP emission limits may not be used by sources subject to this regulation and this alternative should be removed. We recommend that the standard only take the form of PM10 or PM2.5 to appropriately limit emissions of non-Hg metallic HAP.
Response to Comment 19: We address elsewhere the legal requirements for establishing surrogate standards consistent with the statute and applicable case law. We have also responded to similar comments elsewhere in this document related to our choice of surrogates and their support. We believe the surrogate standards established in the final rule are reasonable and consistent with the statute.
The EPA maintains that the only standard that expressly applies to the EPA's establishment of a surrogate standard is that the surrogate be reasonable. We maintain that HCl is a reasonable surrogate for all acid gas HAP and, alternatively, SO2 is a reasonable surrogate for all acid gas HAP when the unit is using a flue gas desulfurization technology to comply with the surrogate standard. We also believe that filterable PM is an adequate surrogate for the non-Hg metallic HAP  -  with the exception of selenium. Selenium may be present as filterable particulate or as the acid gas SeO2, which will be controlled along with the other acid gas HAP (HCl, HF, etc.).
Comment 20: Commenter 18428 agrees with the EPA's decision on the use of work practice standards for organics and dioxins. In addition, the commenter concurs with the EPA's decision to allow plant-wide emissions averaging. The commenter encourages the Agency to maximize the flexibilities authorized in the CAA in order to achieve the emission reductions in the most cost effective manner.
Response to Comment 20: The EPA acknowledges the support of the commenter.
Comment 21: Several commenters (19536, 19537, 19538) do not support use of PM surrogate. The commenters state that the total PM surrogate does not permit or support future residual risk standard setting because the risk and technology review (RTR) will require direct monitoring of each non-Hg metallic HAP to determine health risks. Residual risks cannot be estimated from surrogates.
Response to Comment 21: As explained elsewhere in response to comments on this issue, the EPA maintains that PM is a valid surrogate for non-mercury metallic HAP. We do not agree that the commenter's concern undermines our authority to establish PM as a surrogate. We believe we will have sufficient data upon which to evaluate the risk remaining after implementation of the final rule consistent with section 112(f). In any case, the agency is authorized pursuant to section 114 to collect any information necessary to evaluate HAP emissions from EGUs if we determine additional data is necessary when we conduct the CAA section 112(f) review.
Comment 22: Commenter 18023 states that the EPA should, at a minimum, explain how the MACT floor analysis translates into the HF emission limit provided. The commenter also notes that the EPA has the ability to establish an HBEL for acid gases, even for oil-fired units, under CAA section 112(d)(4). As discussed elsewhere, the EPA should exercise its discretion to set an acid gas HBEL for both coal- and oil-fired units.
Response to Comment 22: The HF analyses were conducted no differently than analyses for other HAP and are detailed on the MACT floor spreadsheets in the docket. The EPA has responded to comments related to the use of HBELs elsewhere in this document.
4G01 - ICR: Data corrections
Commenters: 17621, 17622, 17627, 17718, 17730, 17756, 17857, 18025
Comment 1: Commenter 17621 states that heat rates were calculated incorrectly for 53 EGUs listed in the MACT floor spreadsheets. These errors resulted in emissions on a lb/MWh basis that are two to six times too low. EGUs affected by this error include several identified as lowest emitting in the MACT floor spreadsheets. As part of their submittal, the commenter provided a more detailed discussion and list in an appendix to their submittal.
Response to Comment 1: The errors noted by commenter have been corrected in the final spreadsheets. Some of the "errors" noted were a result of companies providing erroneous data through the 2010 ICR (e.g., failing to apportion MWe to each of the boilers using a common generator). The gross unit heat rates for EGUs noted by the commenter and additional EGUs have been reviewed and corrected. There were 59 boilers that had heat input and generation data, which was originally incorrectly entered by companies, that has been corrected. All documentation of these changes is in the docket.
Comment 2: Commenter 17621 states that EPRI identified errors in Part II and Part III ICR data, some of which impact the calculation of MACT floors. As part of their submittal, the commenter provided a more detailed discussion and list in an appendix to their submittal.
Comment 3: Commenter 17730 did not provide any corrected data. They point out that there were errors in some of the data and analyses.
Commenter 17877 states that the schedule for the 2010 ICR was so compressed that it compromised the agency's ability to perform QA/QC, and as a result the industry had a contractor perform as much of the QA/QC as possible. The commenter adds that the contractor has identified many significant errors which make it difficult to comment on the proposal because correcting for the errors will likely change the MACT floor and a source cannot accurately ascertain what is being proposed that must be complied with.
Response to Comments 2 - 3: The EPA has provided quality control checks on data in the EGU data bases and made corrections where possible. The EPA has documented checks on the data input to the data bases by the companies. There were many instances of follow-up with the companies to question and confirm data entries. In addition, there were many instances where companies sent their corrected data on their initiative. We note that it was the responder's responsibility to provide accurate data and to certify that such had been done. The Supporting Statement to the 2010 ICR identifies as a Respondent activity the "...review [of] stack sampling data for accuracy and completeness..." Morever, the cover letter for each ICR told EGU owners or operators that "...it is highly advisable for each facility...to devise a [specific] Quality Assurance Test Plan...to verify that the quality assurance protocols as contained in the various test methods are met..." Finally, those EGU owners or operators who conducted stack testing for Phase III (but not Hg test data using Method 30B), were required to complete electonrically a test report signature page certifying "...the statements and information in is test report are true, accurate, and complete...based on information and belief formed after reasonable inquiry..."
Comment 4: Commenter 17627 explains that the information for the W.H. Sammis Consent Decree is incorrect as the chart does not list the NOX and SO2 tons cap for the entire plant. The commenter states that the NOX rate requirement for the SCRs installed on W.H. Sammis 6 and 7 is 0.10 lb/MMBtu and the Eastlake Unit 5 must meet an 11,000 ton NOX reduction based on the 2003 NOX rate as a baseline. The commenter also notes that RE Burger Units 4 & 5 have been permanently disabled as of December 31, 2010.
Response to Comment 4: The RE Burger (ORIS code 2864) unit 5 has been excluded from further MACT floor outputs, as it has been permanently retired.
Comment 5: Commenter 17627 states that FE's Mitchell power station in Pennsylvania is incorrectly listed as burning No. 6 residual oil, and in fact burned No. 2 distillate fuel oil for the ICR test.
Response to Comment 5: Mitchell's fuel sheet has been corrected to reflect the firing of No. 2 distillate fuel oil instead of No. 6 residual fuel oil.
Comment 6: Commenter 17718 states that in data supplied by Louisville Gas and Electric Company and Kentucky Utilities Company, in response to the EPA's 2010 ICR, Ghent Unit 4's (ORIS 1356) acid gas test data was duplicated and renamed/assigned as a test for Green River Unit 4 (ORIS 1357). This duplication is identified as "Submittal ID" 165611 for "Facility ID" 1357 in the EPA's databases. Green River Unit 4 performed dioxin/furan testing (Submittal ID 1768), not acid gas testing. The "MACT Floor Analysis-Coal HG-Revised" spreadsheet posted on the EPA's website is one specific location at which this duplication is apparent. The errant data associated with Green River Unit 4 is used in the HF floor analysis within that spreadsheet. The EPA should remove the erroneously duplicated data from its databases and evaluate the potential impact the data's removal could have on determination of the proposed emission limits.
Response to Comment 6: The submittal ID 165611 associated with the Green River unit 4 has been deleted. The Ghent ERT acid gas results appear solely for the Ghent facility, although the Green River facility only displays dioxin/furan test results.
Comment 7: Commenter 17756 states that the file "MACT Floor Analysis-Coal acid gas" dated 3/16/11 incorrectly indicates that KCP&L's Montrose Generating Station (ORIS code 2080) has already installed DSI. The commenter states that they correctly responded in the MACT ICR that the units did not have DSI.
Response to Comment 7: This discrepancy has been corrected.
Comment 8: Several commenters (17808, 17870, 18025) state that the following data errors and missing test results have been identified in the spreadsheet summarizing EPA's MACT floor analysis for oil-fired EGUs:
   :: EPA's spreadsheet entitled "floor_analysis_oil_031611.xlsx" lists Mitchell Power Station Units 001 and 003 as combusting "No.6 Fuel Oil (residual or bunker C)". This information is incorrect based a review of the facility's test reports contained in the docket. The Mitchell units burn distillate fuel oil.
   :: The test reports for the Suwannee River Power Plant indicate that Units 2 and 3 were combusting "Distillate Fuel Oil (Grades 1 and 2)" during ICR testing. However, based on a call to the plant operator, we have determined that both units were combusting residual fuel oil.
   :: Based on discussions with industry colleagues, we would also highlight that Middletown Unit 2 and Norwalk Power Unit 2 both have ESPs installed. The EPA's spreadsheet (floor_analysis_oil_031611.xlsx) only lists the NOX controls installed at the units.
   :: Turkey Point 2 tested for total HAP metals as part of the ICR; however, the unit does not appear in the EPA's oil floor analysis spreadsheet.
   :: Emissions test reports from the Puerto Rico Electric Power Authority (8 units) were not included in the MACT floor analysis because of a late submission. We recommend that the EPA include these additional data points in its MACT floor analysis.
   :: At least two units (Eagle Valley 1 and 2) in the MACT floor for total HAP metals do not appear to report cobalt emissions. As a result, their total HAP metal emission rates appear artificially low. Additionally, six units from the Puerto Rico Electric Power Authority did not appear to report cobalt emissions. This omission identifies potentially inconsistencies in the metals testing and development of the proposed standards.
   :: Similarly, Harding Street 9 has a zero value for one beryllium test run, which appears to be averaged in as zero rather than dropped or substituted with the detection limit value.
   :: Finally, in separate comments, NRG has submitted corrected HAP metals emissions data for Norwalk Unit 2, Montville Unit 5, and Middletown Unit 2. The errors overstated the units' HAP metals emission rates.
