### 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 lates t 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 t he 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 Pu tney 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 actual ly 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 ge t back.

Also, let me say that I have no authority (or desir e) to require you to make changes to the report – I am only suggesting changes that I think will avoid confusio n, and the resulting questions, later on (i.e., dur ing the public comment period). Further, I do not pretend to be re viewing every line of the report – just spot checki ng 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 no t 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 qu estions as quickly as errors, or cause other proble ms such as causing people (correctly or not) to make assump tions.

### p. 2 of 4

So, with that said, let me respond to Scott’s state ment and point out a couple of other items I notice d.

• 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 ord er 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 n g 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 in dividual 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 th e 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 tot al 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 resu lts 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 an d 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 o f 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 congener s 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 i n 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 de al with in terms of reporting was a little mind boggling. If I had actually expanded the PCB resul ts 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 t he more common methods.

• Tables 2-2, 2-7, 2-12, and 2-17 list the Toxic Equi valency Factor (TEF) as 1.0000 for every congener. Typically, the congeners are assigned a T EF relative to the toxicity of 2,3,7,8-TCDD. That i s, 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 toxi city 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 la b results (see for example page G-122 of the final re port). I do not follow the contractor’s method in
these tables. Again this is the way our spreadsheets are set up t o present the data. In this case stating the TEF equals one is just pointing out that the full repor ted values are being used, not an agencies defined lower toxicity multiplier. I know that has confuse d 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 correcte d PCB data. Below is Scott Brown’s response concerning the roof data reporting.

Don, The footnote on table 1-2 states that the lb/h r results are based on the total flow rate per meth od 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 revi sed 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 repor t. 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 an d 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 correcte d versions in the docket as opposed to the originals with addi tional documents to show corrections. Also, I agree with your approach of addressing all the issues before r esubmitting the report. However, it would be good t o know the answers to my questions when you get the inform ation. That is, please inform me of the lab’s respo nse when you get it – as opposed to waiting until the r evised report is completed.

I actually have a follow up comment/question to my email from yesterday. Based on a quick review of th e secondary potline PCB emissions (presented in Table 2-4 of the final report), it appears that those em issions (in units of lb/hr) are based on the downcomer flow rat e (as opposed to the roof vent flow rate). For exam ple, when I attempted to reproduce the Mono PCB emission s 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 Tab le 2-4 of the Final Report. However, the lb/hr emis sion rate
for Mono PCB does match if I use the downcomer flow rate instead of the roof vent flow rate. This coul d be a source of confusion during the public comment perio d. You may want to either modify the table in the r eport to clarify that the lb/hr values are based on the d owncomer flow rates, or modify the emissions values to represent emissions based on roof vent flow rates.

Also, as mentioned in my previous email, the report ed PCB emissions values appear to be overestimated by a factor of 1,000 as a result of the lab reporting th eir results in units of picograms (pg) but those re sults being changed to units of nanograms (ng) in the spreadshe ets 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 l ab data on page G-149 of the report). This would ce rtainly 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