Attachment A 

February 28, 2013 

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Comparison of Contaminant Concentrations in 

Cross Tie-Derived Fuel with Traditional Fuels 

On November 29, 2011, EPA published a document titled “Contaminant Concentrations in Traditional 

Fuels: Tables for Comparison”. This document 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 contaminants in the appropriate traditional fuels. EPA 

presented three tables with contaminant data summarized 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 compared with those compiled by EPA for the three common 

traditional fuels coal, biomass and fuel oil. At the current 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 contaminant or group of contaminants in NHSMs to the 

maximum values for each contaminant or group of contaminants in the appropriate traditional fuel.” Id. 

Thus, in the case of CDF samples, since insufficient data are available to estimate 90% UPLs, a 

comparison of the maximums in the available analytical data with the maximums presented by EPA for 

the traditional fuels coal, biomass and oil should constitute 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, AREvergreenPackaging, 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 naphthalene (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 databases for coal, wood/biomass, and fuel oil with 

the range of values that were summarized in Tables 1 and 2 for cross tie-derived fuels. The comparison is 

made between groups of contaminants that share physical 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), total 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. 

 
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Conclusion 

Based on the available data for cross tie-derived fuels 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 contaminants found in one or more of three traditional 

fuels, coal, biomass and oil, thus supporting a determination that cross tie-derived fuel is not a waste 

when combusted. 
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Table 1. Trace Metals and Major Elements in Various Cross Tie-Derived Fuels 

Units, 

dry basis MAER1

NCASI TB 906a Boiler MACT Fuel A

n2 mean min max n3 n2 mean 

Heat Value Btu/lb 35 8,970 8,828 7,394 Trace Metal HAPs Antimony (Sb) ppm <5 Arsenic (As) ppm <10 6 1.75 1.38 2.15 4 25 1.78 Beryllium (Be) ppm <0.5 4 25 0.12 Cadmium (Cd) ppm <0.5 1 0.10 4 25 0.26 Chromium (Cr) ppm <2.5 8 0.67 0.23 1.44 4 25 9.68 Cobalt (Co) ppm <2.5 Lead (Pb) ppm <10.0 1 8.00 4 22 7.55 Manganese (Mn) ppm 63 4 25 135 Mercury (Hg) ppm 0.02 1 <0.25 5 25 0.04 Nickel (Ni) ppm <5 1 <5.0 4 35 13.78 Selenium (Se) ppm <5 4 25 0.57 Major Elements Chlorine (Cl) ppm 400 5 225 39 345 5 35 81 Fluorine (F) ppm 100 Total Halogens (Cl + Fl) ppm 500 Nitrogen (N) ppm 1,600 28 6,142 3,574 141 Sulfur (S) ppm 800 34 1,700 681 3,277 1 1 1,100 

1M.A. Energy Resources, LLC CDF Testing (March 2013); 2no. of samples tested; 3no. of mills at which CDF was tested with no

2 to 10 

aFrom 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 AirR

2. Results of the March 23-26, 1993 Air Emission Tests on the No. 1 Boiler Stack at the NSP Bay Front Steam Plant, Interpoll La3. Emissions Database Test Report E721, "Results of the November 12-14, 1991 State Air Emission Compliance Tests on the No

Blandin Paper Company Plant in Grand Rapids, Minnesota", by Interpoll Laboratories, Inc., January 17, 1992 

4. Emissions Database Test Report E860, "Results of the October 7-9, 1997 Air Emission Compliance Tests of Unit 1 at the NSP 

Crosse, Wisconsin", by Interpoll Laboratories, Inc., November 5, 1997 

5. "Wood Products in the Waste Stream -- Characterization and Combustion Emissions", by Atkins, Richard S. and Donovan, Ch

subcontractors to New York State Energy Research and Development Authority, October 1996 

bEPA’s Boiler MACT Database - Fuel Sampling Data for Rail Road Ties at 5 Facilities – ALIPPrattville; ALIPRiverdale; AREve

LABoiseNewsprintDeRidder; NDADMNorthernSun 
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Table 2. VOCs, SVOCs, PAHs and Naphthalene in Various Cross Tie-Derived Fuels 

Compound Units MAER1

 Duluth, MN2 Selma, AL2 EPA3

VOC HAPs1 

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 SVOCs1,4,5 966 

 

Base Neutral SVOCs6

 

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 separated out here consistent with EPA’s approach 

 
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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 n1 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 HAPs2 ppm 153.4 27 13,745 1 0.38 

 

Total SVOCs3 ppm 8,900 1 966 

Total PAHs4 ppm 2,0905 54,700 4 7,200 24,533 1

no. of samples tested; 2includes benzene, cumene, ethyl benzene, formaldehyde, styrene, toluene and xylenes; 3

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