The current proposed standard (0.000030 lb/MMBtu), was calculated based on seven units, most of which were burning distillate fuel oil during ICR testing. Apart from the two Port Everglades units, all of the units that established the MACT floor for total HAP metals were combusting distillate fuel oil. In some cases, these units were burning low sulfur distillate fuel oil. Eagle Valley, for example, specifies low sulfur (0.05 percent) distillate fuel oil and most shipments received by the facility contain less than 0.03 percent sulfur. Also, the ESPs at the Port Everglades facility were recently installed (construction was completed in 2006). However, nine units with ESPs and five units that were combusting as much as 75 percent natural gas during ICR testing report emission rates above the EPA's proposed standard.
Commenter recommends that the EPA post a revised spreadsheet on the Utility Toxics Rule website, reflecting the corrections above and any further corrections identified by other commenters.
Response to Comment 8: The concerns raised by the commenters have been addressed such that the correct responses appear in the data base. The issues regarding the fuel oil firing have been addressed. The correct emission control devices are associated with the appropriate boilers. All data received and applicable to the rule have been used. To calculate total metals, the EPA only summed the metals for boilers which provided emissions data for all 10 metals. For a limited number of data submittals, the laboratories had not analyzed for all of the HAP metals; these data were not included in the total HAP metals analyses. All runs equal to or less than 0 were excluded from the test average.
Comment 9: Commenter 17637 is concerned the MACT floor calculations are not accurate. The purpose of the MACT floor calculations is to issue standards that are reasonable and effective. Any errors in (ICR) data collection or MACT floor selection results in a MACT Floor that does not provide a level playing field across the source category.
Response to Comment 9: As noted elsewhere in this document, we believe that all data are now correct. We have reassessed our MACT floor analyses and believe them to be consistent and correct.

4G02 - ICR: New data submissions
No comments were received on this topic.

4G03 - ICR: Data handling
Commenters: 17628, 17715, 17718, 17803, 17813, 17820, 18039, 19654
Comment 1: According to commenter 17628, the 0.050 lb/MWH limit is based on a computational error. In deriving the limit, the EPA mistakenly assumed that each AES unit has a capacity of 180 MW when, in fact, the capacity of the two-unit plant is a total of 180 MW. The commenter states that the EPA must revise the limit and when other coal-fired total particulate emission test results from the ICR data base are evaluated, the total particulate emission standard would be very close, to Plant Washington's current limit of 0.018 lb/MMBTU, or 0.16 lb/ MWH.
Response to Comment 1: The EPA has reviewed and corrected the unit heat rate for this boiler. We would note, however, that the error resulted, in part, from submitter's failure to accurately apportion the MW for the common generator to the separate boilers, providing instead the total MW to each boiler.
Comment 2: Commenter 17715 states that the proposed rule does not address the handling of negative values. The commenter recommends that negative values be rounded to zero and use an associated code to indicate the change. This is similar to how part 75 handles negative data. If instrument drift and allowable calibration error tolerances are included, it is possible to be within the analysis tolerance and read a legitimate negative value.
Response to Comment 2: The agency reviewed the commenter's concern but disagrees with the suggestion to provide instructions on how to handle negative values in the rule. We are unaware of any manual method which provides a means for negative values, and we are unaware of any reputable and knowledgeable emissions testing contractor who would report negative particulate emissions.
Comment 3: Commenter 17803 states that although they agree that raw data from units co-firing oil and natural gas should not be used to set the floor for the liquid oil subcategory, the EPA's failure to utilize an adjusted form of the data is inconsistent with CAA section 112. The CAA requires the EPA to establish standards for existing units based on the average emissions achieved by the best performing 12% of sources for which the Administrator has emissions information. The data collected by co-fired sources was made available to the EPA and the EPA should have adjusted and used the data to develop the proposed standards and the EPA has not offered any justification for its failure to do so.
Commenter 17803 recommends that the EPA revise the MACT floor for existing oil-fired units by using data from units that co-fired oil and gas during ICR testing adjusted to exclude the contributions from gas firing. Owners and operators of co-fired units understood that the EPA would adjust the data to reflect operations on oil only and use the data in setting the standards. It appears that the EPA disregarded this data in its analysis.
Commenter 17739 states that the Indiantown Cogeneration, Unit 1 (docket EPA-HQ-OAR-2009-0234-0754) co-fired natural gas during all Hg sampling tests. The EPA excluded data from three companies required to conduct testing on oil-fired units that also co-fired gas "because their emissions are not representative of EGUs firing 100 percent fuel oil." The commenter states that the EPA must therefore exclude these data from the Hg floor for the same reasons.
Response to Comment 3: The EPA does not believe its handling of such data is inconsistent with CAA section 112. The EPA has made some adjustments as noted by commenter in the final rule. The EPA did this by confirming with all companies operating oil-fired EGUs and providing Part III 2010 ICR testing data which fuel(s) they combusted during their ICR stack testing. As part of the floor calculations, all oil-fired EGUs that co-fired less than or equal to10 percent natural gas (by heat content) had their data included in the floor calculations. However, EGUs that co-fired greater than 10 percent natural gas (by heat content) had their data excluded from the floor calculations. Prior to their stack testing efforts, the EPA was contacted by several companies that had oil-fired EGUs that co-fired natural gas and oil. These companies explained that, due to contracts, they could not stop co-firing to perform 100 percent fuel oil-fired stack testing. The EPA agreed to let those companies test under their "normal operation" even if that operation included co-firing oil with natural gas. We also indicated that the EPA would try to utilize the data if possible. However, the EPA did not realize that the percent natural gas fraction would be as large as it was in some cases and after reviewing the test data we concluded that it is not possible to utilize most of these data. As to the commenter's suggestion to exclude the contributions from natural gas firing, EPA believes it is not possible to separate post-combustion HAP emissions and attribute them to separate fuels (i.e., apportion the data to the oil fraction versus the natural gas fraction). The EPA believes that including such co-firing data in the MACT floor analyses would result in a skewed emission limit that oil-fired EGUs without access to natural gas would be unable to meet. Therefore, the EPA had to disregard these selected co-fired derived data from EGUs exceeding the 10 percent threshold mentioned above from the data used to analyze HAP floor emissions and to develop the final oil-fired EGU limits.
Comment 4: According to commenter 17820, gross unit heat rates (GHR) were calculated incorrectly for 53 EGUs. This resulted in proposed output-based standards for existing units that are two to six times too low. In the emissions floor calculation, the EPA determines GHR based on the "maximum heat input capacity" and "gross (summer) generating capacity" and uses this value to convert reported emissions on the basis of heat input (lb/MMBtu) to unit output (lb/MWh). Due to reporting inconsistencies, these values are not necessarily equivalent to the "design gross heat rate", which the EPA assumed in the data conversion procedure. Significant problems were especially observed with units that share common stacks. The commenter recommends that the EPA recalculate the data by converting measured emissions directly to units of lb/MWh based on the reported stack flows and gross generation at the time of the stack test.
Response to Comment 4: The gross unit heat rates for these and additional EGUs have been reviewed and corrected. There were 59 boilers that had heat input and generation data, which was originally incorrectly entered by companies, that has been corrected.
Comment 5: Commenter 17718 requests that the EPA explain its methodology for converting emission limits from units of "lb/TBtu" to units of "lb/GWH." For the emission limits found in Tables 1 and 2 of the proposed rule, it appears that a unit heat rate of 10 million Btu per megawatt (MMBtu/MW) was used to convert the limits units of measure from "lb/TBtu" to "lb/GWH" for all emissions but Hg. For Hg, it appears that the EPA used a unit heat rate of 8.8 MMBtu/MW. It appears that a unit specific heat rate would be the proper way to convert the limit and it is unclear why a different heat rate would be used for different standards.
Response to Comment 5: The EPA used unit-specific heat rates to convert between the input- (lb/MMBtu) and output- (lb/MWh) based emission factors. Each unit's heat rate was calculated by dividing their maximum heat input by the gross summer generating capacity.
Comment 6: Commenter 19654 states that appendix A to subpart UUUUU-Hg Monitoring Provisions, section <IP_ADDRESS> uses a rounded units conversion factor 6.24 x 10^-11 for the Method 19 emission rates calculations, that appears in Equation A-2 as 6.236 x 10^-11 and questions if thee is a reason that the Method 19 calculations should not use the 6.236 factor.
Response to Comment 6: Given that agency policy is to round terminal calculations to the number of significant figures of the emissions limit, that the value used by the commenter is used in an intermediate calculation, and that the rule's Hg emissions limit contains two significant figures, one may use either the value contained in appendix A or in equation A-2 of the proposed rule; however, based on this comment, equation A-2 in the final rule has been revised to include only two significant figures.
4G04 - ICR: Other
Commenters: 17621, 17770, 17796, 17808, 19114, 6637
Comment 1: Commenter 17621 states that the two EGUs that complied with the limits for all HAP were not typical of U.S. power generating units.
Response to Comment 1: As noted elsewhere in this document, the EPA has reassessed the data used in the MACT floor analyses partly based on comments received and believes that the limits in the final rule comply with the statutory requirements and recent Court decisions. As a result of the reassessment, different EGUs are the basis for the new-source limits than at proposal and the EPA believes these EGUs to be typical of new U.S. power generation.
Comment 2: Commenter 17621 states that some of the ICR organics HAP that were detected in emission tests were affected by contamination of the sample with non-flue gas sources of HAP. Several of the chemicals noted by the EPA as frequently detected in the ICR data (benzene and formaldehyde) were also frequently detected in the field blanks and/or method blanks and are known contaminants or breakdown products of the sorbent used in sample collection.
Response to Comment 2: The EPA proposed and is finalizing a work practice standard for regulating organic HAP.
Comment 3: Commenter 17770 requests that the EPA correct the information on their Oak Creek Power Plant and Valley Power Plant and remove these two plants from the EPA's list of predicted 2015 retirements.
