[Federal Register Volume 85, Number 38 (Wednesday, February 26, 2020)]
[Notices]
[Pages 11079-11082]
[FR Doc No: 2020-03866]

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ENVIRONMENTAL PROTECTION AGENCY

[EPA-HQ-OPPT-2019-0500; FRL-10005-52]

Trichloroethylene; Draft Toxic Substances Control Act (TSCA) Risk
Evaluation and TSCA Science Advisory Committee on Chemicals (SACC)
Meetings; Notice of Availability, Public Meetings, and Request for
Comment

AGENCY: Environmental Protection Agency (EPA).

ACTION: Notice.

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SUMMARY: EPA is announcing the availability of and soliciting public
comment on the draft Toxic Substances Control Act (TSCA) risk
evaluation of trichloroethylene (TCE). EPA is also submitting the same
document to the TSCA Science Advisory Committee on Chemicals (SACC) for
peer review and is announcing that there will be an in-person public
meeting of the TSCA SACC to consider and review the draft risk
evaluation. Preceding the in-person meeting, there will be a
preparatory virtual public meeting for the panel to consider the scope
and clarity of the draft charge questions for the peer review. The
purpose of conducting risk evaluations under TSCA is to determine
whether a chemical substance presents an unreasonable risk of injury to
health or the environment under the conditions of use, including an
unreasonable risk to a relevant potentially exposed or susceptible
subpopulation.

DATES:
    Virtual Meeting: The preparatory virtual meeting will be held on
March 3, 2020, from 1:00 p.m. to approximately 4:00 p.m. (EST). You
must register online on or before March 3, 2020 to receive the webcast
meeting link and audio teleconference information. Submit your comments
for the preparatory virtual meeting, or request time to present oral
comments, on or before noon, February 28, 2020.
    In-Person Meeting: The in-person meeting will be held on March 24-
26, 2020, from 8:00 a.m. to approximately 5:30 p.m. (EST) (final times
for each day will be provided in the meeting agenda that will be posted
in the docket at http://www.regulations.gov and the TSCA SACC website
at http://www.epa.gov/tsca-peer-review). Any comments submitted on the
draft risk evaluation on or before March 18, 2020, will be provided to
the TSCA SACC committee for their consideration before the meeting.
Comments received after March 18, 2020 and prior to the oral public
comment period during the meeting will be available to the SACC for
their consideration during the meeting. Please submit requests to
present oral comments during the in-person meeting on or before March
18, 2020, to be included on the meeting agenda. All comments received
by the end of the comment period will be considered by EPA.
    Comments: All comments on the draft risk evaluation must be
received on or before April 27, 2020. For additional instructions, see
Unit III. of the SUPPLEMENTARY INFORMATION.

ADDRESSES:
    Virtual Meeting: Please visit http://www.epa.gov/tsca-peer-review
to register.
    In-Person Meeting: The location of the in-person meeting will be at
the Washington Plaza Hotel, 10 Thomas Circle NW, Washington, DC 20005.
    Comments. Submit your comments, identified by docket identification
(ID) number EPA-HQ-OPPT-2019-0500, by one of the following methods:
     Federal eRulemaking Portal: http://www.regulations.gov.
Follow the online instructions for submitting comments. Do not submit
electronically any information you consider to be Confidential Business
Information (CBI) or other information whose disclosure is restricted
by statute.
     Mail: OPPT Docket, Environmental Protection Agency Docket
Center (EPA/DC), (28221T), 1200 Pennsylvania Ave. NW, Washington, DC
20460-0001.
     Hand Delivery: To make special arrangements for hand
delivery or delivery of boxed information, please follow the
instructions at http://www.epa.gov/dockets/contacts.html.
    Additional instructions on commenting or visiting the docket, along
with more information about dockets generally, is available at http://www.epa.gov/dockets.
    Requests to present oral comments and requests for special
accommodations. Submit requests for special accommodations, or requests
to present oral comments during the virtual meeting and/or in-person
peer review meeting to the Designated Federal Official (DFO) listed
under FOR FURTHER INFORMATION CONTACT by the deadline identified in the
DATES section.

FOR FURTHER INFORMATION CONTACT: TSCA SACC: Dr. Todd Peterson, DFO,
Office of Science Coordination and Policy (7201M), Environmental
Protection Agency, 1200 Pennsylvania Ave. NW, Washington, DC 20460-
0001; telephone number:<PHONE_NUMBER>; email address:
<EMAIL_ADDRESS>

    Draft Risk Evaluation: Dr. Stan Barone, Office of Pollution
Prevention and Toxics (7403M), Environmental Protection Agency, 1200
Pennsylvania Ave. NW, Washington, DC 20460-0001; telephone number:
(202) 564-1169; email address<EMAIL_ADDRESS>
SUPPLEMENTARY INFORMATION:

I. General Information

A. Does this action apply to me?

    This action is directed to the public in general. This action may
be of interest to persons who are or may be required to conduct testing
and those interested in risk evaluations of chemical substances under
TSCA, 15 U.S.C. 2601 et seq. Since other entities may also be
interested in this draft risk evaluation, the EPA has not attempted to
describe all the specific entities that may be affected by this action.

B. What is EPA's authority for taking this action?

    TSCA section 6, 15 U.S.C. 2605, requires EPA to conduct risk
evaluations to ``determine whether a chemical substance presents an
unreasonable risk of injury to health or the environment, without
consideration of costs or other nonrisk factors, including an
unreasonable risk to a potentially exposed or susceptible subpopulation
identified as relevant to the risk evaluation by the Administrator,
under the conditions of use.'' 15 U.S.C. 2605(b)(4)(A). TSCA sections
6(b)(4)(A) through (H) enumerate the deadlines and minimum requirements
applicable to this process, including provisions that provide
instruction on chemical substances that must undergo evaluation, the
minimum components of a TSCA risk evaluation, and the timelines for
public comment and completion of the risk evaluation. TSCA also
requires that EPA operate in a manner that is consistent with the best
available science, make decisions based on the weight of the scientific
evidence and consider reasonably available information. 15 U.S.C.
2625(h), (i), and (k).
    The statute identifies the minimum components for all chemical
substance risk evaluations. For each risk evaluation, EPA must publish
a document that outlines the scope of the risk evaluation to be
conducted, which includes the hazards, exposures, conditions of use,
and the potentially exposed or susceptible subpopulations that EPA
expects to consider. 15 U.S.C. 2605(b)(4)(D). The statute further
provides that each risk evaluation must also: (1) Integrate and assess
available information on hazards and exposures for the conditions of
use of the chemical substance, including information that is relevant
to specific risks of injury to health or the environment and
information on relevant potentially exposed or susceptible
subpopulations; (2) describe whether aggregate or sentinel exposures
were considered and the basis for that consideration; (3) take into
account, where relevant, the likely duration, intensity, frequency, and
number of exposures under the conditions of use; and (4) describe the
weight of the scientific evidence for the identified hazards and
exposures. 15 U.S.C. 2605(b)(4)(F)(i)-(ii) and (iv)-(v). Each risk
evaluation must not consider costs or other nonrisk factors. 15 U.S.C.
2605(b)(4)(F)(iii).
    The statute requires that the risk evaluation process last no
longer than three years, with a possible additional six-month
extension. 15 U.S.C. 2605(b)(4)(G). The statute also requires that the
EPA allow for no less than a 30-day public comment period on the draft
risk evaluation, prior to publishing a final risk evaluation. 15 U.S.C.
2605(b)(4)(H).

C. What action is EPA taking?

    EPA is announcing the availability of and seeking public comment on
the draft risk evaluation of the chemical substance identified in Unit
II. EPA is seeking public comment on all aspects of the draft risk
evaluation, including any preliminary conclusions, findings, and
determinations, and the submission of any additional information that
might be relevant to the draft risk evaluation, including the science
underlying the risk evaluation and the outcome of the systematic review
associated with the chemical substance. This 60-day comment period on
the draft risk evaluation satisfies TSCA section 6(b)(4)(H), which
requires EPA to ``provide no less than 30 days public notice and an
opportunity for comment on a draft risk evaluation prior to publishing
a final risk evaluation'' and 40 CFR 702.49(a), which states that ``EPA
will publish a draft risk evaluation in the Federal Register, open a
docket to facilitate receipt of public comment, and provide no less
than a 60-day comment period, during which time the public may submit
comment on EPA's draft risk evaluation.'' In addition to any new
comments on the draft risk evaluation, the public should resubmit or
clearly identify any previously filed comments, modified as
appropriate, that are relevant to the draft risk evaluation and that
the submitter feels have not been addressed. EPA does not intend to
respond to comments submitted prior to the release of the draft risk
evaluation unless they are clearly identified in comments on the draft
risk evaluation.
    EPA is also submitting the draft risk evaluation and associated
supported documents to the TSCA SACC for peer review and announcing the
meeting for the peer review panel. All comments submitted to the docket
on the draft risk evaluation by the deadline identified in the DATES
section will be provided for consideration to the TSCA SACC peer review
panel, which will have the opportunity to consider the comments during
its discussions.

D. What should I consider as I prepare my comments for EPA?

    1. Submitting CBI. Do not submit this information to EPA through
regulations.gov or email. Clearly mark the part or all of the
information that you claim to be CBI. For CBI information in a disk or
CD-ROM that you mail to EPA, mark the outside of the disk or CD-ROM as
CBI and then identify electronically within the disk or CD-ROM the
specific information that is claimed CBI. In addition to one complete
version of the comment that includes information claimed as CBI, a copy
of the comment that does not contain the information claimed as CBI
must be submitted for inclusion in the public docket. Information so
marked will not be disclosed except in accordance with procedures set
forth in 40 CFR part 2.
    2. Tips for preparing your comments. When preparing and submitting
your comments, see the commenting tips at http://www.epa.gov/dockets/comments.html.

II. Draft TSCA Risk Evaluation

A. What is EPA's risk evaluation process for existing chemicals under
TSCA?

    The risk evaluation process is the second step in EPA's existing
chemical process under TSCA, following prioritization and before risk
management. As this chemical is part of the first ten chemical
substances undergoing risk evaluation, the chemical substance was not
required to go through prioritization (81 FR 91927, December 19, 2016)
(FRL-9956-47). The purpose of conducting risk evaluations is to
determine whether a chemical substance presents an unreasonable risk of
injury to health or the environment, under the conditions of use,
including an unreasonable risk to a relevant potentially exposed or
susceptible subpopulation. As part of this process, EPA must evaluate
both hazard and exposure, not consider costs or other nonrisk factors,
use reasonably available information and approaches in a

manner that is consistent with the requirements in TSCA for the use of
the best available science, and ensure decisions are based on the
weight-of-scientific-evidence.
    The specific risk evaluation process that EPA has established by
rule to implement the statutory process is set out in 40 CFR part 702
and summarized on EPA's website at http://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-evaluations-existing-chemicals-under-tsca. As explained in the preamble to EPA's final rule on
procedures for risk evaluation (82 FR 33726, July 20, 2017) (FRL-9964-
38), the specific regulatory process set out in 40 CFR part 702,
subpart B will be followed for the first ten chemical substances
undergoing risk evaluation to the maximum extent practicable.

