From: Szurgot,Andrew

To: Dixon, Kenneth

Cc: mlee@kooglerassociates.com; Karl Seltzer (kseltzer@kooglerassociates.com); Bodine, Susan

(Susan.Bodine@btlaw.com); Robert Cleaves (BPA) (rcleaves@biomasspowerassociation.com); William Turley

(turley@cdrecycling.org)

Subject: Re: C&D data followup question

Date: Wednesday, March 27, 2013 12:54:06 PM

Attachments: image003.png

Covanta Niagara C&D Wood Data 3-25-13.xls

Lab report 581691.pdf

Lab report 683108.pdf

Lab report 684797.pdf

Lab report 728266.pdf

Lab report 916193.pdf

Ken, the explanation below along with the attached Excel spreadsheet and example lab reports should

address your question concerning the New York C&D wood data and provide you with the information

needed for your review. In response to your February 25 e-mail and also to assure the accuracy of

the data, we decided to reconstruct the New York C&D wood contaminants table directly from available

lab reports instead of relying on the facility’s lab data summary spreadsheets as we had previously.

The resulting attached Excel C&D Wood Data file should therefore represent accurate and documented

results for the New York C&D wood.

To address your specific questions about the difference in maximum chlorine levels between the

October and December submittals I offer the following explanation which hopefully will clarify this

matter. We obtained C&D wood data presented in Covanta’s February, 2012 NHSM rule comments

(EPA-HQ-RCRA-2008-0329-1893) from annual spreadsheet summaries of the lab data that we

prepare at our Niagara Falls facility, i.e. a lab report is received at the facility and the data are

manually recorded in the annual spreadsheet. The facility spreadsheet summaries indicate that the

results are “as received” so for our February, 2012 comments we first compiled those facility recorded

results into Table 1A (as received results) and then converted them to a dry basis in Table 1B using

each sample’s reported moisture. Prior to the BPA/CMRA December 7, 2012 final petition submittal

we obtained and spot checked several recent lab reports and discovered that the mercury and chlorine

results recorded in the facility spreadsheets as “as received” were actually already on a dry basis and

did not need to be converted. (See, e.g., lab report 916913.) So for the December, 2012 petition we

corrected the mercury and chlorine results accordingly. This is why the dry basis mercury and chlorine

results in the December submittal are lower than those in the February comments Table 1B and in the

October draft petition submittal. Subsequently, to assure accuracy we conducted a complete bottomup review of the NY data by gathering all available lab reports and reconstructing a NY C&D wood

contaminant table directly from these reports rather than the facility spreadsheets. The reconstructed

table, Table 2 in the attached Excel C&D Wood Data file, records dry basis results directly from the

lab reports so there is no need for conversion. This also eliminates issues with rounding errors and

incorrect/missing entries found in the facility spreadsheets. Hopefully, this Excel file and the lab reports

will eliminate any confusion about the basis and provide accurate and verifiable data for purposes of

our petition. 

In reviewing the attached Excel file please note the following:

1. Lab reports were available only back through February, 2005. Neither the facility nor the

laboratory, C&G Coal Analysis Lab, Inc., maintain records prior to that date. However, we were able to

find all but a few of the reports listed in the facility spreadsheets for the 2005-12 period, and data

reported in Table 2 represent in excess of 90 samples for most contaminants;

2. Like mercury and chlorine, we discovered that the fluorine data recorded in the facility

spreadsheets are on a dry basis. (See, e.g., lab reports 683108 and 684797.) We also confirmed with

the C&G lab office manager that the chlorine results for samples prior to March, 2007 were reported

on a dry basis, even though that is not specified on the reports prior to that date. (See, e.g., lab report

581691 which does not specify that the chlorine level is reported on a dry basis and lab report 728266

which specifies that it is.) The fact that the lab did not specify that chlorine results in these earlier

reports were reported on a dry basis is why the plant started recording these results “as received” in
the first place.); and,

3. In our facility records search we found additional lab reports for wood samples, mostly C&D

related wood, taken from individual supplier loads in 2007. (See, e.g., lab report 684797.) While these

results are for individual wood sources as opposed to the boiler feed wood represented by the other

data, they are representative of C&D wood received at the facility and should be included in the NY

data. These “test wood” data are included as Table 3 in the attached Excel spreadsheet and will be

included in the revised NY data table that BPA/CMRA will submit shortly.