Response to Comment 3: Contrary to commenter's statement, the EPA does not assume that the units referenced by the commenter will retire in 2015. The EPA's IPM modeling represents a national perspective of least-cost electricity dispatch throughout the modeled regions to meet electricity demand, in both base case projections as well as projections with policy constraints (such as the proposed MATS emission rate limitations). The EPA is not making any determination of future unit-level compliance based on these modeling projections; individual unit owners will make their own economic determination of how they wish to comply with the regulation. Unit owners and operators should consider compliance options with the proposed emission rate standards and are advised to weigh the economic merit of each compliance option to minimize costs although achieving compliance in the future.
The EPA's IPM modeling relies on assumptions regarding future electricity demand and available generating capacity in each modeled region. The parsed file disaggregates model results to a unit level and does not necessarily capture all of the relevant unit-level details that a unit owner may account for in the future when determining compliance planning and economic operations. IPM projections represent a least-cost system-wide pattern of generation allowing the Agency to determine the overall cost impacts of a potential regulation. In the future, the decision to continue operation with emissions controls, or to cease operation, will be made by each facility according to that owner's determination of economic operation potential.
Comment 4: Commenter 17770 states that the EPA incorrectly identified their Oak Creek and Pleasant Prairie plants as needing to install baghouses.
Response to Comment 4: Per commenter's request, and with information supplied by the commenter regarding current PM control performance and controls currently under construction, the EPA does not assume in final modeling that a fabric filter retrofit is necessary for these units to meet the final PM standard.
Comment 5: Commenter 17808 supplied corrected data for oil-fired units. They stated that of the seven units used to calculate the MACT floor, five burned distillate oil. Nine units with ESPs and five units that were combusting up to 75% natural gas report emissions above the proposed total HAP metals standard. The commenter recommends that the EPA post a revised spreadsheet on the Utility MACT website.
Response to Comment 5: As noted elsewhere in this document, the EPA has reassessed the data used in the MACT floor analyses partly based on comments received.
Comment 6: Commenter 6637 states that there were three revisions of the ERT in an effort to correct and improve the reporting of stack test data. The commenter states that the use of multiple emission spreadsheet versions for reporting the ICR data led to significant issues for both data consistency and data retrieval. According to the commenter, the following were issues resulting from the version changes and technical issues remaining in the May 25 version:
1. In the initial emission spreadsheet each run was entered in a separate column; whereas in the revised spreadsheets, each run is entered in a separate row. This created major difficulties in designing an automated data retrieval tool that could handle both configurations.
2. The original spreadsheet did not include fields for the O2/CO2 concentrations measured in conjunction with each run. In the original spreadsheet, it was unclear how the reported data in the O2/CO2 spreadsheet correlated to the runs for each analyte.
3. The initial spreadsheet did not have a specific place to indicate whether a run value was above or below detection limit; it was to be entered into the "Other Supporting Information" column. There was not a practical way to associate a specific run value with its associated detection flag.
4. The first two versions of the emission spreadsheet listed incorrect units for VOC and SVOC emissions: ppmvd @ 7% O2 rather than the ICR-required units of μg/dscm @ 7% O2. In some cases, the respondents changed the headers to the correct units. In other cases, ICR data were reported in μg/dscm but the column header of ppmvd was retained. Use of the values and units as reported could result in biased results.
5. The dropdown lists for the VOC and SVOC compounds do not match the analytes requested by the EPA on the FAQ page, which may have resulted in inconsistent reporting of speciated organics.
6. The spreadsheet asks for units of flow that are not standard in the testing industry and may have led to data entry errors.
Response to Comment 6: There were numerous requests from the 2010 ICR recipients to clarify the EPA's test plan (listed in the ICR) and to fix some programming elements in the ERT. These requests were addressed in the 2010 ICR effort's website in the "Frequently Asked Questions" web pages. The EPA sought this input in order to improve the early versions of the spreadsheets (which were downloadable) and the ERT program to make it possible to gather accurate information. Through these actions, the EPA made every effort to aid in the gathering of accurate data.
Comment 7: Commenter 17770 states that both the Oak Creek and Pleasant Prairie plants have ESPs to control PM emissions. At Pleasant Prairie, the ESP is followed by a WFGD system and previous tests have shown that these units will be capable of meeting the proposed total PM emission limit. At Oak Creek, a WFGD system is currently being installed and will be operational by the end of 2012. Commenter anticipates that Oak Creek will meet the proposed total PM emission limits at that time. Commenter requests that the EPA revise this document and remove these two plants from the EPA's projection of fabric filter baghouse installations.
Response to Comment 7: Per commenter's request, and with information supplied by the commenter regarding current PM control performance and controls currently under construction, the EPA does not assume in final modeling that a fabric filter retrofit is necessary for these units to meet the final PM standard.
Comment 8: Commenter 19114 states that a number of factors influence the potential emissions from coal-based generating units. All of the data collected through the ICR issued to support the proposed rule was collected during stable full-load operations. Many of the constituents are inherently variable within coals commonly used at the same unit. Under the proposed rule, an operator is likely to be in the unenviable position of testing below a limit one time and then testing above the limit the next without knowing what actions to take to change the emission rate.
Response to Comment 8: The EPA believes that use of the 99% UPL and, for sources that demonstrate compliance on a continuous basis, the 30-day rolling average adequately addresses the variability concerns noted by commenter.
4G05 - ICR: Data quality and data errors
Commenters: 10821, 12991, 17621, 17622, 17711, 17714, 17716, 17725, 17735, 17736, 17739, 17740, 17761, 17770, 17772, 17775, 17781, 17807, 17808, 17812, 17820, 17868, 17871, 17877, 17912, 17914, 18014, 18033, 18034, 18414, 18437, 18498, 6637, 18023
1. Use of Part II data.
Comment 1: According to Commenters 17716 and 18414, Part II test data should have been used in limited circumstances. The commenters state that the test data collected by sources required to perform testing under Part III of the information collection request along with the historic test data previously collected under Part II of that same information collection request should not be treated equally. The commenters state that Part III data was developed using much longer sampling times and greater sampling volumes to allow for more accurate information than would be collected under normal testing. The Part II data used differing sample volumes or times and, perhaps, following different procedures or conditions. Part II data may be useful when the number of units or test data in the category is small because including these data can provide additional information about the variability of the source(s) in question. But for existing coal-fired units involving a large number of units, the Part III data is adequate to address variability concerns. Using the Part II data would also defeat the purpose of longer measuring time and greater sample volumes that were required for the Part III information collection request.
Comment 2: Commenter 17621 states that the Part II ICR data consisted of historical tests performed by power plants over the previous 5 years prior to the ICR, for various purposes. These data may not be representative of the population of U.S. power plants, as the EPA made no attempt to ensure that the numbers of tests reported for each HAP were in proportion to the frequency of occurrence of various categories of power plant in the entire U.S. fleet.
The commenter states that the Part III ICR data came from facilities that were required to perform stack tests in response to the ICR. These EGUs were selected by the EPA as potentially best performing units in each family of HAP and are, therefore, not representative of the current population of U.S. coal-fired power plants.
The commenter notes that the ICR also was sent to a random 50 EGUs selected by the EPA as representative of U.S. coal-fired power plants not selected in Part III of the ICR.
The commenter further states that the three categories of data were pooled to select `best-performing' units. The pooled data are likely not representative of all U.S. power plants. The EPA's selection approach complicates efforts to determine the need for and value of subcategorizing sources, i.e., by coal rank, coal chloride concentration, etc. The selection process also makes it difficult for the Agency and EPRI to calculate representative values for HAP emissions across the industry, which can be accomplished only through an assessment of a broader and more representative population of existing units.
Response to Comments 1 - 2: The EPA's rationale for its selection of units to test is explained in the proposal preamble and in the Supporting Statements for the 2010 ICR. As explained in these documents, the EPA targeted best performing EGUs for non-Hg metallic HAP, acid-gas HAP, and organic HAP so as to be able to use the maximum amount of the data possible when establishing MACT floor limits. In addition, the EPA required all coal- and oil-fired EGUs to provide all available data gathered over the past 5 years and, thus, the EPA had information and data on the industry as a whole. The EPA did not expect, and in fact did not receive, much HAP emissions date under Part II of the ICR because most EGUs are not subject to HAP emission limits. We did receive some HAP data, however, and we used it in establishing the standards to the extent it was in the appropriate format or could be converted to the proper format, and it was not otherwise inappropriate to use the data (e.g., the data was generated before a new pollution control device was installed). Therefore, the EPA believes that the data made available to it is representative of the industry and that the data are sufficient to assess the appropriateness of any subcategories. Furthermore, boilers of all types burning coals of all ranks were represented among the best performing sources so the commenters' concern that the EPA somehow failed to adequately characterize the category is unfounded.
2. Noise level, experience, issues with measurement methods.
Comment 3: Commenter 17622 states that the Hg, HCl and total PM limitations for new units may be at levels that approach the "noise" of practical measurement methods. For this reason, the commenter urges the EPA to verify that the reported performance for the best performing unit that is the basis of the limit is correct. The commenter states that a thorough re-examination of the test reports and procedures should be performed and urges the EPA to validate the ICR test data using the ASME program ReMap and ASME's19.1 Test Uncertainty. The commenter recommends re-testing of these units under the same conditions to verify that the emissions results are repeatable and sustainable over an operating period that includes periods of start-up and shutdown.
Commenter 17622 adds that although Hg measurement methods have been developed rapidly over the past decade, there is insufficient experience measuring Hg in flue gas at concentrations equivalent to the proposed new unit limits to understand the detection limitations and quantitative accuracy at such low Hg concentrations for either of the two continuous methods  -  sorbent traps or continuous analyzers. Without better information on the limitations of these measurement methods at such low Hg concentrations, it is difficult to have confidence in measurements taken at these low concentrations.
Commenter 17621 states that it is important to note that there are also uncertainties associated with measurement of filterable PM. The temperature of the particulate filter has a significant impact on the test results. Since many of the Part III ICR tests on dry stacks were conducted at the lower temperature due to lack of clarity on the ICR testing requirements (EPRI, 2010), some of the ICR data are biased high. The type of filter used also affects the results: In EPRI's study 6 out of 7 samples collected with a glass fiber filter had higher filterable PM loading than a sample collected simultaneously with a quartz fiber filter: the increase in filterable PM on the glass fiber filter ranged from 3 to 124%.