B. What is trichloroethylene?

    Trichloroethylene (TCE) has a wide-range of uses in consumer and
commercial products and in industry. An estimated 84% of TCE's annual
production volume is used as an intermediate in the manufacture of the
hydrofluorocarbon HFC-134a. Another 15% of TCE production volume is
used as a degreasing solvent, leaving approximately 1% for other uses.
The total aggregate production volume decreased from 220.5 to 171.9
million pounds between 2012 and 2015.
    Information about the problem formulation and scope phases of the
TSCA risk evaluation for this chemical is available at https://www.epa.gov/assessing-and-managing-chemicals-under-tsca/risk-evaluation-trichloroethylene-tce-0.

III. TSCA SACC

A. What is the purpose of the TSCA SACC?

    The TSCA SACC was established by EPA in 2016 and operates in
accordance with the Federal Advisory Committee Act (FACA), 5 U.S.C.
Appendix 2 et seq. The TSCA SACC provides expert independent scientific
advice and consultation to the EPA on the scientific and technical
aspects of risk assessments, methodologies, and pollution prevention
measures and approaches for chemicals regulated under TSCA.
    The TSCA SACC is comprised of experts in: Toxicology; human health
and environmental risk assessment; exposure assessment; and related
sciences (e.g., synthetic biology, pharmacology, biotechnology,
nanotechnology, biochemistry, biostatistics, physiologically based
pharmacokinetic modelling (PBPK) modeling, computational toxicology,
epidemiology, environmental fate, and environmental engineering and
sustainability). When needed, the committee will be assisted in their
reviews by ad hoc participants with specific expertise in the topics
under consideration.

B. How can I access the TSCA SACC documents?

    EPA's background documents, related supporting materials, and draft
charge questions to the TSCA SACC are available on the TSCA SACC
website and in the docket established for the specific chemical
substance. In addition, EPA will provide additional background
documents (e.g., TSCA SACC members participating in this meeting and
the meeting agenda) as the materials become available. You may obtain
electronic copies of these documents, and certain other related
documents that might be available, in the docket at http://www.regulations.gov and the TSCA SACC website at http://www.epa.gov/tsca-peer-review.
    After the public meeting, the TSCA SACC will prepare meeting
minutes summarizing its recommendations to the EPA. The meeting minutes
will be posted on the TSCA SACC website and in the relevant docket.

C. What do I need to know about the TSCA SACC public meetings?

    The focus of the public meetings is to peer review EPA's draft risk
evaluation. After the peer review process, EPA will consider peer
reviewer comments and recommendations and public comments, in
finalizing the risk evaluation. The draft risk evaluation contains:
Discussion of chemistry and physical-chemical properties;
characterization of conditions of use; environmental fate and transport
assessment; human health exposures; environmental hazard assessment;
risk characterization; risk determination; and a detailed description
of the systematic review process developed by the Office of Pollution
Prevention and Toxics to search, screen, and evaluate scientific
literature for use in the risk evaluation process.

D. How do I participate in the public meetings?

    You may participate in the public meetings by following the
instructions in this unit. To ensure proper receipt by EPA, it is
imperative that you identify the corresponding docket ID number in the
subject line on the first page of your request.
    1. Preparatory virtual meeting. The preparatory virtual meeting
will be conducted via webcast and telephone. You may participate in the
preparatory virtual meeting by registering to join the webcast. You may
also submit written or oral comments.
    i. Registration. You must register to participate in the
preparatory virtual meeting. To participate by listening or making a
comment during this meeting, please go to the EPA website to register:
http://www.epa.gov/tsca-peer-review. Registration online will be
confirmed by an email that will include the webcast meeting link and
audio teleconference information.
    ii. Written comments. Written comments for consideration during the
preparatory virtual meeting should be submitted, using the instructions
in ADDRESSES and this unit, on or before the date set in the DATES
section.
    iii. Oral comments. Requests to make brief oral comments to the
TSCA SACC during the preparatory virtual meeting should be submitted
when registering online or with the DFO listed under FOR FURTHER
INFORMATION CONTACT on or before noon on the date set in the DATES
section. Oral comments before the TSCA SACC during the preparatory
virtual meeting are limited to approximately 5 minutes due to the time
constraints of this virtual meeting.
    2. In-person meeting. You may participate in the in-person public
meeting by attending and by providing written or oral comments. The in-
person meeting may also be webcast. Please refer to the TSCA SACC
website at http://www.epa.gov/tsca-peer-review for information on how
to access the webcast. Please note that for the in-person meeting, the
webcast is a supplementary public process provided only for
convenience. If difficulties arise resulting in webcasting outages, the
in-person meeting will continue as planned.
    i. Seating at the meeting. Seating at the meeting will be open and
on a first-come basis.
    ii. Written comments. To provide the TSCA SACC the time necessary
to consider and review your comments, written comments must be
submitted by the date set in the DATES section and using the
instructions in the ADDRESSES section and this unit. Comments received
after the date set in the DATES section and prior to the end of the
oral public comment period during the meeting will still be provided to
the TSCA SACC for their consideration.
    iii. Oral comments. To be included on the meeting agenda, submit
your request to make brief oral comments at the in-person meeting to
the DFO listed under

FOR FURTHER INFORMATION CONTACT on or before the date set in the DATES
section. The request should identify the name of the individual making
the presentation, the organization (if any) the individual will
represent, and any requirements for audiovisual equipment. Oral
comments before TSCA SACC during the in-person meeting are limited to
approximately 5 minutes unless prior arrangements have been made. In
addition, each speaker should email their comments and presentation to
the DFO listed under FOR FURTHER INFORMATION CONTACT, preferably, at
least 24 hours prior to the oral public comment period.

(Authority: 15 U.S.C. 2601 et seq.)

    Dated: February 19, 2020.
Andrew R. Wheeler,
Administrator.
[FR Doc. 2020-03866 Filed 2-25-20; 8:45 am]
BILLING CODE 6560-50-P


EASTERN RESEARCH GROUP. INC It Stevenson. EPNCombustion Group Jason Huckaby. Eastern Research Croup, Inc FROM:

DATE: September 4,2002 SUBJECT: \

/

Lee County W C / Emissions Variability Analysis 1.0 INTRODUCTION This memorandum presents an analysis qf the variability in emission that occurs at a well operated municipal waste combustor ( MWC). The analysis reviews the performance of the Lee County ( FL) MWC. The Lee County facility is equipped with the full battery of high efficiency and has operated unmodified since start up in 1994. Additionally the ards for high standards of operation and performance.

MWC includes data for the following pollutants mium ( Cd), lead ( Pb), mercury ( Hg). hydrogen ch oxides ( NO,). The foIlowing se performance, parame annual test results.

2.0 FACILITY DESCRIPTION The Lee County M W C is Iocated in Fort Myers, FL. The facility has capacity to combust 1,200 tons per day ( tpd) of municipal solid waste ( MSW) in two 600 tpd municipal waste combustor ( MWC) units. The combustors are mass burn designs using reverse reciprocating C; iSmaiMWCVer County\ LeeVanabllLyrnemoi 1 793 stoker grates. Process control is achieved through the use of a distributive control system ( Le.,

sensors transmit operating data to compu make adjustments). The au pollution control systems include s carbon injection ( CI), and selective non catalytic re scrubbing syste is used for NOx nitrogen oxide, produdtion, power additional Hg and dioxidfuran ion, continuous emission monitoring syste vated carbon usage, combustion ctrical energy is produced by a 39.7 Mw electric generator driven by a condensing steam turbine. Fresh water usage is minimized through the use of secondary treate steam. Fly ash an ttom ash are passed t scalper, magnetic separator, and non ferrous recovery system IO recover metals from the as 3.0 PLANT OPERATIONS began in 1994, the MWC units' co operators and maintenance personne monthly written quizzes on plant operatio and maintenance personnei attend se operation, the Lee County facility has recently been aw Attachment A). 4.0 PLANT ENVIRONMENTAL PERFORMANCE Since it began operations, the Lee County facility has been in full compliance with all federal, state, and local regulations. The facility has not required any modification to  demonstrated compliance with permitted levels for PM, op Ifuric acid mist, fluorides, NO,, carbon monoxid nia, and dioxidfimns. As a result of their outs e Lee County facility was awarded the Environmental Citizen istrict office of Florida's DEP. The, ASME award no ( Attachment AI contains detailed information on environmental performance for both air I 5.0 PARAMETRIC DATA I Operating parameter data were obtained from the Lee County facility for the years a1 compliance test data ( 1994 2001 >. This data includes information nd the operating variables associated with the air pollution control tains the parametric data.

6.0 EMISSfO BILITY ANALYSIS as analyzed to determine the amount of emissions variabili aintained IWC. Statistical tests were performe th units couid be combined for analysis and what type of distribution ( is.,

t closely fit the data for each polhtant. Addition was necessary. The analysis investi compliance jtevel. The les I and 2. Additionally, Figures ugh 8 present data plots of the test 1 . The complete data Table 1. Summary Statistics for Stack ear 1994 through Particulate Matter ( rng'dscm)

ail values corrected to 3% 02. ' arithmetic average.

