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Submitted By:

M.A. Energy Resources, LLC 

9225 Indian Creek Parkway 

Suite 670 

Overland Park, KS 66210

Submitted To:

Lisa Jackson

Administrator

U.S. Environmental Protection Agency

Mail Code 1101A

Ariel Rios Building

1200 Pennsylvania Avenue, NW

Washington, DC 20460

Prepared By:

SUBMITTED: FEBRUARY 2013

2393 Kimberton Road 

PO Box 299 

Kimberton, PA 19442-0299 
TABLE OF CONTENTS 

Section Name ......................................................................................................... Page Number 

ii 

1. INTRODUCTION.............................................................................................................. 1-1

1.1 DOCUMENT PURPOSE .............................................................................................. 1-1

1.2 NHSM RULE OVERVIEW.......................................................................................... 1-2

1.3 DOCUMENT ORGANIZATION ................................................................................. 1-3

2. NHSM CDF PETITION NON-WASTE DETERMINATION ...................................... 2-1

2.1 PETITIONER'S NAME AND ADDRESS [40 CFR §241.4(B)(1)(I)] ......................... 2-1

2.2 A STATEMENT OF THE PETITIONER'S INTEREST IN THE PROPOSED ACTION 

[40 CFR §241.4(B)(1)(II)] ...................................................................................................... 2-1

2.3 A DESCRIPTION OF THE PROPOSED ACTION, INCLUDING SUGGESTED 

REGULATORY LANGUAGE [40 CFR §241.4(B)(1)(III)] .................................................. 2-2

2.4 A STATEMENT OF THE NEED AND JUSTIFICATION FOR THE PROPOSED 

ACTION .................................................................................................................................. 2-2

2.4.1 The Combustion of CDF has a Significant Beneficial Environmental Impact ...... 2-2

2.4.2 CDF Meets the Legitimacy Criteria Specified by 40 CFR §241.3(d) ................... 2-3

3. SPECIAL CONSIDERATIONS ....................................................................................... 3-1

4. SUMMARY AND CONCLUSION .................................................................................. 4-1
LIST OF APPENDICES 

Appendix Name 

iii 

Appendix A – Constituent/Contaminant Comparison Tables

Appendix B – Constituent/Contaminant Raw Testing Results
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

1-1

1. INTRODUCTION 

The Identification of Non-Hazardous Secondary Materials that are Solid Wastes When Used as 

Fuels or Ingredients in Combustion Units Rule, the so-called Non-Hazardous Secondary 

Materials Rule (NHSM Rule), is codified at 40 CFR Part 241. The rule establishes the process 

or procedures by which non-hazardous secondary materials (NHSMs) are or are not considered 

to be solid wastes when burned in combustion units. The NHSM Rule has far reaching 

regulatory impacts for those facilities that wish to utilize NHSMs as alternative fuels. 

1.1 DOCUMENT PURPOSE 

This document is a rulemaking petition the purpose of which is to demonstrate that Crosstie 

Derived Fuel (CDF) is a non-waste fuel in accordance with the provisions of 40 CFR 

241.4(b)(2), and to hereby request that U.S. EPA issue a categorical determination specifically 

identifying CDF as a non-waste, exempt, NHSM fuel under 40 CFR §241.4(a). CDF is not 

currently considered to be a traditional fuel and is not currently considered to be a non-waste fuel 

under the NHSM Rule. However, M.A. Energy Resources, LLC (MAER), an alternative fuels 

company that specializes in managing the logistics associated with the collection, handling, 

processing, and distribution of specification CDF, is committed to the process of establishing 

CDF as a legitimate non-waste alternative fuel. MAER strongly believes that CDF is indeed a 

non-waste fuel and that U.S. EPA should issue a categorical determination that CDF is a nonwaste fuel in accordance with the provisions of 40 CFR §241.4(b)(2), and specifically list CDF 

as a non-waste NHSM fuel under 40 CFR §241.4(a). MAER is submitting this document in 

addition to and consistent with similar submissions made previously by the following 

stakeholders and members of the regulated community: 

 American Forest & Paper Association 

(AF&PA) 

 Creosote Council (CC) 

 Treated Wood Council (TWC)  Association of America Railroads 

(AAR) 

 American Wood Council (AWC) 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

1-2

This document has been developed in accordance with the provisions of 40 CFR §241.4(b) and 

requests a specific categorical NHSM non-waste determination for CDF. 

1.2 NHSM RULE OVERVIEW 

An NHSM considered to be a non-waste material can be burned as an alternative fuel or an 

ingredient in a combustion unit regulated by either of the following CAA Section 112 rules (or 

other applicable MACT standard): 

 40 CFR Part 63, Subpart DDDDD – National Emission Standards for Hazardous Air 

Pollutants for Industrial, Commercial, and Institutional Boilers and Process Heaters [i.e., 

the Major Source Boiler Maximum Achievable Control Technology (MACT) Standard]. 

 40 CFR Part 63, Subpart JJJJJJ – National Emission Standards for Hazardous Air 

Pollutants for Industrial, Commercial, and Institutional Boilers Area Sources [i.e., the 

Area Source Boiler Maximum Achievable Control Technology (MACT) Standard]. 

Conversely, a NHSM considered to be a solid waste material cannot be burned as an alternative 

fuel or used as an ingredient in a combustion unit regulated by either the Major or Area Source 

Boiler MACT rules and must instead be burned in a combustion unit regulated by either of the 

following CAA Section 129 rules: 

 40 CFR Part 60, Subpart CCCC – Standards of Performance for Commercial and 

Industrial Solid Waste Incineration Units for Which Construction is Commenced After 

November 30, 1999 or for Which Modification or Reconstruction is Commenced on or 

After June 1, 2001 

 40 CFR Part 60, Subpart DDDD – Emissions Guidelines and Compliance Times for 

Commercial and Industrial Solid Waste Incineration Units that Commenced Construction 

on or Before November 30, 1999. 

Without a NHSM non-waste determination, a combustion unit that burns a NHSM fuel will be 

labeled an incinerator. Given the choice of being permitted as an incinerator or a boiler, the 

overwhelming majority of facilities will choose to stop utilizing alternative fuels that are 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

1-3

considered to be solid-wastes and comply with Boiler MACT. This would have an unintended 

negative environmental impact as generators of presumed “solid wastes” used as fuels would 

then potentially be forced to landfill materials that are currently beneficially used as alternative 

fuels, and could also potentially increase emissions of regulated pollutant emissions from such 

facilities as they return to the use of fossil fuels. 

On February 7, 2013, the United States Environmental Protection Agency (U.S. EPA) 

promulgated final revisions to the NHSM Rule. U.S. EPA’s promulgation of the final NHSM 

Rule revisions represents the culmination of a long dialogue with stakeholders from a variety of 

industry sectors stemming back to January 2, 2009 and the original issuance of the Advanced 

Notice of Proposed Rulemaking (ANPRM). Since the ANPRM, the NHSM Rule has undergone 

significant scrutiny and garnered considerable comments at each step of the regulatory process, 

including comments from combustors that utilize Crosstie Derived Fuel (CDF) as an alternative 

fuel to offset all or a portion of the fossil fuels used in their combustion units. 

CDF is a non-hazardous alternative biomass fuel derived from railroad crossties that have been 

removed from service and processed by reclamation companies such as MAER. Approximately 

17 million crossties are removed from service each year. This volume of material is roughly 

equivalent to an area the size of a football field with crossties piled seventy (70) stories tall. 

CDF crossties are overwhelmingly comprised of North American hardwoods that have been 

treated with creosote. As a function of its high energy content, CDF is beneficially used for heat 

and energy recovery in many combustion units across a variety of industry sectors as a nonhazardous, biomass derived, alternative to fossil fuel. 

1.3 DOCUMENT ORGANIZATION 

 SECTION 1 – INTRODUCTION: Provides a brief overview of the NHSM Rule 

background and impacts on the regulated community, and states the document’s overall 

purpose. 

 SECTION 2 – NHSM CDF PETITION NON-WASTE DETERMINATION:

Provides the components of a rulemaking petition specified by 40 CFR §241.4(b)(1) and 

requests a categorical determination that CDF is a non-waste fuel in accordance with the 

provisions of 40 CFR §241.4(b)(2).
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

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 SECTION 3 – SPECIAL CONSIDERATIONS: Provides additional information as 

requested to U.S. EPA responses to comments including the December 20, 2013 final 

rule. 

 SECTION 4 – CONCLUSION: Provides a concluding summary of the information 

included in the document. 

 APPENDIX A – CONSTITUENT/CONTAMINANT COMPARISON TABLES.

 APPENDIX B – CONSTITUENT/CONTAMINANT RAW TESTING RESULTS.
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-1

2. NHSM CDF PETITION NON-WASTE DETERMINATION 

As stated above, the NHSM Rule is codified at 40 CFR Part 241 and identifies the requirements 

and procedures for the identification of non wastes used as fuels or ingredients in combustion 

units. In accordance with 40 CFR §241.4(b), “Any person may submit a rulemaking petition to 

the Administrator to identify additional non-hazardous secondary materials to be listed in 

paragraph 40 CFR §241.4(a).” 40 CFR §241.4(a) includes a list of NHSMs that EPA has 

determined are not solid wastes when used as a fuel in a combustion unit. The required 

components of the NHSM CDF Petition for a Non-waste Determination are detailed in 40 CFR 

§241.4(b)(1)(i) through (iv) and are discussed in more detail below. 

2.1 PETITIONER'S NAME AND ADDRESS [40 CFR §241.4(B)(1)(I)] 

Petitioners Name:

M.A. Energy Resources, LLC 

Petitioners Address:

9225 Indian Creek Parkway 

Suite 670 

Overland Park, KS 66210 

2.2 A STATEMENT OF THE PETITIONER'S INTEREST IN THE PROPOSED 

ACTION [40 CFR §241.4(B)(1)(II)] 

As stated above, MAER is an alternative fuels company that specializes in managing the 

logistics associated with the collection, handling, processing, and distribution of specification 

CDF. MAER operates as an intermediary between the railroad industry and the end-use 

combustors that utilize CDF as a non-hazardous, biomass derived, alternative to fossil fuel. 