Commenter 17621 states it is difficult to evaluate the adequacy of Method 29 to measure total metals or total non-Hg metals at the proposed alternative limits, as the limits are not calculated from the individual metals tests but are the result of a separate statistical calculation on total metals reported for each EGU. The approach used by EPRI was to compare the proposed MACT limits with the sum of the lowest MDLs from the EPRI review multiplied by 10 (2.5 lb/TBtu). However, that approach may be too optimistic as to the method's capability to measure at the limit, as the MDLs do not reflect the actual performance of the method on stack samples.
Commenter 17621 summarized their method adequacy determination for coal-fired EGUs in a table in their submittal. Method 29 is not sensitive enough to quantify five of the HAP metals (antimony, arsenic, beryllium, cadmium, and Hg) at the MACT limits for future coal-fired EGUs, and may not be sensitive enough for four other metals (cobalt, lead, manganese, and nickel). The sensitivity of Method 29 is adequate to quantify total non-Hg metals at the proposed alternative limit for existing and future coal-fired EGUs.
Commenter 17621 notes that the method adequacy determination for new coal-fired EGUs >= 8,300 Btu/lb also applies to the limits for new IGCCs, where those are the same as for coal EGUs. Hg cannot be measured at the limit for new IGCCs (0.00001 lb/GWh) by any of the proposed methods.
Commenter 17621 summarized their method adequacy determination for liquid oil-fired EGUs in a table as part of their submittal.
Commenter 17621 states that Method 29 was determined not to be sensitive enough to accurately measure beryllium and Hg at the proposed alternative individual metal MACT limits for existing liquid oil-fired EGUs. Method 29 is not sensitive enough to accurately measure five of the HAP metals (arsenic, beryllium, cadmium, Hg, and selenium) at the proposed alternative MACT limits for future liquid oil-fired EGUs. The sensitivity of Method 29 is adequate to quantify total non-Hg metals at the total metals limits for both existing and future liquid oil-fired EGUs.
As a final observation, the commenter notes that the EPA stated that Method 29 should not be used in the ICR Part III for stacks with Hg emissions under 1 μg/dscm (approximately 0.9 lb/TBtu for coal units and 0.7 lb/TBtu for oil units). However, 31 percent of the coal-fired EGU test runs and 100 percent of the liquid oil-fired EGU test runs measured with Method 29 had emissions values below those levels and by the EPA's definition should be considered inaccurate. Therefore, the EPA should consider whether omitting those test results from their evaluation would improve the accuracy of the MACT floor determination. Additionally, according to this guidance, Method 29 should not be used for compliance with the proposed MACT floor for existing units of 1.2 lb/TBtu, as that value is fairly close to the level at which EPA states the method is not applicable.
Commenter 17621 reviewed methods sensitivity for HCl, HF, and SO2 only. Method CTM-033 for HCN, which was included in this HAP test group for the ICR, had extremely poor performance, including elevated detection limits and blank contamination. In addition, the inability of most testers to maintain the required basic pH in the CTM-033 impingers led the commenter to conclude that the ICR data for HCN are biased low.
Response to Comment 3: Given that the agency used a procedure that compared the UPL to 3 times the RDL to account for variability and method detection levels when setting emissions limits, the agency believes all emissions limits can be measured accurately using existing methods. As EGU owners or operators collected the data and certified its accuracy and completeness, the agency has no reason to refute the reported results; moreover, if an owner or operator had a problem, the agency expects he or she would have contacted the agency for guidance, as did some owners or operators, or would have conducted additional emissions testing using appropriate techniques. Regarding suggested Method 29 insensitivity for individual metals at an EGU, the owner or operator could choose alternative means of compliance, including a total metals limit. Regarding suggested Method 29 insensitivity for individual metals at an EGU, the owner or operator could choose alternative means of compliance, including a total metals limit or a particulate matter limit. Regarding the commenter's suggestion that IGCC Hg emissions are below the emissions limit, because the commenter need only show that the emissions limit was met, an emissions test using the required volume and resulting in non-detection of mercury emissions will meet the emissions limit. With respect to the commenter's view that Hg data below one microgram per cubic meter collected using Method 29 should be excluded from floor setting, the agency disagrees. As mentioned earlier, the agency's use of a procedure to account for variability and method detection levels when setting emissions limits ensures the Hg data below one microgram per cubic meter can be used to establish an emissions limit. Moreover, as the rule allows sorbent trap measurement and emissions testing as alternatives to the use of Hg CEMS, an EGU owner or operator has a variety of means to demonstrate compliance with the mercury emissions limit. Finally, the agency agrees with the commenter with respect to the HCN data, and the rule contains no separate HCN emissions limit. Moreover, the agency believes the acid gas control technology used to meet the HCl and HF emissions limits will serve to control HCN emissions.
3. Data accuracy/errors (detection limits, heat rates, adherence to sampling requirements) failure to do QA, missing data, incompleteness and inconsistency of ICR data.
Comment 4: Commenter 17648 states that although the EPA has made some errors in arithmetic and data transcription, it either has already corrected them or can do so in response to comments in promulgating the final rule, without the need for re-publication of the rule.
Response to Comment 4: The EPA acknowledges the commenter's statement.
Comment 5: Commenter 17675 notes that the proposed Hg limits in the MACT floor were incorrectly calculated in the background documents for the proposal and an inappropriately low Hg standard is reflected in the proposal. The EPA was made aware of this error by UARG in May 2011 and the EPA must address the necessary corrections to the proposed emission limits in the final standards.
Response to Comment 5: The EPA has reassessed the emissions test data and made any necessary corrections in the final data set. We then reassessed the MACT floor analyses for all HAP and believe that the emission limits in the final rule are consistent with the statutory mandate.
Comment 6: Commenter 12991 states that there are problems of incompleteness and inconsistency with some of the utility MACT ICR data. According to the commenter, coal Hg content is not reported for about 40 percent of the 339 units although the commenter was able to identify Hg content from files in the docket or estimate it based on county-origin of the coal shipped to the plant during 2009 (EIA-923 data) and the county average Hg content of the coal from the 1999 ICR data. According to the commenter, one-third of the ICR Part II Btu/lb, S and Ash values are reported on a moist rather than dry basis and the Part III coal analyses are internally inconsistent. The commenter provides information showing that 42% of the Part III data failed the Mott Spooner test (compares the measured heating value with the theoretical heating value); a 5 to 10% failure rate was expected. According to the commenter, such errors may be significant where F factors are used to determine stack emission rates. The commenter states that there are also inconsistencies in trace metal and Hg contents between Part II and Part III data. The commenter also states that there are other less easily observed limitations.
Numerous commenters (17621, 17637, 17714, 17725, 17736, 17739, 17761, 17775, 17807, 17868, 17871, 17912, 17914, 18014, 18033, 18034, 18437, 18498 and others) express concern over the accuracy of data in the database and the resulting MACT floor calculations. Specifically, comments were received stating that:
1. Errors were identified in the EPA database (e.g., measurements below detection limits, inaccurate heat rates, failure to adhere to sampling requirements) that indicate the EPA did not conduct an adequate quality control review of the data as promised.
2. At least ten units (25%) in the EPA's "corrected" 40 unit mercury floor fail basic QA/QC checks and should be deleted from the floor database.
3. Submitted Hg data from 98 plants have simply been ignored in all emission evaluations without explanation.
4. A conversion error that made the emissions of 20 of the 40 the units in the original Hg floor 1,000 times too low. According to the commenters, the existence of a clear and relatively obvious error such as this appears not to be isolated, but rather systemic. The commenters state that the EPA was made aware of potential data problems during interAgency reviews. The commenters state that the EPA should take additional time to correct the errors.
5. Files that have not been made available on the rulemaking docket.
6. Commenter 10821 states that for the units designed to bum coal with heat values of less than <8,300 Btu/lb (known as Subcategory 2), the EPA stated that there were fewer than 30 units in the subcategory and set the floor based on the top-two EGUs. The EPA has inappropriately excluded at least 4 sources from this subcategory, likely pushing the number over 30. Regardless of whether there are less or more than 30 units in this subcategory, the EPA should still have relied on at least 5 units to set the MACT floor as required by CAA section 112(d)(3).
7. Commenter 17621 states that heat rates are incorrect for 53 EGUs listed in the MACT floor spreadsheets. In these cases, the gross capacity in megawatts (electric) (MWe) for the entire facility was entered into the Part II report rather than an allocated capacity for each boiler. This error produces heat rates that are not realistic for fossil fuel-fired power plants. Due to the impact on emissions, units with this problem are prevalent among the "lowest emitting plants" sorted by lb/MWh. The impacted units were used as the basis for several future plant limits for coal (PM, total metals, antimony, and beryllium).
8. Commenter 17621 states that results of ICR Part III tests from nine liquid-oil fired EGUs are missing from the MACT floor calculations. Commenter 17621 adds that these problems make it very difficult to comment on the substance of the proposal, because correcting these errors will likely change the MACT floors. Commenter 17621 includes a more detailed discussion and a list of errors identified in an appendix to their submittal.
9. Commenter 17621 states that for the new EGU limits, where the UPL is calculated from as few as three test runs conducted at a single facility by a single laboratory, it is incumbent on the EPA to verify that those reported values are free of errors, analyzed according to standard laboratory procedures, and reported in accordance with the ICR requirements.
10. Commenter 17714 states that they found errors in the EPA's calculations used to establish the proposed Hg limit and is concerned that there may be additional errors in the data and calculations and urges the EPA to carefully examine the supporting data and calculations and make necessary corrections prior to finalizing the limits. Any resulting changes to the limits should undergo an additional notice and comment period to allow affected parties to comment.