Particulate Matter variability of data arithmetic avera 4 4 CSmallMWCUee County\ lneVanablttymemofutdwpd Figure 1. Lee County Dioxin/ furan ( total mass basis)

I996 1997 1998 1999 2000 2001 1994 1995 Year 5 Figure 2. Lee County Mercury 0.05 A E + 0.04 m E Y $ 2 0.03 0.02 0.01 0 1994 1995 1996 1997 1998 Year 1999 2000 2001 0.0014 0.001 . cI f3  s t . I o* 0008 E 0.0006 0 P 0.0004 Figure 3. Lee County Cadmium

0.0013 0.0013 0.0013 0.0002 0 1997 1998 1999 2000 2001 1994 1995 1996 Year 7 ' s h 11 4. Lee County Lead   ~       _   ~ _ 0.02 i i 0.01 9 0.01 8 0.01 6 0.01 4 , g 0.0t2 u u)

5 0.01 1 x 2 0.008 0.006 0.004 0.002 0 1994 1995 1996 1997 f 998 8 Year 1999 2000 2001 t P E I Figure 5. Lee County Particulate Matter 9.2 9 8 7 6 5 4 3 2 1 0 1996 1997 1998 1999 2000 2001 1994 1995 Year CISmaMWCUae CountyUteVanabiltymemofma1 wpd 9 18 16 34 12 A >

e 10 8 H 6 4 2 0 1994 1995 1996 1997 1998 1999 2000 2001 Year 45 40 35 25 e n Y 15 70 1994 I995 7 996 1997 1993 1999 Year 2000 2001 I 1 165 160 S: 155 E n P

150 145 140 135 1994 1995 1996 1997 t 998 Year 1999 2000 2001 C. tSmallMWCU. ee Cuunty\ LrrVnriabilt~~ otinal wpd 12 r f d B Attachment A Waste to Energy Facility Recognition Award by ASME i I ~

 3 1 :> t,. 5 INTEROFFICE MEMO U M FROM SOLID WASTE DMSION Phone: ( 941) 479 8181 Fax: ( 941) 479 8119 e county SOUTRWEST FLORIDA Date: April 30,2001 TO: Jim Lavender, Director From: Lindsey J. Sampson, P. E.

s ste To Energy Facility Recognition Award by ASME can Society of Mechanical that an award will be pres Solid Waste Processing County and Covmta L the facility's contributions to the field of solid waste proc n ual North American hc., at no cost to the County. ation that was included in the Cc: BOCC Districts 1 5 D. Stilwell T. Eriksen 4 American Society cal Engineers Solid Waste cility Re plication ee Solid Waste Resour Facility Facility Recognition Award Nomination Form 1. Award Category Combustion ame Recovery Facility ( the '%' acility ' 3 10500 Ft. My 4. Owner Lee Cotinty Solid Waste Division ( the '' County' 3 Address: 1500 Monroe Sireet Contact: Telephone: 341 479 8 I81 Fax: 94 1 479 81 I9 5 . 0 r Martin Systems of Lee. hc. (" OMSL")

Contact: Tom Eriksen Telephone: Fa: 941 337 2510 1 1 ? 4 6. Throughput Capacity ( tons per day)

1,200 tons per day 7. Facility Description Provide a general description of the Facility, including each major piece of equipment Include attachment as needed.

Dirtral water wall Opaciiy, Sulfiir Dioxide, total st used to condense the turbine exhaust steam. l3k 8. Summary of Facility Operations Provide a general summary of Facility opera through the Facility, materials andor energy needed.

" Firxt fire" at this Facility to Department of Environmental first followed by the Turbine Generator on September 2 Acceptance testing was conducted from October I7 Construction Agreement beiween Ogden and Lee Cotrn Stan up of the Facility > vas virtuallyfla passing of acceptance testing I , 1994. The project was completed Since going commercial the FaciIiq h availability of 99.6 percent. A prodiiced; 1,077.000 Ktyh ofpower generated; tons of ferrous; and 835 tons of Ron ferroous me environmental permits and regulations tial operating, hour ere4 staffing, a d other key operationa1 hon, flow of materials Include attachment as County, Ogden and the Florida roblems noted With the on effective December ASME SWPD Fa d Nomination Form 9. Key Contributions to the Field of Solid Waste Processing The ASME Solid Waste Processing Division Facility Recognition Award is based on information provided in this section regarding the Faciliq's contributions to the field of solid waste procesmg. The key selection criteria and weightin are as follows:

I, Success in Reaching Facility Operation Requirements ( 20 percent) the established operating requirements for the Facility, and the history of the Facility with respect eeting those operating requirements.

me, at a minimum, is meamred by the abiliiy ofthe Facility to operate and be maintained in s z h a manner te. generate steam, and convert the steam into electric power for export, at a level consistent nce Guarantees contained in the Service Agreement between the County and The ting , I ce Guarantees contained in Schedule 2 of the Service Agreement are used as the basis for nce. These Pejormance Guarantees include:

erage Energy Guarantee Utility Utilization Guarantee hropane gas)

~

nee Guarantees* petj4onnanceparameters measured during the Facility's acceptance test Facility perjomance. These perjormance parameters include:

ate& 1.8 million tom of waste in fistfive years of operation, which is 96.8 vailability of 1,200 tons per day). During the first three years of compliance of waste. Waste processed by the Facility has increased evey year, e County's waste generation. In the fifth billing year, th e during the five yearperiod. This is 26.5 percent by Mwh of electricity for sale. The Facility P net elecrric essed, as more m t e has became availablefiom the 1 year averaged 601 kWh per ton of wcrste processed, able the Facility to recover energy at th& rate, high e$ ciency boilers, wz pressure and temperature, were installed to increase the turbine efficiency.

generated per ton of waste processed has generally increased over the seven years of operation.

 generator over the first seven years was 99.6percent.

3 ASME SWPD Facility Recognitio II. Innovative Contributions to Solid Waste P Describe the Facility's contributions to equipment, or operations; approaches applications of equipment or materials. your goals.

The Lee County project has several innovative recovery systm, its ecologically sound reuse elements.

In the early stages ofnegotiations L standards. The Facility was therefore sulpassed rhese standards since start all clean air retrofits throughout th This Facility was designed to pro in the United States with a perm wet design. one where acriv into a mix tankfiom where the carbonfwater s to comply with n I50 ug/& cm standard. This consistently rneefi

A post combustion fenous followed by a screened tro that would have been destined for the landfill an in line non ferrous The Faciliw also provides a long range bene4t 20 area wide water resource management. supplied by the Ciiy of would have been discharged into suface waters, now serves " reciaaim" water IS us ue air pollution control system. its metals ent since start up and d. Partially due to the \ i 1 0 gallons per day of the atmosphere in the ~

1 i Additionally, the water transmission lines coILThsl~

conservation efforts in the area.

Many exotic. non native ecies have been in Fuctlity war irrf2sted with the problematic exotic were eradicated and the weltand rstored. A n clogged with non native aquatic wee&. methods to remove rhese wee& the Fa These fish have since condition.

4 1 E d MREE SWPD Facility Recognition Award Nomination Form ore important to the Facdity than health andsafety. AI1 Facility personnel are repued to attend monthly safe9 specific OSHA required sdety training themes me presented by the Facility ' s S a f e Coordinator. onnel also attend weekly safety meetings where plant safity procedures are discussed e in` the employee medical surveiilance program which includes annual physicals. indushial hygiene ring outage and non outage periods to determine ifl where, when and what type of respiratory may be required Monthly plant walkdowns are conducted by the Faciiitys safety committee. d and quickly resolved \

mpiled an excellent safety record. The plant's OSHA Frequency Index not surtained any lost time injuries. in 1998. I999 and 2000. the Facil d a this outstanding performance and has operated the Facility for the last 3 years with excellent relationship with the local environmental agencies. llzk ilt on trust and the howledge that the Facility has and will continue to compi) with all pennit e local DEP stag to attend all vendor training sessions along over a three month period and DEPpersonnel attended every one. By el were able to understand the operation of not just the pollution control equip became acquainted with the FaciliQ stuff and realized the level of education,

lied by vendors prior to start up, in fact it hadjust begun. AN operators are required to rn on power plantfitndumentals as well as Facility speczjk Step Training program prior continual on the job training and are given written quizzes each month on plant systems. a lunch of their choice as recognition and a competitive incentive.

a1 management training. Maintenance and administrative personnel cafiold erection, pump repair, bearing maintenance, FaciIiq c i. e. chlorine handling, water treatmznt and heavy irtance. Several employees are pres ining relative to their support of the Facility This training includes ace entry, quarterly fire drills, elevator rescue. and chemical handling.

all operation and maintenance personnel receive wee erating Manual. These Amendmew also required th Extensive training in Facility operations an ts. Presently the Facility Ma as Chief Facility Operator Certification, the ng in vaste ifi Supervirors have the four Control Room I Waste Combustor training course.

5 ` I 1 4 ~

ET. Technical Contn'butions to Solid Waste The following nunmarizes the Facility` s Technical " gent regulations created by the iremen& the Faciliq proved that Clean Air Act Amendment Acts of I990.

iVon Ferrous Recovery overy sysrem. The contractor date. The system was installed aiko increasing the Inconel Application for Corrosion Control The Faciliy has obse ally related to the pam idenhBed. The entire furnuce area " R" Stamp recognized the need to have an proceeded by applyingfo facility personnel to pedom required boiler rep down time.

Power to Newly Constru W% en a new recyclingfacii The company perfrmed a the new faciliry. The res ASME SWPD Facility Recog Facility Preservation O& fSL has corntan been investigating, experimenting and utilizing erotic materials to help stem conmion occum ng in high humidity, alkaline, and acidic areas. The use of these materials result3 in less maintenance and a longer service & e of systems inrtalled in iner rmance Enhancement on the demineralization system due to decreasing potable water quality. OMSL the water through a reverse osmosis membrane water treatment system in a much improvedperfomance of the demineralizer, & meased chemical . acid Wash System to Ciem Atombms atomizers proved to be a high maintenance item. OMSL designed and installed and acidgwh operating cleaner, reducing maintenance. and provided proper slurry disrnhition in the scmbbm resulting in less downtime and decreased emissions.

On line Binsting of Baghouses dnd Off line Cleaning of Eloiler to energy facilitis to utilize on line percussion cIeaning to improve the operation of the harges are set offin the fly ash hoppers while the boilers are in operation, that res& in a a longer period between outages increasing availability.

aned off line with these * amile charges. ThiY results in a cleaner boiler and no w e of water corrosion. TiiY jiirther provides a cleaner working environment for mainten ed outage lime, and reduces the amount of wastewater generatedfiom the Fa rmance of the Facility with respect to air quality, water quality, workplace nt environmental areas. Include attachments as needed ( e. g. monitoring data, graphs).

a summary of the Facility's Environmental Performance:

Environmental Performance ent recordsince starnip The Fucility has been in fill compliance with all an Air Act of i 995 without performing any mod@ cations to the plant. i n uddigon, tal Citizen Award for the results.

Annual Air Emissions Testing dnnuai uir emissions testing, also known as stack teshg. wusper$ ormed at the Facility in June 2000. During this stack test. issions of particulate matter ( P%$ l, opacity, arsenic, bqliium, lead, mercuv, sulfMic , carbon monoxide, volatile organic compounds ( TOG), mlfir dioxide* hydrogen demonstrated to be in compliance with all permitted levelsfor mercuy, sulfiric acid mist. fluorides, nitrogen oxides ( WOd, carbon & ir dioxide. hydrogen chloride, ammonia, and dioxinsi@ ram.

7 I __  i _  I

I 3 a ASME SWPD Facili ard Nomination Form Tale Y Operating Permit 0710119 0014 Vto the Facility on November I . 2000.