MAER receives railroad creosote crossties from the railroads or the companies contracted by the 

railroads to remove crossties. MAER proceeds to process the crossties into specification CDF 

depending on the particular needs of the end-use combustor. MAER’s primary business is the 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-2

collection, processing, and sale of specification CDF to their diverse client base of end-use 

combustors. 

2.3 A DESCRIPTION OF THE PROPOSED ACTION, INCLUDING SUGGESTED 

REGULATORY LANGUAGE [40 CFR §241.4(B)(1)(III)] 

MAER proposes that U.S. EPA provide a determination that CDF is not a solid-waste and 

instead is a legitimate alternative fuel. MAER further proposes that U.S. EPA include CDF 

categorically as “crossties that have been treated with creosote” in the list of NHSMs that are not 

solid-wastes when used as fuels codified at 40 CFR §241.4(a). MAER has provided proposed 

language to be included in 40 CFR §241.4(a) below: 

40 CFR §241.4(a)(5) – Crossties that have been treated with creosote. 

2.4 A STATEMENT OF THE NEED AND JUSTIFICATION FOR THE PROPOSED 

ACTION 

As stated above, MAER is submitting this document in conjunction and collaboration with 

stakeholders and members of the regulated community both “up-stream” and “down-stream” 

from MAER’s position in the CDF reclamation-to-fuel process. MAER and the other 

stakeholders potentially affected by the outcome of this NHSM CDF Petition for Non-waste 

Determination strongly believe that the reclaimed crossties that comprise CDF are not solidwastes for the following reasons: 

 The use of CDF as a non-hazardous, biomass derived, alternative to fossil fuel has a 

significant beneficial environmental impact. 

 CDF meets the legitimacy criteria specified by 40 CFR §241.3(d). 

2.4.1 The Combustion of CDF has a Significant Beneficial Environmental Impact 

The current combustion of CDF as a non-hazardous alternative biomass fuel has a significant 

beneficial environmental impact. A determination that CDF is not a solid-waste and is instead a 

legitimate alternative fuel, coupled with the categorical inclusion of CDF in the list of NHSMs 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-3

that are not solid-wastes when used as fuels codified at 40 CFR §241.4(a), would keep a 

significant volume of crossties from being unnecessarily land-filled. 

Keeping crossties from being land-filled has a secondary affect on limiting greenhouse gas 

(GHG) emissions as well. The utilization of CDF by end-use combustors can displace the use of 

fossil fuels that emit GHG. The GHG limiting effect of combusting CDF is magnified when one 

considers that alternative fuels derived from biomass such as wood are included within the 

carbon cycle while traditional fossil fuels are not. Should CDF’s status as a non-waste continue 

to be undefined and its use as an alternative fuel cease, the thermal equivalent of the CDF that is 

currently utilized by end-use combustors will need to be offset by a non-waste fuel considered 

legitimate by U.S. EPA or more likely a fossil fuel. Offsetting the use of CDF with a legitimate 

non-waste fuel or a fossil fuel could potentially carry a significant GHG penalty. This GHG 

penalty will again be magnified as the CDF that has been unnecessarily land-filled begins to 

undergo anaerobic decomposition, generating emissions of methane (CH4), a GHG that is 21 

times more potent than carbon dioxide (CO2). 

2.4.2 CDF Meets the Legitimacy Criteria Specified by 40 CFR §241.3(d) 

Pursuant to 40 CFR §241.3(b)(4), non-hazardous secondary materials, including fuels, are not 

solid wastes when combusted as long as the following criteria are met: 

 The fuel is not discarded or is produced from the processing of a discarded NHSM [40 

CFR §241.3(b)(4)]. 

 The fuel meets the legitimacy criteria specified in 40 CFR §241.3(d)(1). 

o The fuel is managed as a valuable commodity [40 CFR §241.3(d)(1)(i)]. 

o The fuel has a meaningful heating value and is used as a fuel in a combustion unit 

that recovers energy [40 CFR §241.3(d)(1)(ii)]. 

o The fuel contains contaminants at levels comparable in concentration to or lower 

than those in traditional fuel(s) which the combustion unit is designed to burn [40 

CFR §241.3(d)(1)(iii)]. 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-4

2.4.2.1 The Fuel is Not Discarded or is Produced from the Processing of a 

Discarded NHSM [40 CFR §241.3(b)(4)] 

MAER understands that a petition to categorically list an NHSM as a legitimate fuel must 

include a demonstration or justification that the material either is not discarded, or if it is 

discarded, then the material has been sufficiently processed. MAER asserts that the vast 

majority of crossties used as CDF by end-use combustors are not discarded as they are instead 

obtained via contractual arrangements. MAER also asserts that those crossties that could be 

considered discarded are sufficiently processed into specification CDF prior to utilization by 

end-use combustors. 

According to the Association of American Railroads, approximately 17 million crossties are 

removed from railways each year. Railroads contract with a crosstie reclamation company to 

remove and reclaim the crossties. Such contracts actually transfer ownership of the reclaimed 

crossties to the removal/reclamation company for the time that the ties are in their possession. 

As such, the reclaimed crossties, while not in the control of the original generator (i.e., the 

railroads), are not discarded in the typical common use of the term discarded. They are instead 

transferred to the removal/reclamation company who sorts the ties according to their condition 

for different end uses. Removed and reclaimed crossties may be temporarily stored in the 

railroad right-of-way or at another location by the crosstie reclamation companies. However, 

regardless of the length of time the crossties are stored, the crossties are not discarded in 

accordance with the common use definition of discarded in that they are not abandoned or no 

longer considered to be useful. The crossties are simply stored until such a time as their value as 

an alternative fuel (i.e., for use as an alternative fuel or other end-use purposes such as 

landscaping) can be realized. MAER understands that even long term storage does not diminish 

the value of the CDF crossties as an alternative fuel. One third of the reclaimed crossties are 

used for landscaping. The majority of the other two thirds of the reclaimed crossties are used by 

end-use combustors for energy recovery. 

Not all CDF originates from crossties removed from service in the same year. Some CDF is 

processed from crossties that were removed from service in prior years and stored by the 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-5

railroads or removal/reclamation companies until their value as a landscaping element or 

alternative fuel could be realized. These crossties are not discarded. There is no record of such 

crossties being abandoned. Waiting until the value of the material can be realized is relevant to a 

determination whether the length of time in storage is reasonable. 76 Fed. Reg. 15456, 15520 

(Mar. 21, 2011) (reasonable time frame for storage is flexible enough to allow accumulation of 

materials to be cost-effective). 

However, even if EPA believed that crossties removed from service in prior years have not been 

stored for a reasonable period of time, MAER maintains that all crossties are sufficiently 

processed prior to utilization by the end-use combustors. Certain removal and reclamation 

companies sell the crossties to companies like MAER who process the crossties, reclaimed by 

the removal companies or otherwise originating from stored crossties, using a combination of the 

following, as appropriate: 

 Removal of metal (i.e., spikes, nails, plates, etc.) via magnetic removal. Note that 

depending on the configuration of a facility’s processing equipment, magnetic removal 

could be applied more than once. 

 Grinding or shredding of the crossties to specified size depending on the particular needs 

of the end-use combustors. Note that depending on the configuration of a facility’s 

processing equipment, the grinding stage of the crosstie processing may occur via 

primary and secondary grinding phases or a single grinding phase. 

 Additional screening of the ground or shredded crosstie material to specified size 

depending on the particular needs of the end-use combustors. Note that depending on the 

configuration of a facility’s processing equipment, screening may occur concurrently 

with grinding or as a subsequent stage of the crosstie processing. 

 Applying a surfactant to minimize dust during transfer and handling of the material. 

The end result of such processing is a specification CDF that has been sufficiently processed to 

improve combustion of the material, remove contaminants, and meet the particular needs of the 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-6

end-use combustor. The specification CDF is then sold directly to the end-use combustor for 

energy recovery. 

In conclusion, crossties that have been removed by companies contracted directly to the railroads 

have not been discarded. In addition, all crossties in the CDF population whether stored prior to 

processing are processed sufficiently to meet the definition of processing codified at 40 CFR 

§241.2. 

2.4.2.2 The Fuel is Managed as a Valuable Commodity [40 CFR §241.3(d)(1)(i)] 

Several companies in the United States, including MAER, exist using a business model that 

revolves entirely around the value created by the removal, reclamation, processing, and sale of 

creosote-treated railroad crossties as CDF. Such companies generate annual industry-wide 

revenue of $65-$75 million. The removed/reclaimed crossties are the valuable commodity that 

creates this industry and the associated revenue. Note that the CDF industry is a thriving 

marketplace where removal/reclamation companies compete both for railroad contracts and the 

end-use combustor customer base who buys the CDF. 

In demonstrating that an NHSM is managed as a valuable commodity U.S. EPA stipulates 

pursuant to 40 CFR §241.3(d)(1)(i)(A) and (B) that storage of the NHSM prior to use as a fuel 

must not exceed reasonable timeframes, and that the NHSM must be managed and contained in a 

manner consistent with an analogous fuel to prevent releases to the environment. Processed 

CDF is delivered to end-use combustors via railcar and/or truck similar to how other biomass 

fuels would be delivered. End-use combustors may also employ additional magnetic removal of 

metal. After receipt, the CDF is stock-piled prior to combustion in a similar manner to other 

analogous fuels like bark fuel, hog fuel, or biomass (i.e., in fuel piles or silos). Prior to 

combustion, which usually takes place within a timeframe from a day to a week of arrival, the 

CDF is transferred and/or handled from temporary storage in a manner consistent with the 

transfer and handling of other biomass fuels; procedures that typically include screening again by 

the end-use combustor, combining with other biomass fuels, and transferring to the combustor 

via conveyor belt or front-end loader. CDF is managed as a valuable commodity since a 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-7

competitive marketplace exists for the removal, reclamation, and sale of CDF crossties, and since 

such crossties are not stored for unreasonable lengths and are handled and treated similar to other 

analogous biomass fuels by end-use combustors. 