11. Commenter 17739 states that assessing the EPA's MACT floor calculations was difficult and largely stem from the EPA's actual, but unexplained, manipulation of the data, which are inconsistent with CAA section 307(d)(3), which requires the EPA to set forth in its proposal "the methodology used in obtaining the data and in analyzing the data."
12. Commenter 17775 states that the EPA published a proposed rule that was not thoroughly reviewed for errors that would have been evident had the EPA allowed itself sufficient time to produce a scientifically sound rule. The EPA's serious conversion error should have led the agency to amend its proposed rule through some form of Federal Register notice. As a result, commenters are left uncertain whether they should comment on the Hg limits published in the Federal Register on May 3, 2011 or the revised Hg standards found in Assistant Administrator McCarthy's May 18 letter and in the rulemaking docket.
13. According to commenter 17716, the heat rates calculated by the EPA of less than 7000 Btu/kWh represent efficiencies that would be impossible for these units to achieve.
14. Commenter 17735 believes the agency made a computational error in converting the AES Hawaii Unit 1 total PM results from input units to output-based units and mistakenly assumed that both AES units have a capacity of 180 MW; the capacity of the two-unit plant is 180 MW. According to the commenter, this error is easily verified in the EPA's spreadsheet because it shows Unit 1 has a heat rate of 5.03 MMBtu/MWh, but the correct value is exactly twice that or 10.06 MMBtu/MWh and when the corrected heat rate (or conversion error) is incorporated into the three individual total PM runs, a repeat of the EPA's UPL calculation yields a calculated PM value of 0.10 lb/MWh. Even as unrepresentative as AES Unit 1 may be for the purpose of determining MACT, the commenter states that it does not appear to support an emission limit of 0.05 lb/MWh. The commenter requests that the EPA revisit the MACT determinations to ensure that these computational errors are corrected prior to the final rule.
The commenter also states that this unit is not representative because it burns Indonesian coal; its generating capacity is nominally 180 MW, but the emissions source identified, in reality, is only half that, and it also burns old tires, used motor oil, and carbon from the State's Board of Water Supply filters; performance data for the unit do not appear to be representative of what the unit will regularly achieve in practice. Therefore, the EPA's PM standard is not representative of what is achievable in practice.
15. Commenter 17761 states that the EPA utilized the wrong units of measure for Walter Scott Unit 4 PM testing conducted in August 2007 and submitted as part of the ICR. In this case, the actual PM test result was 0.008 lb/MMBtu; however the EPA included the value in its database as 0.008 lb/hr, which produces an extremely unrealistic emission rate of 1x10-6 lb/MMBtu.
16. Commenter 6637 reviewed stack test reports for about half of the generating units included in the ICR and inspected an interim database of ICR test data published by the EPA to determine if the same quality issues were present. Areas assessed included calculations and reporting, detection limits, sampling quality control, and laboratory quality control. According to the commenter, a common issue that affected all of the test methods was that utilities provided insufficient information to determine if measurements were within a concentration range at which they could be accurately detected and quantified. Other problems included calculation and data entry errors. The commenter also assessed the quality of data produced by many of the individual test methods and notes specific quality issues with the tests for hydrogen cyanide, formaldehyde, filterable and condensable particulate, and several metals. The non-dioxin/furan organics and the dioxin/furan/PCB organics groups had a high percentage of measurements below detection limits, and were impacted by non-sample-related sources of the target chemicals. For each quality issue, the commenter stated the likely impact on the accuracy of the overall ICR database, and where possible, suggested approaches that could be used to screen out problem measurements and improve the overall data quality. In their submittal, the commenter provides a substantial amount of additional and detailed information for each of the areas they reviewed.
According to the commenter, their reviews of the Part III ICR test results identified quality issues that have the potential to interfere with the usability of the data. The commenter states that the issues identified can be separated into two groups: those that can be addressed by identifying and screening out poor quality data, and those that affect such a high proportion of the results that a more general solution will be needed. In the first category are individual method-related issues such as elevated detection limits for HCN and failures of method quality control criteria for Hg. These issues can be remedied by using information contained in the EPA reporting templates to identify and screen out affected values. The second category includes identification of appropriate detection and quantitation limits for each parameter. Commenter states that to overcome the problem, a possible short-term approach is to identify the range of method detection limits in a cross-section of the ICR test data, and calculate from those values the upper bound detection limits that could be achieved by most laboratories. Provisional quantitation limits could then be established as a multiplier of these detection limits. However, this approach is not a good solution in the long term for establishing quantitation limits for compliance test methods. Rather, the limits should be determined in the field using parallel sampling trains to determine measurement variability over a range of actual stack gas concentrations and conditions.
The following table lists the areas in which the commenter identified data quality issues. See the original comment submittal for a detailed discussion of each area listed below.
                              Data Quality Issue
                          Page in .pdf comment letter
Reporting Template Version Issues
                                      31
Reporting Detection Limits
                                      39
Data Entry and Calculation Errors
                                      43
Incomplete Quality Control Reporting
                                      43
Low Sample/Blank Ratios
                                      43
Reporting of Direct Reading Method Results
                                      44
Acid Gases Method 26A Data Quality
                                      45
Hydrogen Cyanide by EPA Method CTM-033 Data Quality
                                      46
Acid Gases and HCN by EPA Method 320 Method 320 Data Quality
                                      47
Method 29 Metals Data Quality
                                      50
Metals Method 29 and 5 Filterable PM Data Quality
                                      52
Mercury Method 30 B Data Quality
                                      53
PM 2.5 OTM-27 Data Quality
                                      54
Condensable PM OTM-28 Data Quality
                                      55
Formaldehyde Method 0011 Data Quality
                                      59
Formaldehyde by EPA Method 320
                                      60
THC Method 25A Data Quality
                                      60
Methane Method 18 Data Quality
                                      61
CO Method 10 Data Quality
                                      62
VOC Method 0031/8260B Data Quality
                                      63
SVOC Method 0010/8270D Data Quality
                                      64
PCDDs/PCDFsMethod 23 Data Quality
                                      67
PCBs by EPA Methods 23/1668 Method 23/1668B Data Quality
                                     68
17. Commenter 17621 states that they identified many confirmed or suspected errors in individual EGU emissions values that could potentially impact MACT floor calculations and identified their criteria for identifying errors and the types of QA checks that the EPA should perform to identify and correct errors.
Commenter 17621 listed eight liquid oil-fired EGUs in the EPA's Part III database for which test results were missing. Results for these should be added and UPL calculations revised.
18. Commenter 17711 states that the EPA should perform a data quality review to ensure emission rates were correctly calculated and input into the ERT and EPA MACT floor calculations. The EPA should also ensure that non-detect data were correctly reported (e.g., non-detect fractions of Hg were not reported as zero). The commenter recommends that the EPA review the data to ensure that (1) where method quantitation limits are known, data below method quantitation limits are properly identified and treated as less than values, and (2) where method detection and quantitation limits are not known, studies are carried out expeditiously so that all the data below method quantitation limits are treated appropriately. Commenter recommends that no numerical emission standard for a pollutant be set below the measurement ability of the reference test method, i.e., its quantitation limit.
19. Commenter 17725 states that their review of the data shows that there still may be problems with the emissions data and some of the data conversion procedures used by the EPA in the floor analysis. Commenter is concerned because the EPA seems to have done little to check these results or its calculations. For example, a number of sources appear to have failed to report emission results for all ten of the non-Hg HAP metals required under the ICR. However, when it calculated total non-Hg metal values, the EPA appears to have ignored this issue and just summed the results regardless of whether they represented a complete total. Eighteen of the total metals results that the EPA included in its floor analysis for existing coal-fired units were missing various components. Obviously, the EPA should have excluded these incomplete results from its total metals floor analysis.
20. Commenters 17725 and 18498 state that due to reporting inconsistencies, output based standards for existing units are flawed based on incorrect assumptions for GHR. The commenter provides tables illustrating the problems. According to the commenters, the following subcategories suggest GHR values that are unrealistically high or low based on expected boiler performance: Mercury Standard for Coal-Fired Unit >= 8,300 Btu/lb Subcategory; Total and Individual Metals Standards for Solid Oil-Derived Fuel Fired Units; Mercury and Individual Metals Standards for Liquid Oil-Fired Units; Total PM and HCl Standards for IGCC Units. Commenters recommend recalculating the ICR data on an output basis using a tiered approach depending on data availability and suggests alternative approaches.
21. Commenter 17736 states that the EPA's data collection was incomplete resulting in fundamental flaws and irrational determinations in the proposed rule. Additional errors include heat rate errors at different units- R.E. Burger Units 5 and 6 in Ohio are among those misrepresented - resulting in overly stringent emissions limits.
According to the commenter, scrubber installation estimates are inconsistent. The EPA assumed 36 months in this rulemaking, but 27 months in the proposed Transport Rule. These inconsistencies raise concerns as to whether the EPA has information sufficient to rationally consider installation timelines. The EPA also failed to account for the time needed to permit prior to construction. Therefore, the commenter suggests that the EPA expand the quantity and quality of the data reviewed in order to facilitate a more realistic consideration of the cost, development timeline, and performance of emission control systems for the final rule.
22. Commenter 17739 states that the EPA is subject to the specific data quality obligations under the Information Quality Act (IQA), and the EPA's IQA Guidelines entitled "Guidelines for Ensuring and Maximizing Data Quality, Objectivity, Utility, and Integrity of Information Disseminated by the Environmental Protection Agency (Oct. 2002)." Since the MACT proposal meets the definition of "influential information" it is "subject to a higher degree of quality (for example, transparency about data and methods) than [other] information. . . .," The EPA IQA Guidelines state that the EPA will ensure the data it uses are, "as a matter of substance," "accurate, reliable, and unbiased." In order to meet these requirements, the EPA must undertake reasonable and competent efforts to conduct a QA/QC analysis of its rulemaking data. Failure to adhere to the most basic elements of its own practices and procedures governing data quality would simply be arbitrary.