In recognition of the excellent level DEP awarded Ogden Martin Sys me honor because it the DEF, the award tained by the Facility the South n Award '' on September 12,19 V. FaciIity Economics ( 10 percent) Discuss comparative costshipping fe management facilities.

Long rem environmentally responsible solutions to VI. Role in Integrated Waste Managemen Describe the role of the Facility in n. and agricllltural waste collection center ( under cons progrants that are 10. Supplemental Xnformation c3 Photographs ASME SWPD Facility Recognition Award Nomination Form Submitted By Samer Malcolm Pirnie, Inc.

Address: 1715 E. 9"' Avenue Tampa, Florida 33605 Telephone: ( 8 13) 248 6900 Fax: ( 813) 248 8085 Number of Copies Five complete copies o the nomination submittal should be provided Nomination Due Date ASME Solid Waste Processing Division Selection Process judged by the SWPD's Facility Recogtion Award subcommittee of the Honors and Awards Committee, selection criteria described above. The selection process will be completed upon approval ofthe recommended D's Executive CodUee.

ted at the annual Waste Processing Conference @ JAWTEC). The award will consist of a plaque 2suitabie for mounting at the Facility.

ication of Award will publicize the award through press releases and various ASME and waste management industry publication.

D member in good standing may nominale a FaciIity for the SWPD FaciSity Recognition Award. Self nomination by Facility personnel are welcome.

9 PHOTOGRAPHS An array of instruments in the plant's control room Facility staff monitor the plant's condition 1 A view of plant piping le. *

2 I The refuse claw in action Facility tipping floor. The refuse pit is visible to the left. 1 i'

ter pumps at the cool tower.

Sid 4 The Facility's reverse osmosis plant. &

. t i.

View of the non ferrous metal recovery pile 7 t EXCERPTS OF FDEP 2000 SOLID WASTE MANAGEMENT ANNUAL REPORT LOU0 Solid Waste Management m Elonda I Employee Directory I Help 1 SiteMap 1 Search Solid w ment in Florida 2000 This 2000 Solid Waste Man nual Report provides a comprehensive analysis of solid ludes information about the activities of the Department, ai in Florida primarily based on information compiled by ling with waste issues t n s for downloading rh3 whole report for viewing online

rt is availabie in Adobe's Portable Document Format ( PDF). If you d f the reader software, it is avaifable free of charge from Adobe's s above to download the software now. Once you have the Acroba you may download the entire report or specfic chapters.

PDF file is too small to read, use the magnifyng glass tool to zoom in.

n the appendices can also be downloaded in an Microsoft Excel Instructions the chapters: AVAILABLE NOW!

These files will dated shortly, so please be patient, you may wish to wait until the efore downloading. Check back the beginning of March.

1. Create a directory an you can do it during many of 2. rd drive for the report. If you forget, you ng file, cDacwszisgzc  is, saving it in on your is 3 19 Megabytes ( M8). It will take some time to patient. save this Droqram to disk" oDtion and then select llowing steps also.

3.

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t Attachment C Compliance Test Data Analysis for Lee County Solid Waste Resource Recovery Facility C:\ SmaUMWC\ Lee County\ LeeVar1abiltymemofmaLwpd COMPLIANCE TEST DATA ANALYSIS FOR LEE COUNTY SOLID WASTE RESOURCE RECOVERY FACILITY Prepared for:

US. Environmental Protection Agency Office of Air Quality Planning and Standards Emission Standards DivisiodCombustion Group Research Triangle Park, NC 27560 Prepared by:

Eastern Research Group 1600 Perimeter Park Drive Morrisville, North Carolina 27560 September 4,2002 * ERG  September 2002 TABLE OF CONTENTS Section Paye #

1 . O DESCRIPTION OF LEE COUNTY SOLID WASTE RESOURCE RECOVERY FACILITYDATA . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

2.0 STUDYOBJECTIVES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

3.0 PRELIMINARY DATA ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 4 4.0 COMPREHENSIVE DATA ANALYSIS . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 6 4.1 Statistical Distribution of Pollutant Emission Measurements . . e . . . . . . . . e . . . . 6 4.1.1 Dioxin/ Furan . . . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8 4.1.2 Particulate Matter ( PM) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 8

4.1.3 Cadmium . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 9 .

4.1.4 Lead . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

4.1.5 Mercury . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . l O 4.1.6 Mercury Percent Reduction . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 10 4.1.7 Hydrogen Chloride ( HC1) . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 1 1 4.1.8 Hydrogen Chloride ( HCl) Percent Reduction . . . . . . . . . . . . . . . . . . . . 1 1 4.1.9 Sulfur Dioxide ( SO,) Arithmetic Average . . . . . . . . . . . . . . . . . , . . . . . . 12 4.1.10 Sulfur Dioxide ( SO,) Percent Reduction . . . . . . . . . . . . . . . . . . . . . . . . . 12 4.1.11 Nitrogen Oxides ( NOJ . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . 13 4.2 95 and 99 Percent Threshold ( Le., Exceedance) Values . . . . . . . . . . . . . . . . . . . 13 5.0 REFERENCES . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

.. K \ O 154U 1\ 06\ mwc analysis report September 2002. wpd 11 ERG  September 2002 I I LIST OF TABLES Page Table 1 Raw MWC Compliance Data from Lee County Solid Waste Resource Recovery Facility Unit 1 ........................................... 16 Recovery Facility Unit 2 ............................ Table 2 Raw MWC Compliance Data from Lee County Solid Waste Table 3 Summary Statistics for MWC Compliance Data from Lee County Solid Waste Resource Recov 1 ......................... 18 Table 4 Summary Statistics for M W a from Lee County Solid Waste lityUnit2 . . . . . . . . . . . . . . . . . . . . . . . . . . .

Results for the Two Sample F Test .................................. .20 Results for the Two Sample t Test ( Equal Variances) . . . . . . . . . . . . . . . . . . . .21

Table 5 Table 6 Table 7 Summary Statistics for MW Solid Waste Resource Reco Units 1 and 2 Combined . *  *  * * * *  *  * * .   *  *  * m. 22 pliance Data from Lee County Table 8 Summary Statistics for C Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .23 Table 9 The Shapiro Wilk Normality Statistic ( W) for the Raw and Ln TransformedMWC Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......... .24 Table 10 95 and 99 Percent Thresholds and Threshold Mean Differences for the Raw and Ln transformed MWC Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and2Combined . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . , . . . . . . . . 2 5 ... 111 K\ 0154\ 11\ 06\ mwc anaIysis rq~ o1' t September 2002. wpd w ' ERG  September 2002 LIST OF FIGURES Page Figure l( a) Frequency Histograms for Dioxifluran ( ng/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .26 Figure 1 ( b) Normal Probability Plots for Dioxifluran ( ng/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Unitsland2Combined ........................................... 27 Frequency Histograms for PM ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Unitsland2Combined ........................................... 28 Figure 2( a)

Figure 2( b) Normal Probability Plots for PM ( mddscm) Compliance

Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .29

Frequency Histograms for Cadmium ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .30 Normal Probability Plots for Cadmium ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .31 Frequency Histograms for Lead ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and2 Combined .......................................... .32 Normal Probability Plots for Lead ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... .33 Figure 3 ( a)

Figure 3( b)

Figure 4( a)

Figure 4( b)

Figure 5( a) Frequency Histograms for Mercury ( mg/ dscm) Compliance Data & om Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined ........................................... 34 Figure 5( b) Normal Probability Plots for Mercury ( mg/ dscm) Compliance Data fiom Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined .......................................... . 3 5 K:\ 0154\ 11\ 06bnwc analysis report September 2002. wpd iv LIST OF FI S ( Continued)

Figure 6( a) Frequency Histograms for Data from Lee County Units 1 and 2 Combine . . . . . . . . . . . . . . . . . . . . . . . 3 6 Figure 6( b) Normal Probability PI Figure 7( a) Frequency Histograms for Data from Lee County Sol Units 1 and 2 Comb Normal Probability Plots for HC1 ( ppmv) Compliance Data from Lee County Figure 7( b)

 Units 1 and 2 Combine . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

 Figure 8( a) Frequency Histograms for H Reduction Compliance Data from Lee Co Units 1 and 2 Comb Normal Probability Plots for HC1 Percent Reduction Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined . . , . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Frequency Histograms for SO, Arithmetic Average ( ppmv) Compliance Data from Lee County Solid Wast Units 1 and 2 Com e Recovery Facility . . . . . . . . . . . . . . . . . 4 0 Figure 8( b)

Figure 9( a) urce Recovery Fa . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Figure 9( b) Normal Probability Plots for SO, Arithmetic Average ( ppmv) Compliance Data from Lee County Solid Waste Resource Reco Units 1 and 2 Combined .................... '  *  *  *  *    43 Figure 1O( a) Frequency Histograms ent Reduction Compliance Data from Lee County Units 1 and 2 Combined Figure 1 O( b) Normal Probability Plots for SO, Percent Reduction Compliance Data from Lee Coun Units 1 and 2 Comb Frequency Histograms for NO, ( ppmv) Compliance Data from Lee County Solid Waste Resource Recovery Facility Unitsland2Combined . . . . . . . . . . . . , . . . . . . . . . . . . . . . . . . , . . . . . . . . . . . 4 6 Recovery Facility .......................................... .44 ery Facility . . . . . . . . . . . . . . . . . . . . . . . . . . . . . .

Figure 1 1 ( a)

V K \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd LIST OF FIGURES ( Continued)

Figure 1 1 ( b) Normal Probability Plots for NO, ( ppmv) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined . . . . . , . . . . . . . . . . , . . . . . . . . . . . . . .  . . . . . . . . . .47 KA0154\ 11\ 06\ mwc anaiysis report September 2002. wpd . .

Y vi '*

ERG  September 2002 1.0 DESCRIPTION OF LEE COUNTY SOLID WASTE RESOURCE RECOVERY FACILITY DATA Upon request from the U. S. Environmental Protection Agency, COVANTA Lee Inc.

submitted annual municipal waste combustor ( MWC) compliance data for the period 1994 to 200 1 from its solid waste resource recovery facility located in Lee County, Florida. The facility consists of two 600 tons per day ( tpd) mass burn waterwall units ( referred to as Unit 1 and Unit 2) each of which is equipped with spray dryer, fabric filter, carbon injection, and selective non

catalytic reduction. The MWC data submitted included emissions measurements from both units for the following pollutants:

e e e e e e Dioxidfuran ( ng/ dscm),

Particulate matter ( PM) ( rng/ dscm),

Cadmium ( mg/ dscm),

Lead ( mg/ dscm),

Mercury and percent mercury reduction if available ( mg/ dscm),

Hydrogen Chloride ( HCl) and percent HC1 reduction if available ( ppmv),

Sulfur dioxide ( SO,) and percent SO, reduction if available ( ppmv),

Nitrogen oxides ( NOJ ( ppmv).

