p. 1 of 4 

From: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Monday, August 19, 2013 11:15 AM 

To: Putney, David 

Subject: FW: ICR data 

More information from Clean Air based on your latest set of questions. 

Don Backfisch 

From: Scott Brown [mailto:sbrown@cleanair.com] 

Sent: Monday, August 19, 2013 9:41 AM 

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data 

Don, See my responses below.

We can issue a revised report as soon as you give the word.

Scott Brown

From: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Monday, August 19, 2013 7:48 AM 

To: Scott Brown (sbrown@cleanair.com) 

Subject: FW: ICR data

 

I received a couple of more questions from David Putney at EPA concerning the ICR testing. Sorry 

for the delay in getting them to you.

Don Backfisch

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Saturday, August 03, 2013 4:27 PM 

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data

 

Don,

Thanks so much for the new spreadsheets. I’m actually out of the office until Monday, 08/12/13 – so I will not 

get a chance to take a good look at them until I get back.

Also, let me say that I have no authority (or desire) to require you to make changes to the report – I am only 

suggesting changes that I think will avoid confusion, and the resulting questions, later on (i.e., during the public 

comment period). Further, I do not pretend to be reviewing every line of the report – just spot checking that 

information that I believe will be subjected to the greatest scrutiny. Therefore, my quick spot-check review is 

focused on the emissions tables and especially the PCB and D/F (i.e., those pollutants that we did not expect 

to find or at least not in any sizeable quantities). You may want to do a more thorough review (e.g., of the 

report text and/or calculations) than I can afford to do. Finally, when I am reviewing reports such as these my 

eye is drawn to inconsistencies – which can draw questions as quickly as errors, or cause other problems such 

as causing people (correctly or not) to make assumptions.
p. 2 of 4 

So, with that said, let me respond to Scott’s statement and point out a couple of other items I noticed.

• As Scott points out, a footnote under summary Table 1-2 and the referenced text on page 1-4 

indicate that the roof emissions are based on total roof flows. What jumps out at the reader in this 

table is that the PCB emissions are on the same order of magnitude as the PAH emissions – a totally 

unexpected result and one that would most certainly draw attention during the public comment 

period. Hopefully this will change when the pg to ng switch that was mentioned earlier gets addressed.

Also, I found it confusing that Table 1-2 specifies that the roof emissions are based on roof exhaust 

flow rates whereas Table 2-4, 2-6, 2-9 and 2-10 (i.e., the tables for the PCB and PAH roof emissions) list 

the lb/hr emissions for PCB homologue groups and individual PAH species based on manifold flow 

rates. Maybe specify in these tables that E lb/hr is the manifold emission rate?

Yes the total PCB emissions are substantially lower after going from pg to ng. I did not calculate the 

individual lb/hr cogener or homologues groups using the total roof flow, just the manifold flow. The 

only thing I calculated using the toal flow was the total PCDD?PCDF, PCB and PAHs. Our spreadsheets 

had to amended considerably just to include the total lb/hr results based on the Method 14 calcs. 

• Tables 2-2, 2-7, 2-12, and 2-17 include an asterisk (*) beside many of the D/F congeners and a 

footnote explaining that this symbol indicates results that include NDs and/or EMPCs. However this 

footnote is not included for Tables 2-21 and 2-25 (which also include a * beside many of the D/F 

congeners).

I added the footnote to those tables and it will be in the revised report

• The information is in the lab data of the report and we can certainly generate our emissions files 

from that data, but I’m just curious as to why the tables in section 2 of the report do not list all of the 

PCB and D/F emissions. That is, for example Table 2-2 lists the D/F emissions from Roof 2 in toxic 

equivalencies but not actual emissions and Table 2-4 lists the emissions of the PCB homologue groups 

from Roof 2 but not for the individual PCB congeners as cited in the lab results (e.g., PCB77 –on page

G-145 of the final report).

I tried to supply as much information as possible in the report utilizing our standard spreadsheets. The 

PCDD/PCDF spreadsheet had that data already broken down that way, the PCB do not. You do have to 

understand that the amount of data that I had to deal with in terms of reporting was a little mind 

boggling. If I had actually expanded the PCB results to show everything this report would be 

enormous. It should also be noted the PCB and PAH testing is rarely performed these days therefore 

our spreadsheets are not as “friendly” as some of the more common methods.