2.4.2.3 The Fuel Must Have a Meaningful Heating Value [40 CFR §241.3(d)(1)(ii)] 

In an effort to compare the constituents/contaminants of CDF to traditional fuels (i.e., coal, 

biomass, fuel oil, and coal tar oil), MAER has had qualitative laboratory testing performed on a 

sample of the specification CDF that they process and sell. In so doing, a heating value of 6,595 

Btu/lb as fired was determined for the sample tested. U.S. EPA has previously reported that 

creosoted-treated wood has a heating value of 6,000 Btu/lb. Other stakeholders and affected 

industry members like the Treated Wood Council (TWC) have previously reported a heating 

value for creosote-treated wood of upwards of 8,000 Btu/lb. As a result, a heating value range of 

6,000-8,000 Btu/lb as fired is reasonable for specification CDF. U.S. EPA has consistently 

referenced 5,000 Btu/lb as threshold for presuming that an NHSM has a meaningful heating 

value. Based on the qualitative laboratory testing that MAER has had performed, CDF has a 

meaningful heating value pursuant to 40 CFR §241.3(d)(1)(ii). 

2.4.2.4 The Fuel Must Contain Contaminants at Levels Comparable to Traditional 

Fuel(s) [40 CFR §241.3(d)(1)(iii)] 

As stated above, in an effort to make a comparison of the constituents/contaminants present in 

CDF to those found in traditional fuels (including coal, biomass, fuel oil, and coal tar oil), 

MAER has had qualitative laboratory testing performed on a sample of the specification CDF 

that they process and sell. MAER contracted Columbia Analytical Services to perform the 

qualitative testing of CDF. 

The CDF sample was obtained from a CDF fuel pile located at the facility of an end-use 

combustor. The operation of the CDF fuel pile, including any associated processing and 

handling is performed by MAER. Note that the tested CDF sample was obtained in accordance 

with the sampling provisions of 40 CFR §63.7521(c)(2) and composited by the analyzing 

laboratory in accordance with the compositing provisions of 40 CFR §63.7521(c)(2) and (d)(1) 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-8

through (7). In obtaining the composite CDF sample in accordance with the provisions 

referenced above, MAER understands that the CDF sampling has been conducted in a method 

that is compliant with the applicable 40 CFR Part 63, Subpart DDDDD fuel sampling 

requirements. In so doing, MAER believes that the tested CDF sample has been obtained in a 

manner consistent with regulated procedures and is therefore, suitable for inclusion in the NHSM 

CDF Petition for Non-waste Determination. 

In performing the comparison of the constituents/contaminants present in CDF to those found in 

traditional fuels, MAER reviewed a list of constituents/contaminants using the CAA Section 112 

and 129 regulated pollutants and using engineering judgment and other internal resources 

determined which constituents/contaminants could be reasonably expected to be present in the 

crossties comprising CDF. Specifically, MAER reviewed Material Safety Data Sheet (MSDS) 

data and/or industry generated data (i.e., publicly available databases and/or technical 

documents) to prepare a list of constituents that could reasonably be expected to be present in the 

creosote material used to preserve wooden crossties. 

Similarly, using available technical databases and other publically available technical documents 

[largely obtained from the National Counsel for Air and Stream Improvement, Inc. (NCASI) 

technical documents], a list of constituents that could reasonably be expected to be present in 

northern and southern North American hardwoods was compiled. This list of “expected” 

constituents/contaminants was then compared to the list constituents/contaminants known to 

exist in coal, wood biomass, and fuel oil based on publically available databases and documents 

from U.S. EPA’s NHSM website. This list was also compared to a list of 

constituents/contaminants obtained from a representative coal tar oil MSDS. Based on U.S. 

EPA’s response to comments pertaining to contaminant comparisons all constituent/contaminant 

comparisons were made on a pre-combustion basis (i.e., % weight, ppm, μg or mg/kg, etc. as 

appropriate). 

The qualitative laboratory test data performed on the CDF sample represents one (1) 

constituent/contaminant data point. However, MAER believes that one (1) data point is 

sufficient to perform a meaningful constituent/contaminant comparison because the components 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-9

of CDF, wood and creosote, are homogeneous. The wood component of CDF is homogeneous 

because the source is North American hardwoods. The creosote component of CDF is 

homogeneous because the production of creosote is governed by standards established by the 

American Wood Protection Association (AWPA). AWPA has established two blends of 

creosote, P1/P13 or P2. These standards identify the source material for creosote as well as the 

physical-chemical characteristics of the pesticide product. Railroad ties are typically 

manufactured using the P2 blend. Given the homogeneity of the components of CDF, the 

qualitative laboratory test data submitted with this petition is sufficient to provide a meaningful 

constituent/contaminant comparison. Further, the processing of CDF adds further homogeneity 

to the product, by removing contaminants and sizing the material to give it homogeneous fuel 

characteristics. 

Table A-1 of Appendix A presents the compiled list of constituents/contaminants that could 

reasonably be expected to be present in CDF and presents the results of the qualitative testing. 

Table A-2 of Appendix A compares the results of the qualitative testing to the 

constituents/contaminants of the solid fuels coal and biomass and the liquid fuels fuel oil and 

coal tar oil on a concentration basis. Contaminant levels for coal and biomass were chosen for 

comparison since a combustion unit currently utilizing CDF could reasonably be expected to be 

capable of combusting coal and/or other biomass fuels as an innate feature of its original design 

characteristics and no separate delivery system is needed to switch from one solid fuel to 

another. Fuel oil and coal tar oil were chosen for comparison since a combustion unit currently 

utilizing CDF also could reasonably be expected to be capable of combusting either fuel oil or 

coal tar oil as an innate feature of its original design characteristics. 

With respect to liquid fuels, we recognize that EPA interprets the phrase “designed to burn” to 

mean that a combustor that makes a self-determination that its CDF is a processed fuel product 

may have to meet the contaminant legitimacy criterion by installing a nozzle for the delivery of 

liquid fuel into the boiler. According to EPA, this condition is to avoid the possibility that 

discard could be occurring in some situations. However, in the context of a specific non-waste 

determination under section 241.4, EPA has the opportunity to evaluate all the factors relating to 

the use of CDF as a fuel, including the fact that CDF is a commodity that is purchased by the 
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40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-10

combustor. EPA, in granting a petition for a non-waste determination, has the discretion to 

recognize that when a combustor purchases CDF and then burns it in a boiler, that combustion is 

not for the purpose of discarding the CDF. Rather, the combustion is for the legitimate purpose 

of generating energy. 

In comparing the constituents/contaminants that could reasonably be expected to be present in 

CDF to the contaminants in coal, biomass, fuel oil, and coal tar oil, MAER is providing a 

meaningful comparison of CDF contaminants to a collective end-use combustor fuel 

contaminant profile. Such a collective fuel contaminant profile provides a genuine comparison 

of the contaminants potentially present in CDF to the contaminants present in the traditional 

fuels that an end-use combustor capable of burning CDF actually burn. 

MAER combined the individual contaminants into specific groups based on similar physical and 

chemical properties. Specifically, MAER established a Volatile Organic Compounds (VOC) 

hydrocarbon group, a group comprising the common 16 Polycyclic Aromatic Hydrocarbons 

(PAHs), and a semi-VOC hydrocarbon group, which included the 16 PAH group and other semiVOCs. MAER did not choose to combine any metal contaminants. The individual contaminants 

have been combined into their respective groupings as presented on Table A-1. 

As presented in Tables A-1 and A-2, the levels of the constituents/contaminants expected to be 

present in CDF are comparable to the levels known to exist in coal, biomass, fuel oil, and/or coal 

tar oil. All relevant groups of CDF constituents/contaminants tested were either non-detect or 

lower than the comparable levels of groups of contaminants present in one or more of the 

traditional fuels. For contaminants that are VOCs, the analytical data indicate that the sum of all 

CDF VOC contaminants are approximately 0.89 part per million (ppm) by weight which is much 

less than the individual contaminant level listed for n-hexane in fuel oil (10,000 ppm). The CDF 

semi-VOC contaminants are present at approximately 978 ppm which is considerable less than 

the individual contaminant level of phenol that is reported for fuel oil (7,700 ppm). The common 

16 PAH plus two (2) additional PAHs (1-methylnapthalene and 2-methylnaphthalene) detected 

in CDF summed to 7,036 ppm while the contaminant level of naphthalene (just one of the 16 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

2-11

PAHs) is 7,330 ppm from fuel oil. Only two (2) metals were present in CDF at detectable levels 

(manganese and mercury) and both of these contaminants are present at levels less than either 

coal or biomass. Finally the concentration levels for the “precursor contaminants” (chlorine, 

fluorine, nitrogen, and sulfur) detected in CDF are less than the corresponding levels measured in 

coal, biomass, and fuel oil. Overall the groups of contaminants detected in CDF are lower than 

the levels of individual, representative contaminants present in traditional fuels such as coal, 

biomass, and fuel oil. 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

3-1

3. SPECIAL CONSIDERATIONS 

In the final revision to the NHSM, U.S. EPA provided responses to a Petition for Non-Waste 

Determination under 40 CFR §241.4 and Request for Comfort Letter submitted by the AF&PA 

on December 6, 2012. In their response, U.S. EPA requested that the AF&PA provide additional 

information as follows: 

1. A list of industry sectors, in addition to forest product mills, that burn railroad ties for 

energy recovery. 

2. The types of boilers (e.g., kilns, stoker boilers, circulating fluidized bed, etc.) that burn 

railroad ties for energy recovery. 

3. The traditional fuels and relative amounts of these traditional fuels that could otherwise 

generally be burned in these types of boilers. 

4. The extent to which non-industrial boilers (e.g., commercial or residential boilers) burn 

railroad ties for energy recovery. 

5. Laboratory analyses for contaminants known to be present in creosote-treated railroad 

ties or known to be significant components of creosote, specifically Polycyclic Aromatic 

Hydrocarbons (i.e., PAH-16), dioxins, dibenzofurans, hexachlorobenzene, biphenyl, 

quinoline, cresols, and 2,4-dinitrotoluene. 

MAER has provided additional information in response to U.S. EPA’s request below: 

1. MAER knows of 10-16 end-use combustors that utilize CDF as an alternative fuel to 

offset fossil fuel use at all times that their combustion units are operating. CDF usage 

from such end-use combustors can be as much as 100-500 tons daily. MAER knows of 

10-16 additional end-use combustors that utilize CDF occasionally based on availability 

and cost drivers. MAER also knows well over 100 more end-use combustors that are 

operationally able to utilize CDF as an alternative fuel to offset fossil fuel that choose not 

to use CDF as a result of the current solid-waste implications associated with CDF. The 

20-32 end-use combustors that utilize CDF, both full-time and part-time, represent a 

variety of industries including pulp and paper manufacturing, cogeneration, utilities, and 

chemical manufacturing facilities. 

