Attachment A

February 28 , 201 3

ncasi Page 1



### Comparison of Contaminant Concentrations in

Cross Tie

- Derived Fuel w ith 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 non

hazardous 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 contami nant 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 “whe n 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 situati ons 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 eac h 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 ma ximums 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 NC ASI Technical Bulletin No. 906 (2005), and recent

CDF fuel sampling data extracted from EPA’s Boiler MACT Database . The latter correspond ed to five

facilities

– ALIPPrattville

, ALIPRiverdale

, AREvergreenPackaging

, LABoiseNewsprintDeRidder , and

NDADMNorthe rnSun , 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 f uels

. 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 contaminant s are group ed as three types of trace metal

HAPs ( volatile, semi

- vola tile 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 traditio nal fuels used for comparison.Attachment A

February 28 , 201 3

ncasi Page 2 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 o f 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.Attachment A

February 28 , 201 3

ncasi Page 3 Table 1. Trace Metals and Major Elements in Va rious Cross Tie

- Derived Fuel s

Units,

dry basis MAER 1 NCASI TB 906 a Boiler MACT Fuel Analysis Data b

n 2 mean min max n 3 n 2 mean min max

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 1.03 3.16

Beryllium (Be) ppm <0.5 4 25 0.12 0.06 0.30

Cadmium (Cd) ppm <0.5 1 0.10 4 25 0.26 0.23 0.30

Chromium (Cr) ppm <2.5 8 0.67 0.23 1.44 4 25 9.68 3.97 15.28

Cobalt (Co) ppm <2.5

Lead (Pb) ppm <10.0 1 8.00 4 22 7.55 4.09 9.58

Manganese (Mn) ppm 63 4 25 135 104 185

Mercury (Hg) ppm 0.02 1 <0.25 5 25 0.04 0.02 0.05

Nickel (Ni) ppm <5 1 <5.0 4 35 13.78 3.73 38.24

Selenium (Se) ppm <5 4 25 0.57 0.14 1.00

Major Elements

Chlorine (Cl) ppm 400 5 225 39 345 5 35 81 22 161

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

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

2 to 10

a From Table A2 of NCASI Technical Bulletin No. 906

– Sources included the following:

1. Emissions Database Test Report E710, "Compliance Stack Emissions Report/1996 f or the Waste Wood

- Fired Boiler", by AirRECON, March 10, 1997

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 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 the

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 French Island Plant in La

Crosse, Wisconsin", by Interpoll L aboratories, Inc., November 5, 1997

5. "Wood Products in the Waste Stream

-- Characterization and Combustion Emissions", by Atkins, Richard S. and Donovan, Christine T. as

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

b EPA’s Boiler MACT Database

- F uel Sampling Data for Rail Road Ties at 5 Facilities

– ALIPPrattville ; ALIPRiverdale ; AREvergreenPackaging ;

LABoiseNewsprintDeRidder ; NDADMNorthernSunAttachment A

February 28 , 201 3

ncasi Page 4

Table 2. VOCs, SVOCs, P AHs 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) HAP s

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 separated out here consistent with EPA’s approachAttachment A

February 28 , 201 3

ncasi Page 5 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 0.3 8

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 s am

ples 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) ;