• Tables 2-2, 2-7, 2-12, and 2-17 list the Toxic Equivalency Factor (TEF) as 1.0000 for every 

congener. Typically, the congeners are assigned a TEF relative to the toxicity of 2,3,7,8-TCDD. That is, 

the TEF for 2,3,7,8-TCDD is equal to 1.0000 and the TEF for each of the other congeners is some value 

less than 1.0000 reflecting its lower level of toxicity relative to 2,3,7,8-TCDD (e.g., the TEF for 

1,2,3,4,7,8,9-HpCDF is 0.01). Note that these TEF (that is, other than all 1.0000) are cited in the lab 

results (see for example page G-122 of the final report). I do not follow the contractor’s method in 

these tables.

Again this is the way our spreadsheets are set up to present the data. In this case stating the TEF 

equals one is just pointing out that the full reported values are being used, not an agencies defined 

lower toxicity multiplier. I know that has confused other people in the past. I should probably hide

that for future reporting purposes.

Thanks,
p. 3 of 4 

David Putney, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243-02

Ph: (919) 541-2016 Fax: (919) 541-3207

Email: putney.david@epa.gov

From: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Friday, August 02, 2013 3:01 PM 

To: Putney, David 

Subject: FW: ICR data

 

David,

Attached are the ERT spreadsheets with the corrected PCB data. Below is Scott Brown’s response 

concerning the roof data reporting.

Don, The footnote on table 1-2 states that the lb/hr results are based on the total flow rate per method 14. It 

is also reiterated in the second to last paragraph on page 1-4. I am not sure what David wants me to do in 

regards to this. 

We will amend the report as to the PCB revision. 

Scott B.

I will be out again next week, but shouldn’t be out very often after that.

Don Backfisch

From: Scott Brown [mailto:sbrown@cleanair.com] 

Sent: Friday, August 02, 2013 1:40 PM 

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data

 

Don, Attached are the ERT spreadsheets with the PCB data corrected. I will hold off on issuing a revised report 

until all issues have been dealt with.

Scott B. 

From: Backfisch Don (NORALNM) [mailto:Don.Backfisch@noralinc.com] 

Sent: Friday, August 02, 2013 7:24 AM 

To: Scott Brown (sbrown@cleanair.com) 

Subject: FW: ICR data

 

Further comments from David Putney on the ICR report. I will pass his comments on to you as I 

receive them. When we have responded to all of his comments and questions, we will need to submit 

a corrected “final” report and spreadsheet. 
p. 4 of 4 

Don Backfisch

From: Putney, David [mailto:putney.david@epa.gov] 

Sent: Thursday, August 01, 2013 4:23 PM 

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data

 

Don,

It would be preferable to get a corrected report and spreadsheets since those items will eventually be added 

to the docket for this rulemaking action. That is, it would probably better to simply put the corrected versions 

in the docket as opposed to the originals with additional documents to show corrections. Also, I agree with 

your approach of addressing all the issues before resubmitting the report. However, it would be good to know 

the answers to my questions when you get the information. That is, please inform me of the lab’s response 

when you get it – as opposed to waiting until the revised report is completed.

I actually have a follow up comment/question to my email from yesterday. Based on a quick review of the 

secondary potline PCB emissions (presented in Table 2-4 of the final report), it appears that those emissions (in 

units of lb/hr) are based on the downcomer flow rate (as opposed to the roof vent flow rate). For example, 

when I attempted to reproduce the Mono PCB emissions associated with run 1 on the roof 2 duct, I came up 

with emissions values of 1.65 E-04 lb/ton and 1.71 E-03 lb/hr. These match the values in your summary 

spreadsheet but not the lb/hr emission value in Table 2-4 of the Final Report. However, the lb/hr emission rate 

for Mono PCB does match if I use the downcomer flow rate instead of the roof vent flow rate. This could be a 

source of confusion during the public comment period. You may want to either modify the table in the report 

to clarify that the lb/hr values are based on the downcomer flow rates, or modify the emissions values to 

represent emissions based on roof vent flow rates.

Also, as mentioned in my previous email, the reported PCB emissions values appear to be overestimated by a 

factor of 1,000 as a result of the lab reporting their results in units of picograms (pg) but those results being 

changed to units of nanograms (ng) in the spreadsheets and Final Report tables. (See for example, the mass 

value for Mono PCBs from run 1 on the roof 2 duct – cited as 250 ng in the spreadsheets and Table 2-4 in the 

Final Report as opposed to 250 pg as shown in the lab data on page G-149 of the report). This would certainly 

be something that should be revised before putting the document in the docket.

Thanks,

David Putney, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

109 T.W. Alexander Drive, RTP, NC 27711

Mail Drop D243-02

Ph: (919) 541-2016 Fax: (919) 541-3207

Email: putney.david@epa.gov