23. Commenter 17739 states that it must not be the sole or principal responsibility of outside parties to find and correct errors in the EPA data, particularly when it is clear that some serious errors can be and were introduced by the EPA itself. If the EPA has found and corrected any errors, it is not reflected in the docket, which appears to document only a single instance (EPA-HQ-OAR-2009-0234-3024) in which the EPA attempted to reconcile discrepancies between Part II and Part III data. The EPA should either add to the docket any documentation of inquiries it made to reconcile potential data quality errors and how they were resolved, or acknowledge that no such corrections were made. Nor is it incumbent upon the commenter to determine why certain data were excluded from the EPA's analyses. Commenter asserts that it is incumbent upon the EPA to evaluate those data and explain why they were not used, and to do similar analyses and provide explanation if data were excluded for the other HAP and HAP surrogates.
24. Commenter 17740 states that the proposed rule suggests that the EPA made a number of errors in developing the proposed MACT standards. For example, the proposed emissions standard for total HAP metals for new liquid oil-fired units appears to be less stringent than the proposed emissions standard for total HAP metals for existing liquid oil-fired units. Such a result should not be possible.
25. Commenter 17770 refers to comments submitted by RMB on the total PM limit.
26. Commenter 17772 states that ten out ten best performers fail the new facility Hg standard of 0.000010 lb/GWh as published. It appears that a decimal point got moved in the process of publishing the standard and other errors may also exist in establishing that standard. Also, the best performing unit used to set the new and existing facility standards for arsenic and lead, as well as the existing standard for manganese for units that burn coal greater than 8,300 Btu/lb actually burns lignite.
27. Commenter 17812 states that D/F sampling and analytical methods offer unique challenges. The commenter described the D/F data reported for one unit where every congener in each test run was either reported as non-detect of a value flagged with a "J" qualifier. Some were labeled "EMPC." Both flags indicate a high degree of uncertainty with the data at such low levels found in coal-fired boiler stacks. Some D/F congeners were also detected in the field blank indicating background levels of D/F casting further doubt and uncertainty on the reported analyte concentrations.
28. Commenter 17820 states that detailed review of the EPA risk assessment performed by EPRI indicates significant technical issues that raise serious question about whether HAP emissions from coal-fired power plants pose such risk. The commenter noted that EPRI identified several errors in unit stack parameters.
29. Commenter 17871 states that heat rate errors exist in MACT calculations for all HAP groupings for IGCC, liquid oil and petroleum coke units. In addition, transcription errors, data assignment errors and a lack of outlier quality control are all present in the spreadsheets used by the EPA to calculate the MACT floors.
30. Commenter 17877 endorses EPRI's technical review of the ICR data and encourages the EPA to consider its findings and take the time to re-propose the limits.
31. Commenter 17912 states that despite the admitted errors in certain floor calculations, the EPA has refused to withdraw the proposal and make the corrections. This deprives stakeholders of the opportunity to comment on the corrected provisions as required by the Administrative Procedures Act and the CAA.
32. Commenter 17914 listed their major concerns with the ICR data used by the EPA. In several instances, the data used to set the proposed floor limits are reported as being below the detection limit. Standard practice in science and engineering is to not use data below detection limits. These values should not be used in the calculation of the floor limits.
The commenter is concerned about the validity of the data submitted to the EPA and the number of errors that may be present based on their initial review. These concerns include the following examples: there were more than 150 duplicate Submittal ID numbers; there were different Facility ID numbers associated with a single facility; data was entered in numerous tables in text fields; field test reports are not available to review data submitted for two of the three "Top Performer" plants; there are many cases of multiple boilers providing flue gas to a common stack being treated as individual sources.
33. Commenter 18014 states that the output based standards for existing units are based on incorrect assumptions for GHR. In the emissions floor calculation, the EPA determines GHR based on the "maximum heat input capacity" and "gross (summer) generating capacity" as reported in Part I of the ICR for the individual boilers and uses this value to convert reported emissions on the basis of heat input to unit output. Due to reporting inconsistencies, these values are not necessarily equivalent to the "design gross heat rate", which the EPA assumed in the data conversion procedure. These issues resulted in several output standards that are fundamentally flawed and inconsistent with the equivalent input standards.
The commenter recommends that the ICR data be recalculated on an output basis using a tiered approach depending on data availability. In most cases, measured emissions can be converted directly to output units based on the stack flows and gross generation at the time of the stack test. Alternatively, a representative GHR value could be derived based on the most recent stack test conducted under representative conditions for which the necessary data are available (e.g., gross generation, stack flow, CO2/O2). This value could then be applied to the calculated input-based emissions value. Although design GHR data is available in the Part II ICR database, this value is not recommended to be used without further review because of the potential for reporting inconsistencies.
34. Commenter 18034 states that there is a discrepancy in the Sandow Unit 5B data used to determine the existing unit MACT floor.
35. Commenter 18034 states the proposed new unit limit for SO2 for pet-coke EGUs is based on the unit at5Hanford (ORIS code 10373), which is five to ten times smaller than a typical new pet-coke EGU and only slightly larger than the 25 MW threshold for applicability to the Utility NESHAP rule. The commenter questions the representativeness of the emissions from a 27 MW unit compared to units of 150 MW to more than 300 MW. Furthermore, the EPA's MACT analysis for acid gas limits for pet-coke units is counter-intuitive and contrary to the EPA's claims supporting the SO2 surrogacy. AES Deepwater (ORIS code 10670) is used to set the new unit HCl MACT floor. AES Deepwater HCl emissions are almost 30 times lower than the Hanford unit used to set the SO2 new unit MACT floor. However, the SO2 emissions from AES Deepwater are almost 30 times higher than Hanford's SO2 emissions despite the fact that AES Deepwater is equipped with wet FGD and Hanford has no SO2 controls installed. These facts indicate that other factors are affecting the acid gas emissions from pet-coke units that the EPA has not considered. In addition, the EPA is using a unit that is not equipped with FGD to set the SO2 surrogate limit which is contrary to the proposed rule requirement that a unit must be equipped with FGD to qualify for the SO2 surrogate limit.
According to the commenter, the EPA is arbitrarily accepting the mathematical results of the MACT floor analyses without questioning whether the results make sense. Sound science must be applied when establishing emission limits and is critical when evaluating a very small population of units such as the pet-coke EGUs.
36. Commenter 17881 states that as part of their participation in the CAA section 114 2010 ICR, the commenter was granted approval by the EPA to test at the combined stack of Units 1 and 2 with both units in operation, as testing only one unit is not possible due to the stack configuration. The commenter states that the information for the JH Campbell site is correct, with the exception of the table fuels_boiler_information, for submittal ID 2241. The commenter believes the boiler_ID should be JHC2-conf.
Response to Comment 6, items 1-36: These errors have been corrected in the final database.
Although the EPA relies on the primary oversight of testing quality by the source and their test contractor, we recognize that the data quality objectives of the source and test contractor may not be consistent with the uses which we intend. For the test data which were provided in the Phase II ICR, we recognized that the data were collected for several different purposes including but not limited to compliance assessment, CAM monitoring development testing and engineering assessment. For the test data which was conducted as a result of the Phase III ICR, we developed specific guidelines for the conduct of the tests that would result in the delivery of data that provided more beneficial information than we would otherwise be able to obtain. As a result, we specified test methods, test durations, and analytical techniquesthat expanded the information on HAP pollutant emissions normally obtained, improved the analytical detection levels and improved the consistency of measurements between sources. As evidenced by several commenters, we provided additional support to sources and their contractors as they identified issues that challenged to performance of these tests. Upon receiving many of the test reports we also identified situations where the respondent did not follow the guidelines that we provided in the ICR and/or did not perform the emissions test as described in the published method. We also identified that in some instances source testers appeared to be highly cognizant of the importance of this data to the source and the agency and performed the testing as the method and our guidelines indicated and provided the documentation to support their work. In reviewing both of the data sets, we assessed the limitations that existed in using the data for selecting the best performing source or the best performing 12% of the sources and for calculating the numerical limits associated with these two categories. We used some existing procedures for accommodating data limitations based upon the development of other NSPS, NESHAP and MACT emissions standards. Where there were situations where existing procedures were not sufficient or acceptable we made adjustments to the existing procedures, developed alternate procedures or excluded the data. We are confident that we have properly assessed the limitations that exist in the data supplied to us by the utility industry, developed procedures which address the limitations and have used the data to establish emissions limitations that are representative of the best performing source and the average of the best performing 12 percent of the sources.
Comment 6 (cont.):
37. Commenter 17739 states that the EPA made the following errors:
   * For AES Hawaii Units A & B (ORIS 10673), the sampling reports (docket EPA-HQ-OAR-2009-0234-0204 and EPA-HQOAR- 2009-0234-020) the emission measurements for AES Hawaii A &B are all marked as "BDL." For both units, all three sampling runs failed the data QA/QC check known as "Paired Trap Agreement." The unspiked trap failed the "Breakthrough Limit" check in all three sampling runs.

   * For Northampton Generating Unit 1 (ORIS 50888), it is not possible to assess the quality of the Part III emissions measurement data because the docket entry (EPA-HQ-OAR-2009-0234-2462) contains no QA/QC information; all QA/QC entries are marked as "n/a".

   * For AES Warrior Run Unit 1 (ORIS 10678), all three Hg sampling measurements for this unit (EPA-HQ-OAR-2009-0234-2699) failed the Volume Difference, Breakthrough Limit and Paired Trap Agreement QA/QC criteria.

   * For Cedar Bay Units CBB1, CBA1 and CBC1, the method 30B sampling volumes are listed in the QA/QC data as greater than 200 dscm. These are impossibly high volumes, suggesting a possible error in the sampling method or an error in reporting the data.

   * For Wisconsin Electric Valley Units 1,2 3, and 4, the sampling data in the docket (EPA-HQ-OAR-2009-0234-1354, -1355, 1356 and 1357, respectively) reveal negative values for the mercury mass in the second sorbent tubes for Units 1, 3 and 4. For Unit 4, all six of the sorbent tubes are reported to contain negative masses. These values make it impossible to conduct a meaningful breakthrough test, and call into question the values reported for the first sample tubes.