2. The types of boilers operated by those end-use combustors that currently utilize CDF as 

an alternative fuel to offset fossil fuel include fluidized bed, traveling grate, and spreader 

stoker. 

3. Boilers operated by end-use combustors that utilize CDF as an alternative fuel to offset 

fossil fuel also burn a variety of “traditional fuels” including: coal, biomass (i.e., hog 

fuel, bark fuel, and other biomass fuel materials), fuel oil, Tired Derived Fuel (TDF), 

Waste Derived Liquid Fuel (WDLF), and Waste Derived Solid Fuel (WDSF). 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

3-2

4. MAER understands that the residential use of CDF for purposes of energy recovery is 

unlikely. However, MAER does know of several local utilities in the northern Midwest 

that utilize CDF for purposes of power generation. 

5. MAER understands that Tables A-1 and A-2 of Attachment A, and the raw qualitative 

laboratory test data provided in Attachment B, fulfill U.S. EPA’s fifth request as 

appropriate. However, note that since MAER developed the list of 

constituents/contaminants beginning with what constituents/contaminants could be 

expected to be present in CDF not all of the specific constituents/contaminants referenced 

by U.S. EPA were tested as they do not represent constituents/contaminants that would 

be expected to be present in CDF (i.e., dioxins). 

Also, in the final revisions to the NHSM, U.S. EPA provided added four (4) elements to the 

definition of contaminants as precursor “contaminants” including chlorine (Cl), fluorine (F), 

nitrogen (N), and sulfur (S). As a result, MAER has provided data pertaining to the presence of 

Cl, F, N, and S in the qualitative laboratory test data provided as Attachments A and B. 
 M.A. Energy Resources, LLC 

40 CFR Part 241, Subpart B – Crosstie Derived Fuel 

(CDF) Petition for Non-waste Determination 

4-1

4. SUMMARY AND CONCLUSION 

CDF is a non-hazardous alternative biomass fuel derived from railroad crossties that have been 

reclaimed as part of normal railroad maintenance activities. As a function of its high energy 

content, CDF is currently beneficially used for heat and energy recovery in many combustion 

units across a variety of industry sectors as a non-hazardous, biomass derived, alternative to 

fossil fuel. 

Based on the information contained herein, crossties that comprise CDF are not solid-wastes. 

The use of CDF as a non-hazardous, biomass derived, alternative to fossil fuel has a significant 

beneficial environmental impact by reducing emissions of GHG and decreasing the unnecessary 

land-filling of this valuable fuel resource. The CDF meets the legitimacy criteria specified by 40 

CFR §241.3(d) in that the crossties that comprise CDF are (1) either not discarded or are 

sufficiently processed; (2) are managed as a valuable commodity; (3) have a meaningful heating 

value; and (4) have levels of constituents/contaminants comparable to the levels known to exist 

in coal, biomass, fuel oil, and/or coal tar oil. 

For these reasons, the information presented herein, and the overabundance of previously 

submitted similar information, CDF is indeed a non-waste fuel and that U.S. EPA should issue a 

categorical determination that CDF is a non-waste fuel in accordance with the provisions of 40 

CFR §241.4(b)(2), and specifically list CDF as a non-waste NHSM fuel under 40 CFR 

§241.4(a). 
APPENDIX A –

CONSTITUENT/CONTAMINANT COMPARISON TABLES
Table A-1

M.A. Energy Resources, LLC

CDF Testing Qualitative Laboratory Results

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes CDF Test Results Unit Notes

Physical/Fuel Characteristics

1 Moisture 27.98 %wt -

0.58 %wt (as received)

0.81 %wt (moist. free)

6,595 Btu/lb (as received)

9,157 Btu/lb (moist. free)

Non-HAP/Non-Metal Elements

4 Hydrogen 5.79 % wt (Moist Free) -

5 Nitrogen 0.16 % wt (Moist Free) -

6 Sulfur 0.080 % wt (Moist Free) -

7 Fluorine 0.01 % wt (Moist Free) -

8 Chlorine 0.04 % wt (Moist Free) -

9 Oxygen (diff) 32.28 % wt (Moist Free) -

10 Carbon 52.72 % wt (Moist Free) -

Volatile Organic Compounds by GC/MS

11 Benzene 50 ug/Kg Non-Detect

12 Ethyl benzene 57.5 ug/Kg -

13 Styrene 50 ug/Kg Non-Detect

14 Toluene 50 ug/Kg Non-Detect

15 Xylenes 325 ug/Kg (Total)

16 Cumene 50 ug/Kg Non-Detect

17 Acrolein 1,000 ug/Kg Non-Detect

18 Bromomethane 50 ug/Kg Non-Detect

19 Carbon Tetrachloride 50 ug/Kg Non-Detect

20 Carbon-Disulfide 100 ug/Kg Non-Detect

21 Chlorobenzene 50 ug/Kg Non-Detect

22 Methyl Isobutyl Ketone 100 ug/Kg Non-Detect

23 Methylene Chloride 100 ug/Kg Non-Detect

24 m,p-xylene 178 ug/Kg -

25 o-xylene 148 ug/Kg -

26 Tetrachloroethylene 50 ug/Kg Non-Detect

27 Trichloroethylene 50 ug/Kg Non-Detect

28 Vinyl Chloride 50 ug/Kg Non-Detect

29 n-Hexane 50 ug/Kg Non-Detect

TCLP Volatile Organics by GC/MS

30 1,1-dichloroethylene 0.10 mg/L Non-Detect

31 1,2-dichloroethane 0.10 mg/L Non-Detect

32 1,4-dichlorobenzene 0.10 mg/L Non-Detect

33 Chloroform 0.10 mg/L Non-Detect

Selected HAPS in Condensates by GC/FID

34 Acetaldehyde 1.00 mg/Kg Non-Detect

35 Methanol 1.00 mg/Kg Non-Detect

36 Propionaldehyde 1.00 mg/Kg Non-Detect

Semivolatile Organic Compounds by GC/MS

37 2,4-dinitrophenol 57,400 ug/Kg Non-Detect

38 2,4-dinitrotoluene 14,600 ug/Kg Non-Detect

39 Acetophenone 29,100 ug/Kg Non-Detect

40 Aniline 14,600 ug/Kg Non-Detect

-

3 Heat Content

2 Ash 

-
Table A-1

M.A. Energy Resources, LLC

CDF Testing Qualitative Laboratory Results

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes CDF Test Results Unit Notes

41 Biphenyl 137,000 ug/Kg -

42 Dibenzofuran 798,000 ug/Kg -

43 Hexachlorobenzene 14,600 ug/Kg Non-Detect

44 Pentachlorophenol 57,400 ug/Kg Non-Detect

45 Phenol 14,600 ug/Kg Non-Detect

46 Quinoline 40,200 ug/Kg -

TCLP Semivolatile Organic Compounds by GC/MS

47 o-cresol 0.05 mg/L Non-Detect

48 m,p-cresol 1.5100 mg/kg -

49 Hexachlorobutadiene 0.05 mg/L Non-Detect

50 Hexachloroethane 0.05 mg/L Non-Detect

51 Nitrobenzene 0.05 mg/L Non-Detect

52 Pyridine 0.20 mg/L Non-Detect

53 2,4,5-trichlorophenol 0.05 mg/L Non-Detect

54 2,4,6-trichlorophenol 0.05 mg/L Non-Detect

Base Neutral Semivolatile Organic Compounds by GC/MS SIM

55 1-Methylnaphthalene 144,000 ug/Kg -

56 2-Methylnaphthalene 251,000 ug/Kg -

57 Acenaphthene 610,000 ug/Kg -

58 Acenaphthylene 58,600 ug/Kg Non-Detect

59 Anthracene 447,000 ug/Kg -

60 Benz(a)anthracene 201,000 ug/Kg -

61 Benzo(a)pyrene 81,900 ug/Kg -

62 Benzo(b)fluoranthene 128,000 ug/Kg -

63 Benzo(g,h,i)perylene 29,300 ug/Kg Non-Detect

64 Benzo(k)fluoranthene 57,900 ug/Kg -

65 Chrysene 182,000 ug/Kg -

66 Dibenz(a,h)anthracene 29,300 ug/Kg Non-Detect

67 Fluoranthene 1,100,000 ug/Kg -

68 Fluorene 529,000 ug/Kg -

69 Indeno(1,2,3-cd)pyrene 29,300 ug/Kg Non-Detect

70 Naphthalene 444,000 ug/Kg -

71 Phenanthrene 1,930,000 ug/Kg -

72 Pyrene 930,000 ug/Kg -

Organochlorine Pesticides by Gas Chromatography

73 Chlordane 708 ug/Kg Non-Detect

TCLP Organochlorine Pesticides by Gas Chromatography

74 Lindane 0.2380 mg/kg -

75 Heptachlor 0.0002 mg/L Non-Detect

76 Methoxychlor 0.0004 mg/L Non-Detect

77 Toxaphene 0.005 mg/L Non-Detect
Table A-1

M.A. Energy Resources, LLC

CDF Testing Qualitative Laboratory Results

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes CDF Test Results Unit Notes

Carbonyl Compounds by High Performance Liquid Chromatography (HPLC)

78 Formaldehyde 1,600 ug/Kg Non-Detect

Trace Metal HAP:

79 Antimony (Sb) <5 mg/kg (Moisture Free) Non-Detect

80 Arsenic (As) <10 mg/kg (Moisture Free) Non-Detect

81 Beryllium (Be) <0.5 mg/kg (Moisture Free) Non-Detect

82 Cadmium (Cd) <0.5 mg/kg (Moisture Free) Non-Detect

83 Chromium (Cr) <2.5 mg/kg (Moisture Free) Non-Detect

84 Cobalt (Co) <2.5 mg/kg (Moisture Free) Non-Detect

85 Lead (Pb) <10 mg/kg (Moisture Free) Non-Detect

86 Manganese (Mn) 63 mg/kg (Moisture Free) -

87 Mercury (Hg) 16.1 ppb (moisture free) -

88 Nickel (Ni) <5 mg/kg (Moisture Free) Non-Detect

89 Selenium (Se) <5 mg/kg (Moisture Free) Non-Detect

(a) Constituent/contaminant data obtained from Columbia Analytical Services, Inc., Qualitative Laboratory Test Report, 

