Attachment A February 28, 2013

ncasi Page 1 

### Comparison of Contaminant Concentrations in

Cross Tie-Derived Fuel with Traditional Fuels

On November 29, 2011, EPA published a document t itled “Contaminant Concentrations in Traditional Fuels: Tables for Comparison”. This documen t contained ranges and averages for contaminant concentrations in three common traditional fuels namely coal, biomass and fuel oil. EPA indicated that members of the regulated community could use the data when comparing contaminants in their nonhazardous secondary materials (NHSMs) to contaminan ts in the appropriate traditional fuels. EPA presented three tables with contaminant data summa rized from both the scientific literature and EPA databases for coal, wood/biomass, and fuel oil. In this report, limited available contaminant data for samples of cross tie-derived fuel (CDF) are compar ed with those compiled by EPA for the three common traditional fuels coal, biomass and fuel oil. At the curr ent time, CDF is burned in thirty or more industrial

boilers.

EPA agrees that “when compared to the full range of contaminants in traditional fuels, suitable measures of NHSM contaminants would include the upper end of a statistical range, a calculation involving the mean and standard deviation, or perhaps a single data point in situations where data is limited.” 78 Fed. Reg. 9112, 9153 (Feb. 7, 2013). For example, EPA agreed that it is appropriate to compare “the UPL at the 90 percent confidence level for each contaminan t or group of contaminants in NHSMs to the maximum values for each contaminant or group of cont aminants in the appropriate traditional fuel.” Id

. Thus, in the case of CDF samples, since insuffici ent data are available to estimate 90% UPLs, a comparison of the maximums in the available analy tical data with the maximums presented by EPA for the traditional fuels coal, biomass and oil should consti tute a reasonable albeit conservative approach for contaminant comparison.

Table 1 presents the results of analysis of various CDF samples for the eleven trace metal HAPs and for several major elements including Cl, Fl, N, and S. The sources of data included a recent CDF test report prepared by All4 Inc. on behalf of M.A. Energy Resources, LLC and presented to EPA, selective data

from EPA references summarized in Table A2 of NCASI Technical Bulletin No. 906 (2005), and recent CDF fuel sampling data extracted from EPA’s Boiler MACT Database. The latter corresponded to five facilities – ALIPPrattville, ALIPRiverdale, AREver greenPackaging, LABoiseNewsprintDeRidder, and NDADMNorthernSun, four of which were pulp mills.

Table 2 presents the results of analysis of various CDF samples for several VOC HAPs, semi-volatile VOC HAPs, total PAHs and naphtha lene (also a PAH). The data were obtained from several sources including tests for a range of individual PAHs, VOCs and SVOCs carried out by M.A. Energy Resources, LC, tests for several PAHs carried out by URS Corp. on behalf of the Association of American Railroads (at two U.S. facilities, Duluth, MN and Selma, AL), and some historical PAH, VOC and SVOC data obtained from an EPA source (Wood Waste Energy).

Table 3 compares the maximum values in the OAQPS da tabases for coal, wood/biomass, and fuel oil with the range of values that were summarized in Tables 1 a nd 2 for cross tie-derived fuels. The comparison is made between groups of contaminants that share ph ysical and chemical properties that influence their

behavior in a combustion unit. Id . at 9146. The contaminants are grouped as three types of trace metal HAPs (volatile, semi-volatile and low volatile), to tal VOC HAPs, total semi-volatile VOC HAPs, and total PAHs. It is seen that for all the categories of comparison, the grouped contaminants fall well within the range of the same grouped contaminants for one or more of the traditional fuels used for comparison.Attachment A February 28, 2013

ncasi Page 2 Conclusion

Based on the available data for cross tie-derived fu els summarized in Tables 1 and 2, and the relevant comparisons made in Table 3 with the OAQPS database for the traditional fuels coal, biomass and oil, the contaminants in CDF fall well within the range of c ontaminants found in one or more of three traditional fuels, coal, biomass and oil, thus supporting a determ ination that cross tie-derived fuel is not a waste