Response to Comment 6, item 37: The EPA has conducted a review of the commenter's cited data  and has made the following decisions on the validity of g these data.
The EPA has decided to continue to use the AES Hawaii Units A & B (ORIS 10673) Hg emissions data obtained by the Method 30B under Part III of the ICR. The data did not fail the "Paired Trap Agreement" criterion. The "Paired Trap Agreement" criterion is as follows: <10 percent RD mass for Hg concentrations > 1 ug/dscm, or < 20 percent RD mass for Hg concentrations or < 0.2 ug/dscm absolute difference for Hg concentrations < 1ug/dscm. Although the facility reported a "paired trap agreement" of 65, 56, and 100 percent for the 3 test runs, they also reported the absolute differences, which are 0.04, 0.04 and 0.01 ug/dscm; these absolute values meet the criterion. The test did fail the breakthrough limit for the unspiked traps for each test run, but not for the paired spiked traps. Failure of the breakthrough limit for the unspiked traps resulted because the limit is expressed as a percentage of the captured emissions; the emissions and the resulting mass collected on the trap are very low. The breakthrough limit was easily met for the spiked pair indicating that breakthrough was not a problem. Furthermore, the test met the measured spike recovery and the paired trap agreement criteria. This is a performance-based method and a longer sampling time would have increased the measurable quantity on the unspiked trap so that all the performance criteria could be met. Although the test did not meet the breakthrough limit for the unspiked traps, the other QA/QC results indicate the results are valid. Although these data do not meet all the Method 30B criteria, we believe they are of adequate quality to be included in the MACT floor. They could likely have met the criteria if they tested for a longer time, and they will need to do that when determining compliance.
The EPA has decided to continue to use the Northampton Generating Unit 1 (ORIS 50888) Hg emissions data obtained by the Method 30B under Part III of the ICR. The facility submitted these data and certified the results and therefore EPA believes that these data should be included in the Hg MACT floor data set. To determine the impact on the Hg floor, EPA removed the Northampton data and substituted the next unit in the 47-unit Hg MACT floor. This resulted in no change for the >8,300 Btu lb/MMBtu (Subcategory 1) Hg floor. Since there is no impact for dropping these results and using the next facility on the list, removing the data is a moot point. Finally, even though the QA/QC data are not present, the facility states in their emissions test report that they followed the method and met its requirements. This company will need to show their QA/QC data when they determine compliance under the rule.
The EPA has decided to continue to use the AES Warrior Run Unit 1 (ORIS 10678) Hg emissions data obtained by the Method 30B under Part III of the ICR. The tests did not fail the "volume difference" criterion; the results in the spreadsheet were incorrectly calculated (multiplier of 1000 was used instead of 100 to convert fraction to percent). The tests did not fail the paired trap agreement criterion. As indicated for the AES Hawaii unit, the criterion is < 0.2 ug/dscm absolute difference for Hg concentrations < 1 ug/dscm. All three test runs have reported concentrations of < 1 ug/dscm and met the criterion. For two of the runs the unspiked traps failed the breakthrough criterion based on a percentage of the mass collected, but breakthrough obviously was not a problem as demonstrated by the breakthrough limit calculation for the spiked traps (collected concurrently).Although these data do not meet all the Method 30B criteria, we believe they are of adequate quality to be included in the MACT floor. They could likely have met the criteria if they tested for a longer time, and they will need to do that when determining compliance.
The EPA has decided to continue to use the Cedar Bay Units CBB1, CBA1 and CBC1, Hg emissions data obtained by the Method 30B under Part III of the ICR. The error cited by the commenter is simply in the units listed in the heading for the sample volume. The heading indicates "dscm," but the facility obviously reported the volume as liters and should have changed the heading. The reported concentration in ug/dscm (i.e., ug/L) is not correct as the equation should not have divided by 1000. Regardless, the reported lb/MMBtu presented in this data form is a direct entry and is not directly calculated from the data in the QA/QC section of the spreadsheet. The reported lb/MMBtu is the value used for the ICR data base and subsequent floor calculations. Using the volume reported as liters, the calculated concentrations (ug/dscm) are consistent with the reported concentrations for other units with similar emissions rates, lb/MMBtu. Since the error is simply in the units in the heading used for the sample volume, EPA has decided to use these emissions data.
The EPA has decided to use some of the Wisconsin Electric Valley Unit's 1, 2, 3, and 4's Hg emissions data obtained by the Method 30B under Part III of the ICR and to not use other of the data submitted. The data from the 1[st] unit tested, Unit 2, will not be included based upon the improper default value used as well as the small sample volumes and high calibration levels. Even though the results from the proper estimated values are similar and consistent with the other units tested, they are not estimates of sufficient confidence to be included. The other three units' data, while not perfect, are of sufficient quality to use with confidence. After the first tests on Unit 2, the testers made adjustments to the test approach, including further lowering their calibration curve, decreasing the trap spike quantity, and increasing the sample volume. The commenter's basis for invalidating the data is based on negative values being reported for the 2[nd], breakthrough section. However, for all cases, the negative values were treated as zeroes, which is not disallowed by the Method. Since these negative values are very small, and are treated as zeroes in all calculations, the resulting data are indeed valid.
Comment 6 (cont.):
38. Commenter 17739 states that the EPA made the following errors: In a spreadsheet entitled "List of facility/unit Hg stack emission averages from the EGU MACT ICR Parts II and Part III" posted to the docket on 6/30/2011, the AES Somerset Unit 001 (a 681 MW unit, with a listed heat input of 6,280 MMBtu/hr) is shown as having a mercury emission rate of 0.132 lb/MMBtu. If this is true, the AES Somerset unit must emit approximately 3000 ton of mercury per year, which is clearly impossible. Similarly, the revised mercury MACT floor spreadsheet posted to the docket on 5/18/2011 reports a mercury content of 65.5 lb/MMBtu for the coal refuse used by the Ebensburg Power Company (one of EPA's top 40 plants). If this were true, the Ebensburg fuel would contain about 33% mercury by weight.
Response to Comment 6, item 38: These errors have been corrected these data in the final database.
Comment 7: Commenter 17739 states that the EPA handling of the PM data is confusing, because the EPA appears to have ignored much of the data it presented in the MACT floor spreadsheet, and did not ensure that its synthetic "Total PM" values represent any real emission level. The commenter states: Although not explained in the tables or the MACT Floor memo by RTI, it appears that the EPA calculated total particulate by adding the lowest value found in the first of the five columns of filterable particulate data and the lowest value found in the four columns of condensable particulate data, then comparing that sum to the value obtained by summing the filterable and condensable data from the Part II columns (which we assume are the minimum Part II values if other Part II data were available to EPA for these units in Part II). The EPA then chose the lower of these two synthetic "Total Particulate" values from either Part II or Part III for use in ranking the units, and calculating the MACT floor average. As discussed above, the EPA also used only these minima value in calculating the UPL, thus ignoring all other Part II and Part III data. The following needs to be explained by the EPA:
1. The first two columns of filterable particulate data have identical headings. How do they differ and why did the EPA choose to show them separately?
2. The fifth column of filterable particulate data ("Filterable Particulate _OTM_27/28_ERT") was never used in determining the total particulate values or in the UPL calculation. What reason does the EPA have for ignoring these data?
3. The middle column of the Part II data ("PM (Filterable and Condensable)  -  Part II") also was ignored in the MACT floor calculation. What reason does the EPA have for ignoring these data?
4. The "Total PM" value that the EPA used in the MACT floor calculation is a synthetic value, being the sum of lowest individual measurements of filterable and condensable particulate for each unit obtained in Part III of the information collection request or the lowest value similarly obtained in Part II. It is possible, therefore, that these paired filterable and condensable measurements from either were not done simultaneously and might represent emissions at different periods of time. If so, the synthetic "Total PM" value will of necessity be erroneously low. It would also be unlawful to use in the floor calculation, as the combined value was never actually "achieved." Did the EPA ensure that only simultaneous emission measurements were used to calculate total PM. The EPA also needs to describe the quality control procedures employed to ensure this result.
Response to Comment 7: The EPA has explained in detail in docket item EPA-HQ-OAR-2009-0234-13056 how the total PM values were calculated for the proposed rule. As noted elsewhere in this document, the EPA is now finalizing a filterable PM surrogate standard for non-Hg metallic HAP.
The EPA recognizes that the lack of documentation associated with the spreadsheet made reconstructing this data by commenters difficult and confusing. Although it may appear that the lowest Total PM data was selected, this is primarily due to the preferential selection of data collected under the Part III ICR rather than selection of data collected under Part II. The EPA recognizes that filterable particulate testing with Method 29 revealed that some potential high biases may be associated with EPA Method 5 or 17 due to the use of glass fiber filters that do not meet Method 5 or Method 17 filter selection specifications. The EPA also recognizes essentially all of the Part II condensable data were poorly documented and likely used one of the procedures allowed by the 1990 promulgated Method 202 that produce the more biased results. Because the Agency has choosen to use filterable particulate as the surrogate for non-mercury metal HAP emissions, these comments are moot.
4. NEEDS data base.
Comment 8: Commenter 17843 states that states have previously submitted data updates to the EPA for the NEEDS database in response to a Notice of Data Availability (NODA) for the proposed Transport Rule (75 FR 53613-53615). These state-supplied updates, however, do not appear to have been incorporated into this rulemaking. The NESCAUM states would like to work with the appropriate EPA staff to ensure that inclusion of submitted state data reflecting the most current information on emission sources are incorporated into the NEEDS database on a more expedited basis.