Service Request No. T1201895.
Table A-2

CDF Testing Qualatative Laboratory Results Traditional Fuel Comparison (i.e., Coal, Biomass, Fuel Oil, and Coal Tar Oil) (Grou

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

Unit

Analytes Laboratory Result (ppm) Laboratory Comment US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) Literature

Sources (pp

Moisture 27.98 %wt -----

0.58 %wt (as received) -----0.81 %wt (moist. free) -----

6,595 Btu/lb (as received) -----9,157 Btu/lb (moist. free) -----

Non-HAP/ Non-Metal

Hydrogen 57,900 - - - -Nitrogen 1,600 - N/A 13,600 – 54,000 200 – 39,500 2,200 – 4,600 42 – 8,950 Sulfur 800 - N/A 740 – 61,300 Non-Detect – 8,700 Non-Detect – 6,100 N/A Fluorine 100 - N/A Non-Detect – 178 Non-Detect – 300 Non-Detect – 128 N/A Chlorine 400 - N/A Non-Detect – 9,080 Non-Detect – 2,600 Non-Detect – 5,400 N/A Oxygen (diff) 322,800 - -----Carbon 527,200 - -----

Volatile Organic Compounds 0.38 - 8.6 – 56 N/A 1.6 - 27 N/A 50 – 10,00Semi-Volatile Organic Compounds 977 - N/A N/A N/A N/A Non-Detect – 16-PAHs 7,036 - N/A N/A N/A N/A Non-Detect – Trace Metal Haps

Antimony (Sb) <5 Non-Detect 0.5 – 10 Non-Detect – 6.9 Non-Detect – 26 Non-Detect – 6.0 Non-Detect – 

Arsenic (As) <10 Non-Detect 0.5 – 80 Non-Detect – 174 Non-Detect – 6.8 Non-Detect – 298 N/A Beryllium (Be) <0.5 Non-Detect 0.1 – 15 Non-Detect – 206 N/A Non-Detect – 10 N/A Cadmium (Cd) <0.5 Non-Detect 0.1 – 3 Non-Detect – 19 Non-Detect – 3 Non-Detect – 17 N/A Chromium (Cr) <2.5 Non-Detect 0.5 – 60 Non-Detect – 168 Non-Detect – 130 Non-Detect – 340 N/A Cobalt (Co) <2.5 Non-Detect 0.5 – 30 Non-Detect – 25.2 Non-Detect – 24 Non-Detect – 213 N/A Lead (Pb) <10 Non-Detect 2 – 80 Non-Detect – 148 Non-Detect – 340 Non-Detect – 229 Non-Detect – Manganese (Mn) 63 - 5 – 300 Non-Detect – 512 Non-Detect – 840 Non-Detect – 15,800 N/A Mercury (Hg) 0.0161 - 0.02 – 1 Non-Detect – 3.1 Non-Detect – 0.2 Non-Detect – 1.1 N/A Nickel (Ni) <5 Non-Detect 0.5 – 50 Non-Detect – 730 Non-Detect – 540 Non-Detect – 175 Non-Detect – Selenium (Se) <5 Non-Detect 0.02 – 10 Non-Detect – 74.3 Non-Detect – 2 Non-Detect – 9.0 NA 

(a) Represents constituent/contaminant data converted to ppm as appropriate originally obtained from Columbia Analytical Services, Inc., Qualitative Laboratory Test Report, Service Request No. T1201895.(b) Information obtained from U.S. EPA's "Contaminant Concentrations in Traditional Fuels: Tables for Comparison" from U.S. EPA was acquired from www.epa.gov/osw/nonhaz/define/pdfs/nhsm_cont_tf.pdf.(c) Constituent/contaminant data obtained from Table A-1 - Refinery Average Stream Hazardous Air Pollutant Compositions—Default Values of the Emission Estimation Protocol for Petroleum Refineries Final ICR.(d) Constituent/contaminant data obtained from Coopers Creek Chemical Corporate Safety Data Sheet for Coopersote Creosote Oil (AWPA P1/P13).(e) Constituent/contaminant data obtained from Material Safety Date Sheet (MSDS) NO. US 614838 for Creosote/Coal Tar Solution and Creosote Oil.

CDF Test Results(a) COAL(b) Wood & Biomass(b) 

Ash Heat Content

Crosstie Sample Solid Fuel
Table A-3

CDF Testing Qualatative Laboratory Results Traditional Fuel Comparison (i.e., Coal, Biomass, Fuel Oil, and Coal Tar Oil) (Indiv

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes Laboratory Result (ppm) Laboratory Comment US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) Literature(b) Sources (ppm) 

Physical/Fuel Characteristics

1 Moisture 27.98 %wt - - - --

0.58 %wt (as received) - - - --0.81 %wt (moist. free) - - - --

6,595 Btu/lb (as received) - - - --9,157 Btu/lb (moist. free) - - - --

Non-HAP/Non-Metal Elements

4 Hydrogen 57,900 - - - -

5 Nitrogen 1,600 - N/A 13,600 – 54,000 200 – 39,500 2,200 – 4,600 42 – 8,950 6 Sulfur 800 - N/A 740 – 61,300 Non-Detect – 8,700 Non-Detect – 6,100 N/A 7 Fluorine 100 - N/A Non-Detect – 178 Non-Detect – 300 Non-Detect – 128 N/A 8 Chlorine 400 - N/A Non-Detect – 9,080 Non-Detect – 2,600 Non-Detect – 5,400 N/A 9 Oxygen (diff) 322,800 ------

10 Carbon 527,200 ------

Volatile Organic Compounds by GC/MS

11 Benzene 0.05 Non-Detect Non-Detect – 38 N/A - - Non-Detect – 75 12 Ethyl benzene 0.0575 - 0.7 – 5.4 N/A - - 22 – 1,270 13 Styrene 0.05 Non-Detect 1.0 – 26 N/A - - Non-Detect – 320 14 Toluene 0.05 Non-Detect 8.6 – 56 N/A - - Non-Detect – 380 15 Xylenes 0.325 (Total) 4.0 – 28 N/A - - Non-Detect – 3,100 16 Cumene 0.05 Non-Detect - - - - 6,000 – 8,600 17 Acrolein 1 Non-Detect - - - --18 Bromomethane 0.05 Non-Detect - - - --19 Carbon Tetrachloride 0.05 Non-Detect - - - --20 Carbon-Disulfide 0.1 Non-Detect - - - --21 Chlorobenzene 0.05 Non-Detect - - - --22 Methyl Isobutyl Ketone 0.1 Non-Detect - - - --23 Methylene Chloride 0.1 Non-Detect - - - --24 m,p-xylene 0.178 ------

25 o-xylene 0.148 - - - - - - 26 Tetrachloroethylene 0.05 Non-Detect - - - --27 Trichloroethylene 0.05 Non-Detect - - - --28 Vinyl Chloride 0.05 Non-Detect - - - --29 n-Hexane 0.05 Non-Detect - - - - 50 – 10,000 

TCLP Volatile Organics by GC/MS

30 1,1-dichloroethylene 0.08 Non-Detect - - - --31 1,2-dichloroethane 0.08 Non-Detect - - - --32 1,4-dichlorobenzene 0.08 Non-Detect - - - --33 Chloroform 0.07 Non-Detect - - - --

Selected HAPS in Condensates by GC/FID ---

34 Acetaldehyde 1.00 Non-Detect - - - --

35 Methanol 1.00 Non-Detect - - - --36 Propionaldehyde 1.00 Non-Detect - - - --

2 Ash 3 Heat Content

CDF Test Results(a) 

Crosstie Sample 

COAL(b) Wood & Biomass(b) Unit

Solid Fuel
Table A-3

CDF Testing Qualatative Laboratory Results Traditional Fuel Comparison (i.e., Coal, Biomass, Fuel Oil, and Coal Tar Oil) (Indiv

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes Laboratory Result (ppm) Laboratory Comment US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) Literature(b) Sources (ppm) 

CDF Test Results(a) 

Crosstie Sample 

COAL(b) Wood & Biomass(b) Unit

Solid Fuel

Semivolatile Organic Compounds by GC/MS

37 2,4-dinitrophenol 57.4 Non-Detect - - - --

38 2,4-dinitrotoluene 14.6 Non-Detect - - - --39 Acetophenone 29.1 Non-Detect - - - --40 Aniline 14.6 Non-Detect - - - --41 Biphenyl 137 ----- 1,000 – 1,200 42 Dibenzofuran 798 ------

43 Hexachlorobenzene 14.6 Non-Detect - - - --44 Pentachlorophenol 57.4 Non-Detect - - - --45 Phenol 14.6 Non-Detect - - - - Non-Detect – 7,700 46 Quinolines 40.2 ------

TCLP Semivolatile Organic Compounds by GC/MS

47 o-cresol 0.05 Non-Detect - - - --

48 m,p-cresol 1.51 ------49 Hexachlorobutadiene 0.05 Non-Detect - - - --50 Hexachloroethane 0.03 Non-Detect - - - --51 Nitrobenzene 0.04 Non-Detect - - - --52 Pyridine 0.20 Non-Detect - - - --53 2,4,5-trichlorophenol 0.03 Non-Detect - - - --54 2,4,6-trichlorophenol 0.03 Non-Detect - - - --

Base Neutral Semivolatile Organic Compounds by GC/MS SIM

55 1-Methylnaphthalene 144 ------

56 2-Methylnaphthalene 251 ------

57 Acenaphthene 610 ------58 Acenaphthylene 58.6 Non-Detect - - - --59 Anthracene 447 ------60 Benz(a)anthracene 201 ------61 Benzo(a)pyrene 81.9 ------62 Benzo(b)fluoranthene 128 ------63 Benzo(g,h,i)perylene 29.3 Non-Detect - - - --64 Benzo(k)fluoranthene 57.9 ------65 Chrysene 182 ------