The tests followed the procedures required by the large MWC New Source Performance Standards ( NSPS) ( 40 CFR Subpart Cb). The values reported for dioxins/ furans, PM, cadmium,

lead, mercury and HCl are the arithmetic average control device outlet levels for a 3 run stack test using the EPA test methods and sampling times required by the NSPS. For mercury, the average percent reduction for the 3 run test is also provided. The SO, values are % hour arithmetic average outlet concentration and percent reduction values calculated fiom continuous emission monitoring ( GEM) data during the first 24 hours of the annual performance test. ( Note that Subpart Cb requires facilities to demonstrate SO, compliance with either a geometric mean outlet concentration or a percent reduction. The facility is using percent reduction and did not K\ 0154\ 11\ 06unwc analysis report September 2002. wpd 1 t provide the geometric mean.)

device outlet calculated from CEM d Tables 1 and 2 present the raw MWC compliance data provided by the Lee County solid waste resource recovery facility units 1 and 2 94 through 2001. ' EQG  September 2002 2.0 STUDY OBJECTIVES The main objectives of the study are:

To characterize the variability in pollutant emission measurements ( due to variability in process and measurement) using basic univariate statistics and relative frequency histograms,

To evaluate the statistical distribution of pollutant emission measurements ( ie., normal versus lognormal) with normality tests and applicable shape statistics, such as relative frequency histograms and normal probability plots, and To compute relevant threshold values ( Le., exceedance values), based on computed sample means and standard deviations, for which the probability that a given test at the facility will be above the threshold value is 95 and 99 percent. *

K \ O 1 5 4 1 1\ 06\ mwc analysis report September 2002. wpd 3 I ~~~

1

"? 3.0 PRELIMINARY DATA ANALYSIS Tables 3 and 4 present the routine swnmary statistics for the annual MWC compliance data fiom the Lee County solid waste resource recovery facility units 1 and 2, respectively, for the period 1994 to 200 1 pollutant, ERG first evaluated precision. For this, ERG empl any evidence to indic the two units are substantial1 sts that assess whether there is First, ERG conducted a hypothesis t r there is sufficie  indicate a significant difference in the variability and 2. Table 5 presents the results of the hypothesis test ( two sample F test) conducted for each pollutant. Because the computed value of the F statistic was less than the critical value, Fa, for all pollutants at the 95 and 99 percent confidence levels, ERG faiIed to reject the null hypothesis that the variability of pollutant emission measurements from the two units are statistically equivalent.

Having established that there is insufficient evidence to support that the observed variability of pollutant emission measurements for Unit 1 is different than that of Unit 2, ERG conducted an additional hypothesis test to evaluate whether there is sufficient evidence to indicate a difference in the mean value of pollutant emission measurements between the two units. Table 6 presents the results of the hypothesis test ( two sample t test) conducted for each pollutant. From the table, the absolute value of the computed t statistic is less than the critical value, t,, for all pollutants at the 95 and 99 percent confidence levels. This indicates that there is insufficient evidence to reject the null hypothesis that the mean pollutant emission measurements fiom the two units are statistically equivalent.

Because both hypothesis tests suggest that there is no statistically significant difference in the mean pollutant emission measurement and its variability between Units 1 and 2 for each 4 K\ 0154\ 11\ 06\ mwc anaIysis report September 2002. wpd 1 c ERG  September 2002 pollutant, ERG combined the data for the two units for all pollutants.* It is expected that the data from the two units would be similar because the designs of the combustors and control equipment are identical, they were installed at the same time, they receive MSW from the same sources, and they are operated and maintained similarly at the same MWC facility. Table 7 .

presents the routine summary statistics for MWC compliance data from the Lee County solid waste resource recovery facility units 1 and 2 combined. Table 8 provides the same summary statistics for the In transformed MWC compliance data.

* It should be noted that the parametric distributional tests conducted are relatively low power, especially for small sample sizes. Hence, conclusions obtained fiom these tests have to be weighted appropriately in light of other relevant considerations, such as the similarity of control technologies in each unit.

K:\ 0154\ 11\ 06~ wc analysis report September 2002. wpd 5 * I ERG  September 2002 ( 1' I 4.0 COMPREHENSIVE DAT ERG utilized several statistical an data for both units combined. These techniques 1 0 ical distribution llutant data ( normal ver probability plots, s and normality tests, and 0 Computation of threshold values ( i. e., exceedance values) for each pollutant based on sample means and standard deviations.

The following sections discuss the techniques and results obtained in further detail.

.

4.1 Statistical Distribution of Pollutant Emission Measurements There are numerous methods for evaluating the statistical distribution of a given data set.

For the Lee County MWC data, ERG employed the following techniques to assess whether the compliance data submitted for a given pollutant is normally or lognormally distributed:

0 Frequency histograms,

Normal probability plots,

0 Sample moments ( skewness and kurtosis), and 0 Shapiro Wilk ( W) test.

AJFequency histogram divides the data range into units, counting the number of points within the units, and displaying the data as the height or area within a bar graph. The frequency histogram provides a means for assessing the symmetry and variability of the data. If the data afe symmetric, the frequency histogram will also display symmetry around a central point, such as a mean. Typically, the frequency histog ibuted data will be bell shaped.

6 K \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd i U # ERG  September 2002 A normalprobabilityplot shows the observations of a sample plotted against a cumulative frequency distribution ( or quantiles of a data set against the quantiles of the normal distribution). Comparing against the standard S shaped cumulative frequency distribution is difficult, so the chart transforms the observations so they can be compared against a straight line.

Observations for a normally distributed sample should closely follow a straight line. For non

normally distributed data, there will be large deviations in the tails or middle of a normal probability plot. The normal probability plot is also another way to assess the degree of symmetry ( or asymmetry) displayed by the data. For example, if the data in the upper tail fall above and the data in the lower tail fall below the quartile line, the data are too slender to be well modeled by a normal distribution. Similarly, if the data in the upper tail fall below and the data in the lower tail fall above the quartile line, then the tails of the data are too heavy to be well modeled using a normal distribution.

The skewness coeficient measures the degree of symmetry ( or asymmetry) displayed by a data set. The kurtosis coefJicient, on the other hand, measures the degree of flatness of a distribution near its center. For an ideal normal distribution, the skewness and kurtosis coefficients are equal to 0. Substantial variations from the 0 value indicate that the data may not be modeled using a normal distribution.

The Shapiro Wilk ( w) test is one of most commonly employed tests of normality. The test involves computing a correlation between the quantiles of the standard normal distribution and the ordered values of a data set and is only recommended for sample sizes less than or equal to 50. The statistical power of the test, however, declines for very small sample sizes. The value of the W statistic computed for a given set of data can range from 0 to 1, with low values typically leading to the rejection of the null hypothesis of normality.

In evaluating the most appropriate statistical distribution ( normal versus lognormal) for a given set of data, the results obtained from the application of the above statistical techniques have to be considered jointly. Especially for small sample sizes, no single technique is likely to yield definitive conclusions on the type of distribution displayed by the data. The following sections present the results of the statistical analyses performed on MWC compliance data for K:\ 0154\ 11\ 06\ mwc anaIysis report September 2002. wpd 7 , each pollutant. The sections also provide an assessment the data based on the analyses performed tatistical distribution displayed by 4.1.1 Dioxin/ F'uran The frequency histograms dioxidfuran data are depicted in Figures 1 ( a) and 1 ( b transformed data is more symmetric aro the raw data. Further, the In transforme normal probability plot depicted in Figure 1 data ( 0.0487) is much statistics for the raw and In transformed dioxidfuran data are 0.8568 and 0.9572, respectively ( see Table 9). The W statistic indicates a normal data distribution for the In transformed data at the 95 percent level of confidence.

Overall, the analyses performed suggests al dioxidfbran compliance data submitted by the Lee County solid wa distribution.

4.1.2 Particulate Matter ( PM)

The frequency histograms and n and ln tmnsformed PM data are depicted in Figures 2( a) and 2 is more symmetric around its mean with so the In transformed data is more evenly spread out and hence more close straight line in the normal probability plot depicted in Figure 2( b). The skewness coefficient of approximate the ed data ( 0.0835) is 7). Similar to the

dioxin/ fbran data, ho indicates normality at the 95 percent level of confidence. r the In transformed PM data ( 0.8688)

8 K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd P Overall, the analyses performed suggests that the annual PM compliance data submitted by the Lee County solid waste resource recovery facility display a lognormal distribution.

4.1.3 Cadmium I The fiequency histograms and normal probability plots of the raw and In transformed cadmium data are depicted in Figures 3( a) and 3( b), respectively. From Figure 3( a), the raw data appears more symmetric around its mean with some extreme values in the highest bin ( 0.001 125 scm). The normal probability plot of the raw data more closely approximates the straight line in the normal probability plot depicted in Figure 3( b). Further, the skewness coefficient of the raw data ( 0.544) is higher ( closer to 0, the value for an ideal normal distribution) than that of the In transformed data ( 0.9395). The W tests for the raw and ln

transformed data both reject the null hypothesis of normality at the 95 percent level of

confidence.

Overall, the analyses performed suggests that the annual cadmium compliance data submitted by the Lee County solid waste resource recovery facility display a relatively normal distribution. I 4.1.4 Lead The frequency histograms and normal probability plots of the raw and In transformed lead data are depicted in Figures 4( a) and 4( b), respectively. From Figure 4( a), the In transformed data appears more symmetric around its mean with some extreme values in the  5.25 to  4.75 range. The In transformed data is more evenly spread and hence more closely approximates the straight line in the normal probability plot depicted in Figure 4( b). Further, the skewness coefficient of the In transformed data ( 0.473 1) is lower ( closer to 0, the value for an ideal normal distribution) than that of the raw data ( 0.876). The W tests conducted for the raw and ln

transformed data, however, both fail to reject the null hypothesis of normality at the 95 percent level of confidence.

c K:\ 0154\ 11\ 06\ mwc a~ lysis reprt September 2002. wpd 9 I Overall, the analyses performed suggests that the annual lead compliance data suimitted by the Lee County solid waste resource recovery display a lognormal distribution. ,

4.1.5 Mercury The frequency histograms and normal probability plots of the raw and In tr mercury data are depicted in Figures 5(

appears more symmetric around its mean with fewer extreme v evenly spread and hence, more closely appr plot depicted in Figure 5( b) as well. T observations clustered along higher, hence closer t ( 2.6078). The computed W statistic for a normal data distribution at the 95 percent level of confidence. the value for an Overall, the analyses performed sug mercury compliance data submitted by the Lee County solid waste resource recovery facility display a relatively normal distribution.