when combusted.Attachment AFebruary 28, 2013ncasiPage 3Table 1.Trace Metals and Major Elements in Various Cross Tie-Derived FuelsUnits,dry basisMAER1NCASI TB 906aBoiler MACT Fuel Analysis Databn2mean min max n3n2mean min maxHeat Value Btu/lb 35 8,970 8,828 7,394Trace Metal HAPsAntimony (Sb) ppm <5Arsenic (As) ppm <10 6 1.75 1.38 2.15 4 25 1.78 1.03 3.16Beryllium (Be) ppm <0.5 4 25 0.12 0.06 0.30Cadmium (Cd) ppm <0.5 1 0.10 4 25 0.26 0.23 0.30Chromium (Cr) ppm <2.5 8 0.67 0.23 1.44 4 25 9.68 3.97 15.28Cobalt (Co) ppm <2.5Lead (Pb) ppm <10.0 1 8.00 4 22 7.55 4.09 9.58Manganese (Mn) ppm 63 4 25 135 104 185Mercury (Hg) ppm 0.02 1 <0.25 5 25 0.04 0.02 0.05Nickel (Ni) ppm <5 1 <5.0 4 35 13.78 3.73 38.24Selenium (Se) ppm <5 4 25 0.57 0.14 1.00Major ElementsChlorine (Cl) ppm 400 5 225 39 345 5 35 81 22 161Fluorine (F) ppm 100Total Halogens (Cl + Fl) ppm 500Nitrogen (N) ppm 1,600 28 6,142 3,574 141Sulfur (S) ppm 800 34 1,700 681 3,277 1 1 1,1001M.A. Energy Resources, LLC CDF Testing (March 2013);2no. of samples tested;3no. of mills at which CDF was tested with no. of samples ranging from2 to 10aFrom Table A2 of NCASI Technical Bulletin No. 906 – Sources included the following:1. Emissions Database Test Report E710, "Compliance Stack Emissions Report/1996 for the Waste Wood-Fired Boiler", by AirRECON,March 10, 19972. Results of the March 23-26, 1993 Air Emission Tests on the No. 1 Boiler Stack at the NSP Bay Front Steam Plant, Interpoll Labs, April 26, 1993.3. Emissions Database Test Report E721, "Results of the November 12-14, 1991 State Air Emission Compliance Tests on the No. 5& 6 Boilers at theBlandin Paper Company Plant in Grand Rapids, Minnesota", by Interpoll Laboratories, Inc., January 17, 19924. Emissions Database Test Report E860, "Results of the October 7-9, 1997 Air Emission Compliance Tests of Unit 1 at the NSP French Island Plant in LaCrosse, Wisconsin", by Interpoll Laboratories, Inc., November 5, 19975. "Wood Products in the Waste Stream -- Characterization and Combustion Emissions", by Atkins, Richard S. and Donovan, Christine T. assubcontractors to New York State Energy Research and Development Authority, October 1996bEPA’s Boiler MACT Database - Fuel Sampling Data for Rail RoadTies at 5 Facilities – ALIPPrattville; ALIPRiverdale; AREvergreenPackaging;LABoiseNewsprintDeRidder; NDADMNorthernSunAttachment A February 28, 2013

ncasi Page 4 Table 2. VOCs, SVOCs, PAHs and Naphthalene in Various Cross Tie-Derived Fuels

Compound Units MAER 1 Duluth, MN 2 Selma, AL 2 EPA 3

VOC HAPs 1
Benzene ppm <0.050 Cumene ppm <0.050 Ethyl benzene ppm 0.0575 Formaldehyde ppm <1.60 Styrene ppm <0.050 Toluene ppm <0.050 Xylenes ppm 0.325

Semi-Volatile VOC (SVOCs) HAPs Phenol ppm <15 Biphenyl ppm 137 Dibenzofuran ppm 789 Quinoline ppm 40

Total SVOCs 1,4,5 966

Base Neutral SVOCs 6
Total PAHs ppm ~ 7,200 18,318 - 23,150 12,601 - 24,533 21,237 Naphthalene ppm 444 1,100 – 1,400 2,600 – 3,200 490

1 M.A. Energy Resources, LLC CDF Testing, March 2013

2” Evaluation of Used Railroad Ties Treated With Creosote and POMs Which Includes PAHs”; prepared for the Association of Amercan Railroads by URS Corp., Jan. 28, 2013

3 Data received from EPA - Wood Waste Energy

4 SVOCs m- & p-cresols were also detected in “trace amounts” in a TCLP sample extract (0.076 mg/L)

5 Lindane was also detected in trace amounts

6 Although Naphthalene is a PAH, it is separate d out here consistent with EPA’s approachAttachment A February 28, 2013

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Table 3. Comparison of Typical Cross-Tie Concentrations With OAQPS Max for Coal, Biomass & Oil

Compound Units OAQPS

Coal Biomass Fuel Oil CDF

Max Max Max n 1 Min Max

Trace Metal HAPs Volatile Metals (Hg) ppm 3.1 1.1 0.2 35 0.023 0.05

Semi-Volatile Metals (Pb,
Cd, Se) ppm 241 255 57 25 3 23

Low-Volatile Metals (Sb,
As, Be, Cr, Co, Mn & Ni) ppm 1,822 16,842 3,551 25 93 153

Major Elements Chlorine (Cl) ppm 9,080 5,400 1,260 41 22 400 Fluorine (F) ppm 178 128 14 1 100 100 Total Halogens (Cl + Fl) ppm 9,258 5,528 1,274 32 122 500 Nitrogen (N) ppm 54,000 4,600 3,000 29 1,600 14,400 Sulfur (S) ppm 61,300 6,100 57,000 36 681 3,277

Total VOC HAPs 2 ppm 153.4 27 13,745 1 0.38

Total SVOCs 3 ppm 8,900 1 966

Total PAHs 4 ppm 2,090 5 54,700 4 7,200 24,533

1 no. of samples tested; 2 includes benzene, cumene, ethyl benzene, formaldehyde, styrene, toluene and xylenes;

3 includes phenol, biphenyl, dibenzofuran and quiniline; 4 includes naphthalene; 5 PAH (52 extractable);