66 Dibenz(a,h)anthracene 29.3 Non-Detect - - - --

67 Fluoranthene 1,100 ------68 Fluorene 529 ------

69 Indeno(1,2,3-cd)pyrene 29.3 Non-Detect - - - --

70 Naphthalene 444 - - - - - Non-Detect – 7,330 

71 Phenanthrene 1930 ------72 Pyrene 930 ------

Organochlorine Pesticides by Gas Chromatography

73 Chlordane 0.708 Non-Detect - - - --

TCLP Organochlorine Pesticides by Gas Chromatography

74 Lindane 0.2380 ------75 Heptachlor 0.0001 Non-Detect - - - --76 Methoxychlor 0.0003 Non-Detect - - - --77 Toxaphene 0.0030 Non-Detect - - - --

Carbonyl Compounds by High Performance Liquid Chromatography (HPLC)

78 Formaldehyde 1.6 Non-Detect - - 1.6 - 27 N/A -
Table A-3

CDF Testing Qualatative Laboratory Results Traditional Fuel Comparison (i.e., Coal, Biomass, Fuel Oil, and Coal Tar Oil) (Indiv

40 CFR Part 241, Subpart B – Crosstie Derived Fuel (CDF) Petition for Non-Waste Determination

No. Analytes Laboratory Result (ppm) Laboratory Comment US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) US EPA Literature Sources (ppm) US EPA OAQPS Database (ppm) Literature(b) Sources (ppm) 

CDF Test Results(a) 

Crosstie Sample 

COAL(b) Wood & Biomass(b) Unit

Solid Fuel

Trace Metal HAP:

79 Antimony (Sb) <5 Non-Detect 0.5 – 10 Non-Detect – 6.9 Non-Detect – 26 Non-Detect – 6.0 Non-Detect – 15.7 

80 Arsenic (As) <10 Non-Detect 0.5 – 80 Non-Detect – 174 Non-Detect – 6.8 Non-Detect – 298 N/A 81 Beryllium (Be) <0.5 Non-Detect 0.1 – 15 Non-Detect – 206 N/A Non-Detect – 10 N/A 82 Cadmium (Cd) <0.5 Non-Detect 0.1 – 3 Non-Detect – 19 Non-Detect – 3 Non-Detect – 17 N/A 83 Chromium (Cr) <2.5 Non-Detect 0.5 – 60 Non-Detect – 168 Non-Detect – 130 Non-Detect – 340 N/A 84 Cobalt (Co) <2.5 Non-Detect 0.5 – 30 Non-Detect – 25.2 Non-Detect – 24 Non-Detect – 213 N/A 85 Lead (Pb) <10 Non-Detect 2 – 80 Non-Detect – 148 Non-Detect – 340 Non-Detect – 229 Non-Detect – 56.8 86 Manganese (Mn) 63 - 5 – 300 Non-Detect – 512 Non-Detect – 840 Non-Detect – 15,800 N/A 87 Mercury (Hg) 0.016100 - 0.02 – 1 Non-Detect – 3.1 Non-Detect – 0.2 Non-Detect – 1.1 N/A 88 Nickel (Ni) <5 Non-Detect 0.5 – 50 Non-Detect – 730 Non-Detect – 540 Non-Detect – 175 Non-Detect – 50.2 89 Selenium (Se) <5 Non-Detect 0.02 – 10 Non-Detect – 74.3 Non-Detect – 2 Non-Detect – 9.0 NA 

(a) Represents constituent/contaminant data converted to ppm as appropriate originally obtained from Columbia Analytical Services, Inc., Qualitative Laboratory Test Report, Service Request No. T1201895.(b) Information obtained from U.S. EPA's "Contaminant Concentrations in Traditional Fuels: Tables for Comparison" from U.S. EPA was acquired from www.epa.gov/osw/nonhaz/define/pdfs/nhsm_cont_tf.pdf.(c) Constituent/contaminant data obtained from Table A-1 - Refinery Average Stream Hazardous Air Pollutant Compositions—Default Values of the Emission Estimation Protocol for Petroleum Refineries Final ICR.(d) Constituent/contaminant data obtained from Coopers Creek Chemical Corporate Safety Data Sheet for Coopersote Creosote Oil (AWPA P1/P13).(e) Constituent/contaminant data obtained from Material Safety Date Sheet (MSDS) NO. US 614838 for Creosote/Coal Tar Solution and Creosote Oil.
APPENDIX B –

CONSTITUENT/CONTAMINANT RAW TESTING RESULTS








January 29, 2013 Service Request No:T1201895

Mike Sorcher

MA Energy Resources, LLC (MAER)

9225 Indian Creek Pkwy, Suite 670

Overland Park, KS 66210

All analyses were performed according to our laboratory’s quality assurance program. The test 

results meet requirements of the ISO 17025 standards except as noted in the case narrative report. 

All results are intended to be considered in their entirety, and Columbia Analytical Services, Inc. 

dba ALS Environmental (ALS) is not responsible for use of less than the complete report. Results 

apply only to the items submitted to the laboratory for analysis and individual items (samples) 

analyzed, as listed in the report.

For your reference, these analyses have been assigned our service request number

Enclosed are the results of the sample(s) submitted to our laboratory

Laboratory Results for: Railroad Crosstie Derived Fuel (CDF)

Dear Mike,

November 27, 2012

T1201895.

Respectfully submitted,

Columbia Analytical Services, Inc. dba ALS Enviromental

Wendy Hyatt

Project Chemist

1 of 26

Part of the ALS Group A Campbell Brothers Limited Company

Columbia Analytical Services, Inc.

ADDRESS

PHONE FAX

9143 Philips Highway, Suite 200, Jacksonville, FL 32256

+1 904 739 2277 | +1 904 739 2011
CASE NARRATIVE

T1201895

Date Received:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

11/27/12

All analyses were performed consistent with the quality assurance program of Columbia Analytical Services, Inc. (CAS). This

report contains analytical results for samples designated for Tier I data deliverables. When appropriate to the procedure, method

blank results have been reported with each analytical test. Analytical procedures performed by the lab are validated in accordance

with NELAC standards. Parameters that are included in the NELAC Fields of Testing but are not included in the lab’s NELAC

accreditation are identified in the discussion of each analytical procedure.

Sample Receipt

One solid sample was received for analysis at Columbia Analytical Services on 11/27/12. The sample was received in good

condition and consistent with the accompanying chain of custody form. Samples are refrigerated at <6°C upon receipt at the lab

except for aqueous samples designated for metals analyses, which are stored at room temperature. 

Volatile Organic Analyses:

Method 8260B: Method Blank JQ1207986-02 contained a low level amount of Dichloromethane above the Method Detection Limit

(MDL), but less than the Method Reporting Limit (MRL). The data are flagged with a qualifier to indicate the results are estimated

values. The method blank results may indicate the potential for a false positive.

Semi-Volatile Organic Analyses:

Method 8081 TCLP: The confirmation comparison criteria of 40% difference for surrogate analyte Tetrachloro-m-xylene was

exceeded in Laboratory Control Sample JQ1207868-02 (LCS). The higher of the two values were reported because no evidence

of a matrix interference was observed. The confirmation comparison criteria of 40% difference for surrogate analytes Tetrachlorom-xylene and Decachlorobiphenyl was exceeded in sample T1201895-001. The results from the front analytical column were

reported because of a matrix interference observed on the back analytical column. The elevated RPD was likely due to a negative

bias on the back analytical column. The results for this analytical sequence were reported from the front analytical column;

therefore, no further corrective action was taken.

Method 8270C TCLP: The upper control criterion was exceeded for the following analyte in Laboratory Control Sample (LCS)

JQ1207990-03: Quinoline. The analyte in question was detected in the associated field samples. The error associated with

elevated recovery equates to a high bias. The sample data ma y be affected. No further corrective action was appropriate.

Method 8270C: The Method Reporting Limit (MRL) is elevated for all target analytes in sample T1201895-001. The sample was

extracted using approximately 3.5g of sample instead of the usual 30.0g due to problems created by the sample matrix during

extraction, filtration, and concentration.

Method 8081: The spike recovery of analyte Chlordane (technical) for Laboratory Control Sample JQ1208161-03 (LCS) was

outside the lower control criterion at 67% (limit 70-130%). The analyte in question was not detected in the associated field sample.

The error associated with reduced recovery equates to a potential low bias. The pesticide JQ1208161-02 (LCS) recovered within

the acceptance criteria for all pesticide analytes, which indicates the analytical batch was in control. No further corrective action

was taken.

Method 8081: The control criteria were not met for the following surrogates in sample T1201895-001 due to suspected matrix

interferences: Tetrachloro-m-xylene and Decachlorobiphenyl. The extract was highly colored, viscous, emitted a strong odor, and

contained particulates. All of these factors indicated the need to perform a dilution prior to injection into the instrument. The

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sample matrix interference was evident in the chromatography for sample T1201895-001; high concentrations of background/nontarget interference eluted within the retention time windows of interest for the surrogates. No further corrective action was

appropriate.

Method 8081: The reporting limit is elevated for analytes in sample T1201895-001. The sample extract was diluted prior to

instrumental analysis due to relatively high levels of non-target background components. The extract was highly colored, viscous,

emitted a strong odor, and contained particulates. All of these factors indicated the need to perform a dilution prior to injection into

the instrument. Clean-up of the extract was performed within the scope of the method, but did not eliminate enough of the

background components to prevent dilution. The results are flagged to indicate the matrix interference.

Method 8270SIM: The control criteria for the following surrogates in sample T1201895-001 are not applicable: 2-Fluorobiphenyl

and p-Terphenyl-d14 The analysis of the sample required a dilution, which resulted in a surrogate concentration below the Method

Reporting Limit (MRL). No further corrective action was appropriate.

Method 8270SIM: Sample T1201895-001 required dilution due to the presence of elevated levels of target analyte. The reporting

limits are adjusted to reflect the dilution.

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Approved by Date 1/29/2013 3 of 26
State Certifications, Accreditations, and Licenses

Agency Number Expire Date

Florida Department of Health E82502 6/30/2013

Louisiana Department of Environmental Quality 02086 6/30/2013

Georgia Department of Natural Resources 958 6/30/2013

Kentucky Division of Waste Management 63 7/5/2013

South Carolina Department of Health and Environmental Control 96021001 6/30/2013

Texas Commision on Environmental Quality T104704197-09-TX 5/31/2013

Maine Department of Health and Human Services 2011006 2/3/2013

Department of Defense 66206 5/31/2013

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4 of 26
+ Possible Tedlar bag artifact.