4.1.6 Mercury Percent Reduction The frequency histograms and normal probability plots of the raw and In transformed mercury percent reduction data are depicted in Figures 6( a) and 6( b), respectively. From Figure , 6( a), both the raw and the ln transformed data appear to be positively skewed. There also is no substantial difference between how the raw and In transformed data are spread along the straight line in the normal probability data ( 1.3233) is higher, henc transformed data ( 1 3549). Fu reduction compliance data ( 0 confidence. efficient of the raw e for an ideal normal distribution, than the ln

raw mercury percent 95 percent level of 10 K.\ O 154\ 11\ 06~ wc analysis report September 2002. wpd P ERG  September 2002 Overall, the analyses performed suggests that the annual mercury percent reduction compliance data submitted by the Lee County solid waste resource recovery facility display a relatively normal distribution.

4.1.7 Hydrogen Chloride ( HCI)

The frequency histograms and normal probability plots of the raw and In transformed HCl data are depicted in Figures 7( a) and 7( b), respectively. From Figure 7( a), the In transformed data appears less skewed than the raw data. Further, the In transformed data is more evenly spread out and hence more closely approximates the straight line in the normal probability plot depicted in Figure 7( b). The skewness coefficient of the In transformed data ( 0.591 8) is lower than that for the raw data ( 1.3 140). Finally, the W test for the In transformed data fails to reject

the null hypothesis of normality at the 95 percent level of confidence.

Overall, the analyses performed suggests that the annual HC1 compliance data submitted by the Lee County solid waste resource recovery facility display a lognormal distribution.

4.1.8 HCI Percent Reduction The frequency histograms and normal probability plots of the raw and In transformed HCl percent reduction data are depicted in Figures 8( a) and 8( b), respectively. From Figure 8( a),

both the raw and the In transformed data appear to be positively skewed. There also is no substantial difference between how the raw and In transformed data are spread along the straight line in the normal probability plot depicted in Figure S( b). The skewness coefficients of the raw and In transformed data are nearly identical indicating no substantial difference between using the two distributional assumptions. Finally, the computed W statistics for the raw and ln

transformed data both fail to reject the assumption of normality at the 95 percent level of confidence.

K \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd 11 4.1.9 Sulfur Dioxide ( SO,) Arithmetic Average The frequency histograms the raw and ln transformed so,

ectively. From Figure 9( a), the arithmetic average data are depicted in Figure raw data is negatively skewed wi In transformed data is positively ske The raw data is, ho plot depicted in Figure 9( b). The the quartile line in the upper tail.

hence closer to 0, the value for 1.0151). Additionally, the data ( 0.9030) also support e upper tail of the distribution.

0, arithmetic average compliance nt level of confidence.

Overall, the analyses performed suggests that the annual SO, ar compliance data submitted by the Lee County s relatively normal distribution.

4.1.10 SO, Percent Reduction 1 The frequency histograms an probability plots of the percent reduction data are depicted both the raw and the In transfo percent reduction data, there is no s data are spread along the straight li skewness coeffkients of the raw and In transformed data are fairly close with the skewness n how the raw and In transformed coefficient of the raw data slightly better than that of the In transformed one. Finally, the ' ERG  September 2002 computed W statistics for the raw and ln transformed data both fail to reject the assumption of normality at the 95 percent level of confidence.

Overall, the analyses performed suggests that the annual SO, percent reduction compliance data submitted by the Lee County solid waste resource recovery facility display a relatively normal distribution.

4.1.11 Nitrogen Oxides ( NO,)

The frequency histograms anb normal probability plots of the raw anc In transformed NO, data are depicted in Figures 1 1 ( a) and 1 l( b), respectively. From Figure 1 1 ( a), both the raw and In transformed data are positively skewed with extreme values in upper tail of the distribution. Moreover, there are no substantial differences in the spread of observations along the quartile line between the raw and In transformed data in the normal probability plots depicted in Figure 1 1 ( b). The skewness coefficient of the raw data ( 1.5242), however, offers a slight

improvement over that of the In transformed one ( 1.5905). The conducted W tests for the raw and In transformed data both reject the normality assumption at the 95 percent level of confidence.

Overall, the analyses performed suggests that the annual NO, compliance data submitted by the Lee County solid waste resource recovery facility display a relatively normal distribution.

4.2 95 and 99 Percent Threshold ( i. e. Exceedance) Values In the second stage of the comprehensive data analysis, ERG computed compliance thresholds ( i. e., exceedance values) at 95 and 99 percent significance levels for each pollutant.

The 95 and 99 percent exceedance values reflect the emission levels that the Lee County facility can meet during an annual test with 95 and 99 percent probability, respectively, and are computed as:

K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd 13 where: tandard Deviation Mean Standard deviation = Sarnpl ta P Table 10 presents the 95 and mean by pollutant ( c applicable threshold v

Section 4.1 for each p .

I Deviation and is spec threshold and the mean is t, ' Standard

j 14 K\ 0154\ 11\ 06\ mwc analysis report Septmber 2002. wpd ' c ' ERG  September 2002 5.0 REFERENCES Epperson, David and David White. 1995. " Supplemental Analysis of NO, Emissions Data from the Stanislaus County MWC." Memorandum from Radian Corporation to Walt Stevenson, EPA/ ESD. August 30.

Lanier, Steven W. and Charles D. Hendrix. 2001. Reference Method Accuracy and Precision ( ReMAP): Phase I : Precision of Manual Stack Emission Measurements. American Society of Mechanical Engineers ( ASME) Research Committee on Industrial and Municipal Waste. February.

Mendenhall, William, Dennis D. Wackerly, and Richard L. Scheaffer. 1990. Mathematical Statistics with Applications. 4& Edition. P WS Kent Publishing Company. Boston, MA.

U. S. Environmental Protection Agency ( EPA). 2000. Guidance for Data Quality Assessment: Practical Methods for Data Analysis. EAP QNG 9 QAOO Update. Office of Environmental Information. Washington, D. C. July.

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FI 0 .* Y Y 3 3 k d0" w l w l n a a 5 W ERG  September 2002 Frequency Histograms for Dio Data from Lee County Frequency Hi Frequency Histogram: in transformed Data 4.5 0.5 1 1.5 2 2.5 3 Ln( dioxin/ furan ( ngldscm)) Bins*

26 * b e 4 ERG  September 2002 Normal Probability Plots for DioxinB'uran ( ng/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 0 5 10 15 20 25 30 DioxinlFuran ( ngldscm )

Normal Probability Plot: Ln transformed Data 0.5 1 1.5 2 2.5 3 3.5 Ln( Dioxin/ furan ( nglds crn ))

K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd 27 Frequency Histograms for PM ( mgldsc ounty Solid Waste Resource Recove 9, I 1 l 0 2 4 6 8 Particulate Matter (

* The x axis labels denote the midpoint of the bin range, Le., +/ 1 mg/ dscm about the midpoint.

6 5 4 s E s 3 ET $ 2 1 0 * The x axis labels denote the midpoint of the bin range, Le., + I 0.25 In ( mg/ dscm) about the midpoint.

28 K:\ 0154\ 11\ 06hwc analysis report September 2002. wpd / ' i Figure 2( b) Normal Probability Plots for PM ( mgdscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 0 2 4 6 8 10 Particulate Matter ( mg/ dscm)

Normal Probability Plot: Ln transformed Data 2 . 2 1 . Id E m s o  E  1 m z  2  1  0.5 0 0.5 1 1.5 2 2.5 Ln( Particu1ate Matter ( m gldscm))

K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd 29 a Figure 3( a) Frequency Histograms for Cadmium ( m ce Data from Lee Waste Resource Re J 3.5 3 2.5 6 E 2 1.5 2 " 1 0.5 0 0 Cadmium ( mgldscm) Bins*

* The x axis labels denote the midpoint of F Frequency Histogram: Ln transformed ta 4.5 , 1 1 1 1 1 4 3.5 3 5 2.5 2 1.5 1 0.5 0 6 s 2 u.

 8.25  8  7.75  7.5  7.25  7  6.75 Ln( Cadmium ( mg/ dscm)) Bins*

* The x axis labels denote the midpoint of the bin range, Le., +/ 0.125, In ( mddscm) about the midpoint.

K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd 30 ' E8G  September 2002 Figure 3( b) Normal Probability Plots for Cadmium ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 0.00025 0.0005 0.00075 0.001 0.00125 0.0015 Cadm ium ( mgldscm)

* The x axis labels denote the midpoint of the bin range, Le., + I 1 mg/ dscm about the midpoint.

Normal Probability Plot: Ln transformed Data  8.25  8  7.75  7.5  7.25  7  6.75  6.5 Ln( Cadm ium ( ngldscm))

E.\ O154\ 11\ 06\ mwc analysis report September 2002. wpd 31 Frequency Histograms for Lead ( mg/ dscm) Co om Lee County Solid Waste nd 2 Combined Lead ( mgldscm) Bins*

* The x axis labels denote the midpoint of the b rmed Data 4.5 4 3.5 3 2.5 1.5 1 0.5 0 5 2 * The x axis labels denote the midpoint of the bin range, i. e., +/ 0.25 In ( mg/ dscm) about the midpoint.

32 K:\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd r

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 4 . :  September 2002 I Figure 4( b) Normal Probability Plots for Lead ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 0 0.003 0.005 0.008 0.01 0.013 0.015 0.018 0.02 Lead ( mgldscm)

Normal Probability Plot: Ln transformed Data 2 I I I I b I i  7  6.5  6  5.5  5  4.5  4  3.5 Ln ( Lead ( m g/ ds cm ))

K\ 0154\ 11\ 06hwc analysis report September 2002. wpd 33 Figure 5( a) 1 Frequency Histograms for Mercu Waste Resource R from Lee County Solid * The x axis labels denote the midpoint of the bin range, Le., +/ 0.005 mg/ dscm about the midpoint.

ency Histogram med Data 7 6 5 1 0 * The x axis labels denote the midpoint of the bin range, Le., +/ 0.25 In ( mg/ dscm) about the midpoint.