Response to Comment 8: With regard to source specific comments at the model input stage (i.e., NEEDS), the EPA did make source-specific updates to its IPM model. These comments were generally pointing out a discrepancy between a commenters understanding of a unit's current configuration, and how the units configuration is depicted in the EPA's National Electric Energy Data System (NEEDS) database. NEEDS is meant to reflect the current configuration (or configuration as of December 31, 2011) of the U.S. Power Sector and is the primary input for unit level data in the IPM v.4.10 modeling. Since NEEDS is an approximate snap shot of the power sector, the EPA was sensitive to comments that suggested this depiction was not consistent with the current configuration as observed by the commenter. The EPA reviewed NEEDS in light of these comments and made updates accordingly.
Note that only those updates that would impact the modeling results for affected units, such as existence of pollution controls, were implemented. Updates that are expected to have minimal or no impacts on the modeling results, such as scrubber online years prior to 2015, were not incorporated into the final modeling for this rule. Overall, any limited differences in projected impacts that might result from implementation of any NEEDS-based comments that were not incorporated would not materially change the overall impacts of the final rule that the EPA is estimating, nor would they fundamentally change the requirements of the rule. The EPA projections of the power sector impacts are intended to be a reflection of possible compliance using specific tools, assumptions, and methodologies that the agency believes to reflect the best and most current information related to the power sector. It is not intended to reflect actual compliance decisions, since those will be made individually be the affected industry based on what makes most sense using existing technologies or other, more cost-effective strategies.
The EPA thanks commenters for providing this information, and the EPA intends to incorporate this new information in subsequent updates of the modeling.
Comment 9: Commenter 16513 states that the EPA failed to incorporate its comments on the EPA base case and NEEDS database and that the EPA should incorporate all of the changes made by states to the base case and NEEDS or explain why they were not.
Commenter 17627 states that the data in the NEEDS database is not correct and, thus, the IPM model output is also incorrect, which directly impacts the proposed EGU MACT rule. The commenter requests that the EPA correct the database and provides the corrections that should be made.
Response to Comment 9: With regard to source specific comments at the model input stage (i.e., NEEDS), the EPA did make source-specific updates to its IPM model. These comments were generally pointing out a discrepancy between a commenters understanding of a unit's current configuration, and how the units configuration is depicted in the EPA's NEEDS database. NEEDS is meant to reflect the current configuration (or configuration as of December 31, 2011) of the U.S. Power Sector and is the primary input for unit level data in the IPM v.4.10 modeling. Since NEEDS is an approximate snap shot of the power sector, the EPA was sensitive to comments that suggested this depiction was not consistent with the current configuration as observed by the commenter. The EPA reviewed NEEDS in light of these comments and made updates accordingly. Note that only those updates that would impact the modeling results for affected units, such as existence of pollution controls, were implemented. Updates that are expected to have minimal or no impacts on the modeling results, such as scrubber online years prior to 2015, were not incorporated into the final modeling for this rule. Overall, any limited differences in projected impacts that might result from implementation of any NEEDS-based comments that were not incorporated would not materially change the overall impacts of the final rule that the EPA is estimating, nor would they fundamentally change the requirements of the rule. The EPA projections of the power sector impacts are intended to be a reflection of possible compliance using specific tools, assumptions, and methodologies that the agency believes to reflect the best and most current information related to the power sector. It is not intended to reflect actual compliance decisions, since those will be made individually be the affected industry based on what makes most sense using existing technologies or other, more cost-effective strategies.
The EPA thanks commenters for providing this information, and the EPA intends to incorporate this new information in subsequent updates of the modeling.
Comment 10: Commenter 17857 states that the following errors were found in the EPA's NEEDSv41O_PTox file database:
:: The Alloy Steam Station (ORIS ID 50012) is not an electric generating unit, it is a coal-fired boiler at an industrial facility that produced electricity for use in-house, not for distribution on the grid and should not be included as an electric generating unit for the purposes of this rule. The Alloy Steam Station BLR4 shut down as of 10/26/2007.
:: Mount Storm (ORIS 3954) Unit JF1 is a 215.3 MMBtu/hr combustion turbine emergency generator that was installed in 1967 and does not produce electricity for sale, and should not be included as an electric generating unit for the purposes of this rule.
Column X - Scrubber Online Year:
:: The scrubbers on Ft. Martin (ORIS 3943) Units 1 and 2 did not come online in 2006, they came online 10/3112009 and 8/26/2009, respectively.
:: John E. Amos (ORIS 3935) Units 2 and 3 are equipped with wet scrubbers which came online 11/11/2010 and 2/1/2009, respectively. These scrubbers are required by paragraph 87 of the federal AEP Consent Decree (Civil Action No. C2-99-1182).
Column Y - Scrubber_Efficiency:
:: The NEEDS database indicates that the John E. Amos (ORIS 3935) Units 2 and 3 scrubbers have a 50 percent control efficiency, the correct scrubber efficiency is 95 percent.
Column AD - PM Controls:
:: The NEEDS database indicates that Longview (ORIS 56671) has ESPC+B for PM control, Longview is not equipped with an ESP, it is equipped only with a baghouse (B).
Column AI - SO2 Permit Rate (lb/MMBtu):
:: The SO2 Permit Rate for Longview (ORIS 56671) is given as 3.1 lb/MMBtu, however the correct permit rate is 0.095 lb/MMBtu on a calendar year average basis (Section 5.1.3 of permit R14-0024D).
:: The SO2 Permit Rate for the Big Sandy Peaker Plant (ORIS 55284) is given as 2.7 lb/MMBtu, however the correct SO2 Permit Rate is 0.00227 lb/MMBtu for each of the 12 turbines, with two (2) turbines feeding each of the six (6) generators (Permit R30-09900080-2009).
:: The SO2 Permit Rate for Pleasants Energy LLC (ORIS 55349) is given as 2.7 lb/MMBtu, however the correct SO2 Permit Rate is 0.00159lb/MMBtu for each of the two (2) turbines (Permit R30-073-00022-2009).
:: The SO2 Permit Rate for Ceredo Generating Station (ORIS 55276) is given as 2.7 lb/MMBtu, however the correct SO2 Permit Rate is 0.004121b/MMBtu for each of the six (6) turbines (Permit R30-09900081-2008).
:: The SO2 Permit Rate for Kanawha River (ORIS 3936) is given as 1.75 Ib/MMBtu, however the correct SO2 Permit Rate is 1.6 Ib/MMBtu, as specified in 45CSR10, section 3.2.b.
Columns AJ, AK, Al and AM - Uncontrolled NOX Base Rate (lb/MMBtu); Controlled NOX Base
Rate (lb/MMBtu); Uncontrolled NOX Policy Rate (lb.MMBtu); and Controlled NOX Policy Rate (lb/MMBtu):
:: The permitted NOX rate for Longview (ORIS 56671) is 0.0650 Ib/MMBtu (Section 5.1.2 of permit R14-0024D).
:: The permitted NOX rate for Big Sandy Peaker Plant (ORIS 55284) is 0.1038 Ib/MMBtu for each of the 12 turbines, with two (2) turbines feeding each of the six generators.
:: The permitted NOX rate for Pleasants Energy LLC (55349) is 0.04137Ib/MMBtu for each of the two (2) turbines.
:: The permitted NOX rate for Ceredo Generating Station (ORIS 55276) is 0.03292 lb/MMBtu for each of the six turbines.
Column AN - HG EMF Inputs:
:: John E. Amos (ORIS 3935) Units 1 and 2 should include wet scrubbers, in addition to the Cold-side ESP + SCR.
:: Fort Martin Power Station (ORIS 3943) Units 1 and 2 should include wet scrubbers in addition to Cold-side ESP + SNCR.
:: Harrison Power Station (ORIS 3944) Units 1, 2 and 3 should include wet scrubbers in addition to Cold-side ESP + SCR.
:: Longview (ORIS 56671) is equipped with a Fabric Filter + SCR + Wet Scrubber, but does not include a Cold-side ESP.
Columns AO, AP, and AQ - Controlled Hg EMF for BIT, Controlled Hg EMF for SUB and Controlled Hg EMF for LIG:
:: Longview (ORIS 56671) has a permit limit (Section 5.1.9 of Perm it R14-0024D) for Hg of 0.01461blhr (3 hr averaging time), and 0.0638 tpy (12 month rolling average). Longview has a permitted maximum hourly heat input of 6.114 MMBtu (Section 5.1.1), which equates to a Hg permit limit of 0.00239 lb/MMBtu.
:: The controlled Hg EMFs for John E. Amos (ORIS 3935) Units 1, 2 and 3, Fort Martin Power Station (ORIS 3943) Units 1 and 2, and Harrison Power Station (ORIS 3944) Units 1, 2 and 3 should reflect the fact that they are all equipped with wet scrubbers.
Response to Comment 10: With regard to source specific comments at the model input stage (i.e., NEEDS), the EPA did make source-specific updates to its IPM model. These comments were generally pointing out a discrepancy between a commenters understanding of a unit's current configuration, and how the units configuration is depicted in the EPA's NEEDS database. NEEDS is meant to reflect the current configuration (or configuration as of December 31, 2011) of the U.S. Power Sector and is the primary input for unit level data in the IPM v.4.10 modeling. Since NEEDS is an approximate snap shot of the power sector, the EPA was sensitive to comments that suggested this depiction was not consistent with the current configuration as observed by the commenter. The EPA reviewed NEEDS in light of these comments and made updates accordingly. Note that only those updates that would impact the modeling results for affected units, such as existence of pollution controls, were implemented. Updates that are expected to have minimal or no impacts on the modeling results, such as scrubber online years prior to 2015, were not incorporated into the final modeling for this rule. Overall, any limited differences in projected impacts that might result from implementation of any NEEDS-based comments that were not incorporated would not materially change the overall impacts of the final rule that the EPA is estimating, nor would they fundamentally change the requirements of the rule. The EPA projections of the power sector impacts are intended to be a reflection of possible compliance using specific tools, assumptions, and methodologies that the agency believes to reflect the best and most current information related to the power sector. It is not intended to reflect actual compliance decisions, since those will be made individually be the affected industry based on what makes most sense using existing technologies or other, more cost-effective strategies.
The EPA thanks commenters for providing this information, and The EPA intends to incorporate this new information in subsequent updates of the modeling.