A TIC is a suspected aldol-condensation product

B Analyte found in the associated method blank as well as in the sample.

BC Reported results are not blank corrected.

BH The back section of the tube yielded higher results than the front.

BT Results indicated possible breakthrough; back section >=10% front section.

C Result identification confirmed.

D Compound identified in an analysis at a secondary dilution factor

D Spike was diluted out

DE Reported results are corrected for desorption efficiency.

E Estimated value. Concentration above calibration range

E The percent difference for the serial dilution was greater than 10%, indicating a possible 

matrix interference in the sample.

H1 Sample analysis performed past holding time. See case narrative.

H2 Initial analysis within holding time. Reanalysis for the required dilution was past holding 

time.

H3 Sample was received and analyzed past holding time.

H4 Sample was extracted past required extraction holding time, but analyzed within analysis 

holding time. See case narrative.

I Internal standard not within the specified limits. See case narrative.

J Estimated Value. Concentration found below MRL.

K A deflection in the QC ion may indicate interference with the quantitation of this ion. The 

concentration of this analyte should be considered as an estimate.

K Analyte was detected above the method reporting limit prior to normalization.

L1 Laboratory control sample recovery outside the specified limits; results may be biased 

high.

L2 Laboratory control sample recovery outside the specified limits; results may be biased low.

L3 Laboratory control sample recovery outside the specified limits.

M Matrix interference; results may be biased high.

M The duplicate injection precision not met.

M1 Matrix interference due to coelution with a non-target compound; results may be biased 

high.

N Presumptive evidence of a compound for TICs that have been identified based on a mass 

spectral library search.

N The Matrix Spike sample recovery is not within control limits. See case narrative.

P Indicates chlorodiphenyl ether interference present at the retention time of the target 

compound.

P Pesticide/Aroclor target analyte > 40% difference for detected concentrations between GC 

columns

Q Indicates as estimated value because the P and P + 2 theoretical abundance ratio does not 

meet method criteria.

R Duplicate Precision not met.

R1 Duplicate precision not within the specified limits; however, the results are below the 

MRL and considered estimated.

S Surrogate recovery not within specified limits.

Data Qualifiers

CAS Standard

5 of 26
S The reported value was determined by the Method of Standard Additions (MSA).

T Analyte is a tentatively identified compound, result is estimated.

U Compound was analyzed for, but was not detected (ND).

V1 The continuing calibration verification standard was outside (biased high) the specified 

limits for this compound.

V2 The continuing calibration verification standard was outside (biased low) the specified 

limits for this compound.

W Result quantified, but the corresponding peak was detected outside the generated retention 

time window.

W The post-digestion spike for furnace AA analysis is out of control limits, while sample 

absorbance is less than 50% of spike absorbance.

X See case narrative.

Y Recovery outside limits

Y The chromatogram resembles a petroleum product but does not match the calibration 

standard.

Z The chromatogram does not resemble a petroleum product.

i The MRL/MDL has been elevated due to a matrix interference.

Data Qualifiers

CAS Standard

6 of 26
ASTM American Society for Testing and Materials

A2LA American Association for Laboratory Accreditation

CARB California Air Resources Board

CAS Number Chemical Abstract Service registry Number

CFC Chlorofluorocarbon

CFU Colony-Forming Unit

DEC Department of Environmental Conservation

DEQ Department of Environmental Quality

DHS Department of Health Services

DOE Department of Ecology

DOH Department of Health

EPA U. S. Environmental Protection Agency

ELAP Environmental Laboratory Accreditation Program

GC Gas Chromatography

GC/MS Gas Chromatography/Mass Spectrometry

LUFT Leaking Underground Fuel Tank

M Modified

MCL Maximum Contaminant Level is the highest permissible concentration of a 

substance allowed in drinking water as established by the USEPA.

MDL Method Detection Limit

MPN Most Probable Number

MRL Method Reporting Limit

NA Not Applicable

NC Not Calculated

NCASI National Council of the Paper Industry for Air and Stream Improvement

ND Not Detected

NIOSH National Institute for Occupational Safety and Health

PQL Practical Quantitation Limit

RCRA Resource Conservation and Recovery Act

SIM Selected Ion Monitoring

TPH Total Petroleum Hydrocarbons

tr Trace level is the concentration of an analyte that is less than the PQL but 

greater than or equal to the MDL.

Acronyms

ALS Laboratory Group

7 of 26
T1201895-001 CDF 11/27/2012 0000

Client: MA Energy Resources, LLC (MAER) Service Request:T1201895

Project: Railroad Crosstie Derived Fuel (CDF)

SAMPLE CROSS-REFERENCE

SAMPLE # CLIENT SAMPLE ID DATE TIME

Printed 1/29/2013 2:18:29 PM 8 of 26 Sample Summary
Lab Code: T1201895-001

Sample Name: CDF

Volatile Organic Compounds by GC/MS

11/27/12 00:00

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8260B

Prep Method: EPA 5035

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

4-Methyl-2-pentanone (MIBK) 100 U 100 1 12/11/12 20:12 12/11/12

Acrolein 1000 U 1000 1 12/11/12 20:12 12/11/12

Benzene 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Bromomethane 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Carbon Disulfide 100 U 100 1 12/11/12 20:12 12/11/12

Carbon Tetrachloride 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Chlorobenzene 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Ethylbenzene 57.5 50.0 1 12/11/12 20:12 12/11/12

Isopropylbenzene 50.0 U 50.0 1 12/11/12 20:12 12/11/12

m,p-Xylenes 178 100 1 12/11/12 20:12 12/11/12

Methylene Chloride 100 U 100 1 12/11/12 20:12 12/11/12

n-Hexane 50.0 U 50.0 1 12/11/12 20:12 12/11/12

o-Xylene 148 50.0 1 12/11/12 20:12 12/11/12

Styrene 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Tetrachloroethene (PCE) 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Toluene 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Trichloroethene (TCE) 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Vinyl Chloride 50.0 U 50.0 1 12/11/12 20:12 12/11/12

Xylenes, Total 325 150 1 12/11/12 20:12 12/11/12

Surrogate Name % Rec Control Limits Date Analyzed Q

1,2-Dichloroethane-d4 84 80 - 120 12/11/12 20:12

4-Bromofluorobenzene 105 64 - 135 12/11/12 20:12

Dibromofluoromethane 85 74 - 125 12/11/12 20:12

Toluene-d8 116 46 - 156 12/11/12 20:12

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

9 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

TCLP Volatile Organics by GC/MS

11/27/12 00:00

As Received

mg/L

Basis:

Units:

Analysis Method: 8260B Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/4/12

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Q

1,1-Dichloroethene (1,1-DCE) 0.100 U 0.100 100 12/07/12 21:47

1,2-Dichloroethane 0.100 U 0.100 100 12/07/12 21:47

1,4-Dichlorobenzene 0.100 U 0.100 100 12/07/12 21:47

Chloroform 0.100 U 0.100 100 12/07/12 21:47

Surrogate Name % Rec Control Limits Date Analyzed Q

1,2-Dichloroethane-d4 102 72 - 121 12/07/12 21:47

4-Bromofluorobenzene 104 86 - 113 12/07/12 21:47

Dibromofluoromethane 103 86 - 112 12/07/12 21:47

Toluene-d8 102 88 - 115 12/07/12 21:47

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

10 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

Selected HAPS in Condensates by GC/FID

11/27/12 00:00

As Received

mg/Kg

Basis:

Units:

Analysis Method: NCASI HAPS-99.01

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Q

Acetaldehyde 1.0 U 1.0 1 12/11/12 16:19

Methanol 1.0 U 1.0 1 12/11/12 16:19

Propionaldehyde 1.0 U 1.0 1 12/11/12 16:19

Surrogate Name % Rec Control Limits Date Analyzed Q

Cyclopentanol 72 50 - 150 12/11/12 16:19

Analytical Report

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Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

11 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

Semivolatile Organic Compounds by GC/MS

11/27/12 00:00

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8270C

Prep Method: EPA 3550C

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

MA Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

2,4-Dinitrophenol 57400 U 57400 10 12/18/12 21:57 12/6/12

2,4-Dinitrotoluene 14600 U 14600 10 12/18/12 21:57 12/6/12

Acetophenone 29100 U 29100 10 12/18/12 21:57 12/6/12

Aniline 14600 U 14600 10 12/18/12 21:57 12/6/12

Biphenyl 137000 29100 10 12/18/12 21:57 12/6/12

Dibenzofuran 798000 14600 10 12/18/12 21:57 12/6/12

Hexachlorobenzene 14600 U 14600 10 12/18/12 21:57 12/6/12

Pentachlorophenol (PCP) 57400 U 57400 10 12/18/12 21:57 12/6/12

Phenol 14600 U 14600 10 12/18/12 21:57 12/6/12

Quinoline 40200 - 10 12/18/12 21:57 12/6/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2,4,6-Tribromophenol 58 28 - 164 12/18/12 21:57

2-Fluorobiphenyl 71 33 - 133 12/18/12 21:57

2-Fluorophenol 54 10 - 126 12/18/12 21:57

Nitrobenzene-d5 60 25 - 138 12/18/12 21:57

Phenol-d6 59 10 - 170 12/18/12 21:57

p-Terphenyl-d14 72 16 - 168 12/18/12 21:57

Tentatively Identified Compounds

Compound Identification RT

Result

CAS# ug/Kg Q

No Tentatively Identified Compounds 

Detected

Analytical Report

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Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

12 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

TCLP Semivolatile Organic Compounds by GC/MS

11/27/12 00:00

As Received

mg/L

Basis:

Units:

Analysis Method: 8270C

Prep Method: EPA 3510C

Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/6/12

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

o-Cresol, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

m,p-Cresols, TCLP 0.0755 0.0500 1 12/14/12 07:45 12/12/12

Hexachlorobutadiene, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

Hexachloroethane, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

Nitrobenzene, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

Pyridine, TCLP 0.200 U 0.200 1 12/14/12 07:45 12/12/12

2,4,5-Trichlorophenol, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

2,4,6-Trichlorophenol, TCLP 0.0500 U 0.0500 1 12/14/12 07:45 12/12/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2,4,6-Tribromophenol 72 13 - 133 12/14/12 07:45