34 K\ 0154\ 11\ 06\ mwc analysis repo~ September 2002. wpd Figure 5( b) Normal Probability Plots for Mercury ( mg/ dscm) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data n 0 0.01 0.02 0.03 0.04 0.05 0.06 Mercury ( m glds cm )

Normal Probability Plot: Ln transformed Data 2 1 0  . E O m 3 m 0 u  1  2  3  4

 7  6.5  6  5.5  5  4.5  4  3.5  3  2.5 Ln ( M e rcury ( m glds cm ))

K\ 0154\ 11\ 06\ mwc analysis report September 2002. hpd 35 Frequency Histograms for Merc ata from Lee County ed a 7 6 3 5 f 4 L e 3 Q i 2 1 I 0 * The x axis labels denote the midpoint of the bin range, Le., +/ 5% about the midpoint.

Frequency Histogram Data 3 e C a, 3 Q U. I O , I I I I 9 7 6 5 4 3 2 1 0 a 3.6 4.4 * The x axis labels denote the midpoint of the bin range, Le., +/ 0.1 In (%) about the midpoint.

36 K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd Figure 6@) Normal Probability Plots for Mercury Percent Reduction Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 2 1 Q)  . I + I 5 0 I 5  2  I I ti z  2  3 40 50 60 70 80 90 100 Mercury % Reduction Normal Probability Plot: Ln transformed Data Q)

E m  . + I 5  m E z I 3.8 4 4.2 4.4 4.6 3.6 Ln( Mercury % Reduction)

K \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd 37 ~ ~ ~

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Frequency Histograms for HCl ( ppm Resource Recovery Lee County Solid Waste 8 7 6 E 5 L 2 ? 3 5 4 m 2 1 0 _ i * The x axis labels denote the midpoint of the b midpoint.

Frequency Histogram; Ln transformed Data I I I 7 6 5 $ 4 W s3 2 L 2 1 0 2.25 2.5 Ln( HCI ( ppmv)) Bins*

38 K \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd %

4 Figure 7( b) Normal Probability Plots for HCl ( ppmv) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data  2 0 I 10 . 15 20 25 30 35 40 HCI ( PPmv)

Normal Probability Plot: Ln transformed Data K.\ 0154\ 11\ 06\ mwc analysis report Septernber 2002. wpd 39 Frequency Histograms for H ta from Lee County ine Solid Waste Reso 6 5 4 5 2 3 C r E 2 1 0 * The x axis labels denote the midpoint of the bin range, Le., % about the midpoint.

7 6 5 >, E 4 Q)

5 3 2 L 2 1 0 K\ 0154\ 11\ 06\ mwc analysis report September 2002. wpd 40 c 4' T& ERG  September 2002 Normal Figure 8( b)

Solid Waste Resource Recovery Facility Units 1 and 2 Combined Probability Plots for HCI Percent Reduction Compliance Data from Lee County Q)

E m  . c a Normal Probability Plot: Raw Data 95.5 96 96.5 97 97.5 98 98.5 HCI % Reduction Normal Probability Plot: Ln transformed Data 4.56 4.565 4.57 4.575 4.58 4.585 4.59 Ln( HCI % Reduction)

41 K \ O 154\ 11\ 06\ mwc analysis repon September 2002. wpd  r 7 _ D_/ >

Frequency Histogra 0 2.5 5 7.5 10 12.5 15 17.5 S * The x axis labels denote the midpoint of the bin range, i. e., +/ 1.25 ppmv about the midpoint.

Frequency Histogra Da 7 6 5 g 4 Q) J c r 3 2 u 2 1 0 Ln( S02 Arithmetic Mean ( ppmv)) Bins*

* The x axis labels denote the midpoint of the bin range, i. e., +/ 0.5 In( ppmv) about the midpoint.

42 KAO 154\ 11\ 06\ mwc analysis report September 2002. wpd Figure 9( b) ormal Probability Plots for SO, Arithmetic Average ( ppmv) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 0 2.5 5 7.5 10 12.5 15 17.5 20 SO2 Arithmetic Average ( ppmv) .

Normal Probability Plot: Ln transformed Data  1 0 1 2 3  3  2 Ln( S02 Arithmetic Mean ( ppmv))

K:\ 0154\ 11\ 06hwc analysis report September 2002. wpd 43 Frequency Histograms fo Solid 8 * The x axis labels denote the midpoint of the bin range, Le., +/ 2 5 % about the midpoint.

sformed I i 6 5 4 6 f 3 ; 2 U 1 0 Ln( S02 % Reductio * The x axis labels denote the midpoint of the bin range, i. e., +/ 0.025 In(%) about the midpoint.

44 E \ O 154\ 11\ 06\ mwc analysis report September 2002. wpd Figure 1O( b) Normal Probability Plots for SO, Percent Reduction Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data 2 85 90 95 100 80 SO2 % Reduction Normal Probability Plot: Ln transformed Data 2 I  2 0,

 3 , 4.35 4.4 4.45 4.5 4.55 4.6 4.65 ln( S02 % Reduction)

K:\ O 154U 1\ 06\ mwc analysis report September 2002. wpd 45 .

I Frequency Histograms Lee County So ta 9 . , I I I 8 7 6 $ 5 0 5 4 E 3 2 1 0 NOX ( ppmv) Bins*

* The x axis labels denote the midpoint of the bin range, Le., +/ 2.5 ppmv about the midpoint.

9 8 7 6 3 f 5 $ 4 E 3 2 1 0 * The x axis labels denote the midpoint of the bin range, Le., + I 0.0125 ln( ppmv) about the midpoint.

46 K:\ 0154\ 11\ 06\ mwc analysis qo~ September 2002. wpd  %,

G  September 2002  3 Figure ll( b) Normal Probability Plots for NO, ( ppmv) Compliance Data from Lee County Solid Waste Resource Recovery Facility Units 1 and 2 Combined Normal Probability Plot: Raw Data I I I NOX ( PPm VI I 155 160 165 170 145 150 Normal Probability Plot: Ln transformed Data K \ O 154\ 1 1\ 06\ mwc analysis report September 2002. wpd 1 47 i


MEMORANDUM

TO:		Amy Hambrick, EPA/OAQPS/SPPD/FIG

FROM:	David Hendricks, EC/R, Inc.

DATE:	April 22, 2016

SUBJECT:	Summary of the January 28, 2016 Meeting with the American Petroleum Institute (API) and the U.S. Environmental Protection Agency
--------------------------------------------------------------------------------

I.	INTRODUCTION

The American Petroleum Institute (API) requested this meeting with EPA to present an overview of their comments on the September 18, 2015 proposed Oil and Natural Gas Sector NSPS (80 FR 56593), draft CTG (80 FR 56577), proposed Source Determination Rule (80 FR 56579), and proposed FIP for EPA's Indian Country Minor NSR program. This summary addresses the discussion on the first three actions.

II.	ATTENDEES

The following is a list of participants in the meeting.

U.S. Environmental Protection Agency
Bruce Moore
Greg Nizich
Cheryl Vetter
Matthew Witosky
Lisa Thompson
Amy Hambrick
Jerri Garwood (by phone)
Alex McPherson
Beth Miller
Jodi Howard
Charlene Spells
David Cozzie
Eric Goehl
Susie Waltzer (by phone)
Jameel Alsalam (by phone)

API and Member Organizations
Mike Ford, Hess
Tom Monahan, XTO
Phil Norwood, ERM
Brad Morello, Shell
Dana Wood, BP
Grover Campbell, Devon
Greg Johnston, Chesapeake
Mike O'Connor, XTO
Matt Todd, API
Dennis Newman, Oxy
Shankar Ananthakrishna, Chevron
Vanessa Ryan, Chevron
John Wagner, API
Andrew Baker, Encana
Jeff Adams, BP
Laura Perry, ConocoPhillips
Andy Woerner, ERM

EC/R Incorporated
David Hendricks (by phone)

III.	SUMMARY OF DISCUSSION

Bruce Moore opened the meeting and explained to the attendees that since the EPA is in the post-proposal phase of the NSPS, CTG and Source Determination Rule, EPA personnel would listen to their comments but cannot respond to any of the issues raised. However, the EPA welcomed the comments. The attendees offered the following comments.

Source Determination Rule
 Expressed opposition to proposed option 2.
 Agreed with EPA to be mindful of the direction the DC Circuit provides that a source for permitting purposes should comport with the common sense notion of `plant'; an overarching concern in terms of aggregation of source.
 Asserted proposed option 1 without revision and proposed option 2 would violate the above provision.
 When revising the rule, asked the EPA to be mindful of the meaning of `adjacent' as explained in the 6th circuit Southern Petroleum decision.
 Stated that an arbitrarily chosen distance should not be used to define `adjacent'.
 Strongly agreed that, with regard to minor sources, NSPS and NESHAP work well but stated minimal extra pollution control can be had by putting these requirements on title V affected facilities.
 Claimed EPA misconstrued some state's source determinations as detailed in their written comments. For example, noted that PA's rule is more complicated.
 Supported the EPA definition of `service site' as same as in the NESHAP, but proposed using `facility' as defined in the NESHAP with some modification to better define many activities.
 Proposed option 1 is insufficient for source determination. Cannot presume that all sources, for example, within a (1/4) mile can be aggregated. Believed that inside (1/4) mile, the regulating agency should be allowed to make the source determination and (1/4) mile should be the maximum distance.
 Suggested regulatory language for a 2-step process to determine contiguous  -  first, operations separated by at least (1/4) mile are not contiguous or adjacent and, second, operations within (1/4) mile are continuous/adjacent only if two additional are criteria met: First, operations are physically touching or only separated by happenstance, for example, separated by a road, river or railroad. Second, operations meet the common sense notion of `plant'.  Noted many states now operate this way, so would not be a big change for industry.
 Alternatively to the above, supported Anadarko's language  -  contiguous or adjacent properties means surface site areas within a fixed building, structure, facility or installation including permanent grade or cleared area for such building, etc. that share an edge or boundary, physically touch and are adjoining or physically abutting.
 Stated would need a 1-year transition period if option 2 is adopted or option 1 without revision, because permitting time needed could change depending on the type of permit required; some states will need to revise their statutory language.
 Retroactive concern, for example, that if you have a well field with old well fields, drill a new well, draw (1/4) mile circle around that well and it pulls in 4-5 other existing wells: how do those existing wells affect minor/major status of new well? Believed this is a concern of states also and a burden on resources.
 Noted that no industry supported option 2 and of state and tribal comments 75% were opposed.
 Asserted that applying option 1 within (1/4) mile may involve cross jurisdictional issues between 2 or more states and tribes, becoming a permitting nightmare. Noted that there may be different ownership of land vs leases; surface leases and mineral leases are typically split; multiple owners of different mineral leases; multiple interest owners in single facility and multiple owners of minerals below.
 Noted that ownership changes frequently and would be required to re-aggregate at those times.
 Ownership can change over time on projects lasting a number of years and well drilling can take place over many years with years of no drilling in between.
 Also noted that two sites may be connected with an unconnected site (such as a homestead) in between so this would be counter to the commonsense notion of `plant'.