Hopefully this addresses your questions and provides a supportable NY database for your review.

BPA/CMRA will soon submit a revised Appendix A and Excel Traditional Fuel Comparison

spreadsheet which incorporates the reconstructed NY data table and replaces the earlier table. If you

have any further question please don’t hesitate to contact us.

_____________________________________________________

Andrew M. Szurgot

Principal, Stratosphere, LLC

Consultant to Covanta Energy Corporation

Covanta Energy Corporation

445 South Street

Morristown, New Jersey 07960

Tel: 862-345-5426

www.CovantaEnergy.com

P Please consider the environment before printing this email.

From: Dixon, Kenneth [mailto:Dixon.Kenneth@epa.gov]

Sent: Monday, February 25, 2013 2:34 PM

To: mlee@kooglerassociates.com

Cc: 'Karl Seltzer'; Szurgot,Andrew

Subject: RE: C&D data follow-up question

Hi Max,

I’ve been operating under the assumption that all C&D contaminant data (Maine,

Washington, Minnesota, Massachusetts, New York, as well as the WM data from Wisconsin,

California, and Massachusetts) has been presented on a dry basis. That’s what I gathered

from the original February 2012 spreadsheets, the fact that the traditional fuel contaminant

data it’s compared to is all on a dry basis, and the WM sampling description. If that’s not the

case, we need to resolve what we have before moving forward with our proposal. 

I see footnote 2 in the New York table states “all values are reported as Dry Basis,” but it’s

the same in the October and December 2012 versions. I didn’t pay it much attention because

I assumed all contaminant data—New York and otherwise—in the submission was dry basis.

Thanks,

Kenneth Dixon

Environmental Engineer

U.S. EPA, Office of Resource Conservation and Recovery

703-300-2454 

From: Dr. Max Lee [mailto:mlee@kooglerassociates.com]

Sent: Monday, February 25, 2013 1:12 PM

To: Dixon, Kenneth

Cc: 'Karl Seltzer'; aszurgot@covantaenergy.com

Subject: RE: C&D data follow-up question

Hi Ken,

I am glad you noticed the change which started when Andrew Szurgot noticed that all of the

mercury and chlorine NY data was first submitted on a wet basis (as-fired) when in fact the

samples were analyzed and reported to the NY facility on a dry basis. Andrew reviewed all
of the NY data individual reports and revised the submitted information to all be on a wet

basis like the rest of the analytical data. The revised dry basis concentrations of mercury and

chlorine to wet basis are now lower than they were in the previous submittal.

Andrew is the expert on that data so I have copied him on this email. He can provide more

detail as needed. I believe we noted this in the spreadsheet and am reviewing for that

comment in the sheet notes.

Thanks for your thorough review.

Max

Max Lee, Ph.D., P.E.

President

www.kooglerassociates.com

Koogler and Associates, Inc.

4014 NW 13th st.

Gainesville, FL 32609

Office 352 377-5822

Cell 352 318 4450

mlee@kooglerassociates.com

From: Dixon, Kenneth [mailto:Dixon.Kenneth@epa.gov] 

Sent: Monday, February 25, 2013 11:44 AM

To: Dr. Max Lee (mlee@kooglerassociates.com )

Cc: 'Karl Seltzer'

Subject: C&D data follow-up question

Hi Max,

I’ve got a follow-up question on the C&D data, related to chlorine: 

· February 2012 comments to the proposed rule, table lists 169 samples with max value of 11,847

· October 2012 updated dataset, table lists 175 samples with max value of 11,847 (one of the 138

samples from New York). The non-representative 1992 and 1995 New York datasets had supposedly

been removed for this dataset. Additional data from other states had been added at the same time,

explaining why the overall number of samples increased.

· December 2012 latest dataset (Attachment A sent by Susan Bodine), table lists 175 samples with max

value of 9,940 (one of 138 values from New York). Footnote 6 in Susan’s petition request explains

that February 2012 data not included in December 2012 is due to the removal of the 1992 and 1995

New York datasets.

 If the New York datasets had already been removed, the total number of samples stayed the

same, and the number of New York samples stayed the same, what happened to the 11,847

ppm value for chlorine?

Thanks,

Kenneth Dixon

Environmental Engineer

U.S. EPA, Office of Resource Conservation and Recovery

703-300-2454