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Need rule of thumb for burner emissions guarantee

Need rule of thumb for burner emissions guarantee

Need rule of thumb for burner emissions guarantee

(OP)
Hello all,
I just found the forum. I'm a ChemEng with PE in Environmental and 10 yrs of air permitting practice in the midwest.

Problem:
I can't get any information from the burner manufacturer.
I have design case emissions at 0.0600 lb NOx/MMbtu
What I need to do is add a margin to the emission rate; 0.0600 + X
(Source: ~500 MMbtu/hr LNB firing NG)

The stack testing confirmed operation at that level but it was tight. So, is there a rule of thumb burner manufacturers use to get there guaranteed emission rates? Is 10% margin adequate?

Normally I just get the manufacturer's guaranteed rates, this time I'm working it backwards.

RACT/LAER research shows some burners in this size range were permitted at 0.0125 lb NOx/MMbtu (initail permit, to be modified after stack test). I know the regulatory agency will not buy a 100% increase in emissions as a "margin" for operating variances.

Thanks,

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