NSPS Proposal
 Expressed concern regarding changes to subpart OOOO that will be effective retroactively.
 Regarding storage vessels, asked EPA to consider allowing an option to opt out of the rule for equipment like pneumatic pumps and LDAR requirements where states have enforceable equivalent programs.
 Asked for a 1-year phase-in for implementation of OOOO, particularly for LDAR and pumps; the usual 60 days for NSPS is too short a time for leaks. Already a backlog since proposal date to be dealt with and industry and contactors need to ramp up for LDAR program, training, etc.
 Stated depending on pneumatic pump requirements are finalized, if required to control, could take some planning time to do so.
 Requested EPA reevaluate cost effectiveness (CE) of the rule because some of the parameters for CE are not reflective of current and future conditions. The EIA projections from 2014 are off now because of gas prices and industry activity, downsizing.
 Concerned about methane permitting issue  -  OOOOa did not deal with the GHG permitting issue the way OOOO did for power plants. A more solid fix is needed.
 Supported not including liquids unloading requirements.
 BLM Rule
 Noted that BLM released its draft rule and expressed crossover concerns between OOOO and the BLM rule. Asked EPA to work closely with BLM.
 Stated that analyses by EPA and BLM do not include a lot of the same exemptions.
 Regarding crossover with the BLM leak requirements, for example, noted that the BLM rule states that if you have 2 leaks, you must change your monitoring frequency.
 Monitoring Requirements
 Duplicity of monitoring requirements that could be streamlined by having unified monitoring requirements.
 Stated their Table 26-1 compares overlap of requirements. Different closed vent system (CVS) monitoring requirements for controlling pump vs tank, also subject to leak monitoring requirements because CVS is part of the definition of `fugitive emission component'.
 Asked that CVC be defined and that EPA look to subpart HH definition and provide consistency across rules.
 Need clarification regarding monitoring requirements for covers and thief hatches, not part of subpart HH. Also requested clarification regarding controlled vs uncontrolled emissions.
 Preferred one set monitoring requirements for simplicity.
 Regarding well sites and CS, stated the proposed definition for fugitive emissions component (FEC) should be consistent with other definitions for equipment. Suggested language in their written comments.
 Stated dehydrators and pressure vessels are not FEC but have FEC on them (connections, etc.) and believed those types of equipment should be eliminated and the definition more reflective of what historically has been defined in equipment definitions.
 LDAR
 Stated the proposed 15 BOE exemption from leaks is helpful but generally not common for new sites because operators do not drill wells that will only achieve 15 BOE/day. Would be useful as an offramp for LDAR as a well's production declines. Suggested removing control if consistently below 15 BOE for leaks for 1 year.
 Should exempt oil well sites from LDAR where there is no gas because economics work for methane, whereas there is little methane and gas in a strict oil well.
 Flowback exemption for wells below 300 GOR would be an indication that it is a low gas well and the economics would be different. Should be considered exempt because so little gas is available.
 Wellsite
 Stated the definition of `well site' is problematic because it would seem to assume you take a wellhead to a central battery and aggregate to a single well site. Asked for clarity and suggested a central production site could account for an upstream central site that could be a compressor station (CS) or combination compressor station and batteries and then have a transmission CS.
 Concerned that, according to the definition of `modification', refracturing or hydraulic fracturing would be considered a modification of a wellsite. Stated that these activities do not necessarily result in increased emissions.
 Site Survey and Plans
 Stated EPA did not give enough consideration to the cost of leak surveys, such as the cost of transportation to and from a site, training costs, costs of plan development, recordkeeping, etc.
 Stated that EPA assumed a cost of $2 to resurvey a component based on soap bubble, but that it is not apparent that use of the soap bubble test is allowed, which they advocate.
 Asserted there is a corporate-wide plan and site-specific plan and believe there should just be one plan required based on an area. Noted that corporate-wide operations can be different within one company from one part of the country the next.
 Stated it is unnecessary to have diagrams of sites and walking paths because sites typically are too small for this to be necessary.
 Believed the cost estimate is high relative to the amount of methane that will be recovered. They see a long term leak rate of less than 1/10 of 1 percent.
 Because of low leak rates, an annual survey would achieve EPA's goals and make it easier for industry to manage the program, rather than having to track what has to be done quarterly, semiannually, etc.; easier to schedule an area for survey for a particular time.
 Stated that once a site is past the initial survey, there is a diminishing return of survey; leak rate is not typically going to show marked improvement between annual and semiannual survey.
 Expressed that requiring monitoring 30 days from startup does not make sense because during this period they are evaluating controls, etc. Recommend 180 days, ideally 1 yr. Stated 180 days is consistent with subpart VV for startup. Noted a longer period also allows for more sites to become subject to this monitoring. Opportunity to merge these sites into the existing program schedule; more cost efficient and less burdensome. Noted the burden to small firms using contract services.
 Regarding the 6 month repair requirement, API requested an extended delay of repair  -  preferably until next scheduled shutdown.
 Asked that compressor stations that add/replace a compressor without adding capacity not trigger requirements.
 Pumps
 Requested that chemical injection pumps be exempt. Stated EPA analysis; emissions below the equivalence of a low bleed pneumatic controller should be exempt; and diaphragm pumps operated less than 90 days/year should be exempt.
 Stated there needs to be a definition for `control device.' Stated the rule seems to indicate that blowers and heaters are considered controllers but stated these should be considered process devices; they are not designed for control. Preferred a definition similar to subpart HH definition so that blowers and heaters are not mistakenly considered equivalent to a flare.
 Stated costs of controlling pumps underestimated. When routing to a CD you cannot route straight from pump to CD, must route to knockout pump or SV first, otherwise the flow will overwhelm CD. In WY, for example, all are routed to a knockout device or tank first. Also must look at heat input capacity CD can handle. Will have to go back and look at CDs installed since Sept. 18 to see if CD can handle the heat input, requiring engineering analysis and additional costs.
 Noted that a CD may already be subject to other requirements because of state permitting.
 Noted that requirements CDs are very complicated for each device and totally different between tanks and pumps because they follow centrifugal compressor requirements.
 Stated the rule currently does not allow going to knockout or tank first.
 Stated that EPA underestimated the impacts of the rule  -  additional operating, monitoring, recordkeeping, testing, etc.; none of which were added to the cost estimate. EPA also did take into account the technical feasibility of routing nor account for when an onsite control device belongs to another party.
 Requested a portable pump exemption.
 Commented that there is no provision for a facility that is no longer an affected facility.
 Recommended phasing in the rule, in part, due to the backlog of sites that will become subject retroactively to the rule.
 Recordkeeping and Reporting
 Stated the requirements for non-affected pumps to certify that they are not affected facilities and not subject to the rule does not add any value.
 Believed reporting pump control devices was also unnecessary and duplicative because they would already be reporting CDs under another state or other reporting requirement. Noted this effort was not also accounted for in the cost estimate.
 Stated CDs need further clarity because of circular referencing. Asserted, for example, that the initial PT does not appear consistent between subparts OOOO, OOOOa and the CTGs.
 Expressed confusion over CPMS requirements, for example, SVs look like they require a PT, whereas in the CTGs it appears they may not. Stated that CPMS requirements were not intended to apply to storage tanks and are not very clear.
 CPMS should not be required for SV because most are at well sites and no infrastructure is in place to handle CPMS plus most very small and even in subpart ZZZZ area sources do not have these requirements.
 Asked if the CEDRI system will allow them to report under a group of facilities as they are currently doing.
 Stated that LDAR recordkeeping seems overly burdensome. Opposed having to take photos. Does the requirement mean one photo of site or one each component or one each leaking component?
 Asserted the rule seems to encourage the use of flares because as far as PT and monitoring requirements go, it would appear best for industry to install flares.
 Stated the amount of confirmation required for at pneumatic pumps and compressors falls within CPMS requirements so additional regulation is unnecessary. Do not have a full plan for pilot confirmation, would need a full monitoring plan for how to ensure accuracy measurement.
 Regarding the requirements in section 60.18 for velocity measurement, stated that when conducting a PT, you never see maximum velocity, only a very low velocity. Therefore, suggested OOOO use a specific provision to require a design calculation instead of a velocity measurement.
 Stated they would be disappointed if the FR includes next generation compliance without a proposal.
 Asked for exemptions for oil well completions and for separators on site for initial flowback stage on wells they typically think will not need to be separated.
 Because of potential backlog of wells coming on line since Sept. 18, asked if wells drilled but not completed before effective date would be exempt.
 Believed the pneumatic pump requirements for CDs and CPMS ought to be the same as for SVs and not the same as centrifugal compressors.
 Testing
 Regarding CD standards, noted the rule lists 4 standards options and wanted assurance that you can pick your compliance option, then pick your PT to meet that.
 Concerned that the PT requires a percent by weight calculation but then you need a speciated composition so you can add up VOC and need flow to calculate on a mass basis, yet mass basis was not set in the rule, only percent reduction.
 Recommended using a carbon balance method wherein proving destruction by carbon balance, using M25a.
 Stated rule should clarify the use of design calculations which are always within a few percent of max.
 Stated it is unclear if a FIP needs continuity if designated nonattainment. Expressed the importance of ensuring that while planning is going on the SIP does not apply just because it is designated nonattainment; extend FIP until SIP is approved.
 Stated nothing in the proposed rule accommodates synthetic minors and supported an alternative compliance option. Did not see why there should be a difference between a synthetic minor and a true minor source.
 Requested clarity on endangered species issues. Believed statements in the preamble mean that it would not trigger federal action or ESA requirements. Prefer submitting what they did for EIS. Will an older EIS be appropriate? Would use of BLM's application for permit to drill APD be sufficient?
 Regarding case-by-case permitting at EPA discretion for site specific permit, asked for clarity regarding criteria for this.
 Asked for a process in the FIP to allow an operator with major sites to make them minor.

Control Technique Guidelines
 Concerned with overlap between CTGs and subpart OOOO, believing some requirements appear to be different between the two that they do not believe were intended. For example, CTGs require CPMSs on SV where subpart OOOO does not.
 Urged EPA to delay the CTGs for 6 months after subpart OOOO so that issues can be dealt with in the CTGs.
 Noted that the CTGs are guidelines for states, while a lot of states have their own regulations. Stated the preamble to the FR should remind states of the flexibility they do have.
 Asserted that compliance assurance issues can be more of a burden than emission reduction issues.
 Asked if states will have the flexibility to modify the CTGs equally.
 Stated that the CTGs should contain a minimum VOC threshold.
 Requested that the OOOO provision to remove CDs at 4 tpy should be carried over to the CTGs.