2-Fluorobiphenyl 60 22 - 105 12/14/12 07:45

2-Fluorophenol 53 10 - 69 12/14/12 07:45

Nitrobenzene-d5 59 10 - 123 12/14/12 07:45

Phenol-d6 44 10 - 59 12/14/12 07:45

p-Terphenyl-d14 71 28 - 120 12/14/12 07:45

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

13 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

Base Neutral Semivolatile Organic Compounds by GC/MS SIM

11/27/12 00:00

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8270C SIM

Prep Method: EPA 3550C

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

1-Methylnaphthalene 144000 29300 5000 12/19/12 17:37 12/13/12

2-Methylnaphthalene 251000 29300 5000 12/19/12 17:37 12/13/12

Acenaphthene 610000 58600 5000 12/19/12 17:37 12/13/12

Acenaphthylene 58600 U 58600 5000 12/19/12 17:37 12/13/12

Anthracene 447000 29300 5000 12/19/12 17:37 12/13/12

Benz(a)anthracene 201000 29300 5000 12/19/12 17:37 12/13/12

Benzo(a)pyrene 81900 29300 5000 12/19/12 17:37 12/13/12

Benzo(b)fluoranthene 128000 29300 5000 12/19/12 17:37 12/13/12

Benzo(g,h,i)perylene 29300 U 29300 5000 12/19/12 17:37 12/13/12

Benzo(k)fluoranthene 57900 29300 5000 12/19/12 17:37 12/13/12

Chrysene 182000 29300 5000 12/19/12 17:37 12/13/12

Dibenz(a,h)anthracene 29300 U 29300 5000 12/19/12 17:37 12/13/12

Fluoranthene 1100000 29300 5000 12/19/12 17:37 12/13/12

Fluorene 529000 29300 5000 12/19/12 17:37 12/13/12

Indeno(1,2,3-cd)pyrene 29300 U 29300 5000 12/19/12 17:37 12/13/12

Naphthalene 444000 29300 5000 12/19/12 17:37 12/13/12

Phenanthrene 1930000 58600 5000 12/19/12 17:37 12/13/12

Pyrene 930000 29300 5000 12/19/12 17:37 12/13/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2-Fluorobiphenyl 0 30 - 118 12/19/12 17:37 *

p-Terphenyl-d14 0 41 - 146 12/19/12 17:37 *

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:29 PM 12-0000232496 rev 00

14 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

Organochlorine Pesticides by Gas Chromatography

11/27/12 00:00

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8081A

Prep Method: EPA 3541

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

Chlordane 708 U 708 10 12/18/12 16:47 12/18/12 *

Surrogate Name % Rec Control Limits Date Analyzed Q

Decachlorobiphenyl 0 32 - 170 12/18/12 16:47 *

Tetrachloro-m-xylene 0 10 - 147 12/18/12 16:47 *

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

15 of 26

Superset Reference:
Lab Code: T1201895-001

Sample Name: CDF

TCLP Organochlorine Pesticides by Gas Chromatography

11/27/12 00:00

As Received

mg/L

Basis:

Units:

Analysis Method: 8081A

Prep Method: EPA 3510C

Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/6/12

11/27/12 09:45

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

gamma-BHC (Lindane), TCLP 0.0119 0.000200 1 12/12/12 00:14 12/11/12

Heptachlor, TCLP 0.000200 U 0.000200 1 12/12/12 00:14 12/11/12

Methoxychlor, TCLP 0.000400 U 0.000400 1 12/12/12 00:14 12/11/12

Toxaphene, TCLP 0.00500 U 0.00500 1 12/12/12 00:14 12/11/12

Surrogate Name % Rec Control Limits Date Analyzed Q

Decachlorobiphenyl 36 10 - 160 12/12/12 00:14

Tetrachloro-m-xylene 38 22 - 126 12/12/12 00:14

Analytical Report

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Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

16 of 26

Superset Reference:
Lab Code: JQ1207986-02

Sample Name: Method Blank

Volatile Organic Compounds by GC/MS

NA

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8260B

Prep Method: EPA 5035

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

4-Methyl-2-pentanone (MIBK) 10.0 U 10.0 1 12/11/12 18:46 12/11/12

Acrolein 100 U 100 1 12/11/12 18:46 12/11/12

Benzene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Bromomethane 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Carbon Disulfide 10.0 U 10.0 1 12/11/12 18:46 12/11/12

Carbon Tetrachloride 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Chlorobenzene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Ethylbenzene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Isopropylbenzene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

m,p-Xylenes 10.0 U 10.0 1 12/11/12 18:46 12/11/12

Methylene Chloride 10.0 U 10.0 1 12/11/12 18:46 12/11/12

n-Hexane 5.00 U 5.00 1 12/11/12 18:46 12/11/12

o-Xylene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Styrene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Tetrachloroethene (PCE) 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Toluene 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Trichloroethene (TCE) 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Vinyl Chloride 5.00 U 5.00 1 12/11/12 18:46 12/11/12

Xylenes, Total 15.0 U 15.0 1 12/11/12 18:46 12/11/12

Surrogate Name % Rec Control Limits Date Analyzed Q

1,2-Dichloroethane-d4 97 80 - 120 12/11/12 18:46

4-Bromofluorobenzene 94 64 - 135 12/11/12 18:46

Dibromofluoromethane 88 74 - 125 12/11/12 18:46

Toluene-d8 101 46 - 156 12/11/12 18:46

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

17 of 26

Superset Reference:
Lab Code: JQ1207774-01

Sample Name: Method Blank

TCLP Volatile Organics by GC/MS

NA

As Received

mg/L

Basis:

Units:

Analysis Method: 8260B Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/4/12

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Q

1,1-Dichloroethene (1,1-DCE) 0.100 U 0.100 100 12/07/12 13:32

1,2-Dichloroethane 0.100 U 0.100 100 12/07/12 13:32

1,4-Dichlorobenzene 0.100 U 0.100 100 12/07/12 13:32

Chloroform 0.100 U 0.100 100 12/07/12 13:32

Surrogate Name % Rec Control Limits Date Analyzed Q

1,2-Dichloroethane-d4 101 72 - 121 12/07/12 13:32

4-Bromofluorobenzene 108 86 - 113 12/07/12 13:32

Dibromofluoromethane 102 86 - 112 12/07/12 13:32

Toluene-d8 100 88 - 115 12/07/12 13:32

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

18 of 26

Superset Reference:
Lab Code: JQ1208083-01

Sample Name: Method Blank

Selected HAPS in Condensates by GC/FID

NA

As Received

mg/Kg

Basis:

Units:

Analysis Method: NCASI HAPS-99.01

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Q

Acetaldehyde 1.0 U 1.0 1 12/11/12 15:08

Methanol 1.0 U 1.0 1 12/11/12 15:08

Propionaldehyde 1.0 U 1.0 1 12/11/12 15:08

Surrogate Name % Rec Control Limits Date Analyzed Q

Cyclopentanol 72 50 - 150 12/11/12 15:08

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

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Superset Reference:
Lab Code: JQ1208159-01

Sample Name: Method Blank

Semivolatile Organic Compounds by GC/MS

NA

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8270C

Prep Method: EPA 3550C

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

2,4-Dinitrophenol 670 U 670 1 12/19/12 09:59 12/6/12

2,4-Dinitrotoluene 170 U 170 1 12/19/12 09:59 12/6/12

Acetophenone 340 U 340 1 12/19/12 09:59 12/6/12

Aniline 170 U 170 1 12/19/12 09:59 12/6/12

Biphenyl 340 U 340 1 12/19/12 09:59 12/6/12

Dibenzofuran 170 U 170 1 12/19/12 09:59 12/6/12

Hexachlorobenzene 170 U 170 1 12/19/12 09:59 12/6/12

Pentachlorophenol (PCP) 670 U 670 1 12/19/12 09:59 12/6/12

Phenol 170 U 170 1 12/19/12 09:59 12/6/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2,4,6-Tribromophenol 75 28 - 164 12/19/12 09:59

2-Fluorobiphenyl 80 33 - 133 12/19/12 09:59

2-Fluorophenol 66 10 - 126 12/19/12 09:59

Nitrobenzene-d5 74 25 - 138 12/19/12 09:59

Phenol-d6 74 10 - 170 12/19/12 09:59

p-Terphenyl-d14 95 16 - 168 12/19/12 09:59

Tentatively Identified Compounds

Compound Identification RT

Result

CAS# ug/Kg Q

No Tentatively Identified Compounds 

Detected

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

20 of 26

Superset Reference:
Lab Code: JQ1207868-01

Sample Name: Method Blank

TCLP Semivolatile Organic Compounds by GC/MS

NA

As Received

mg/L

Basis:

Units:

Analysis Method: 8270C

Prep Method: EPA 3510C

Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/6/12

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

o-Cresol, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

m,p-Cresols, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

Hexachlorobutadiene, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

Hexachloroethane, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

Nitrobenzene, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

Pyridine, TCLP 0.200 U 0.200 1 12/14/12 06:32 12/12/12

2,4,5-Trichlorophenol, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

2,4,6-Trichlorophenol, TCLP 0.0500 U 0.0500 1 12/14/12 06:32 12/12/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2,4,6-Tribromophenol 95 13 - 133 12/14/12 06:32

2-Fluorobiphenyl 91 22 - 105 12/14/12 06:32

2-Fluorophenol 68 10 - 69 12/14/12 06:32

Nitrobenzene-d5 88 10 - 123 12/14/12 06:32

Phenol-d6 51 10 - 59 12/14/12 06:32

p-Terphenyl-d14 97 28 - 120 12/14/12 06:32

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

21 of 26

Superset Reference:
Lab Code: JQ1208048-01

Sample Name: Method Blank

Base Neutral Semivolatile Organic Compounds by GC/MS SIM

NA

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8270C SIM

Prep Method: EPA 3550C

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

1-Methylnaphthalene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

2-Methylnaphthalene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

Acenaphthene 6.80 U 6.80 1 12/14/12 03:23 12/13/12

Acenaphthylene 6.80 U 6.80 1 12/14/12 03:23 12/13/12

Anthracene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

Benz(a)anthracene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Benzo(a)pyrene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Benzo(b)fluoranthene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Benzo(g,h,i)perylene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Benzo(k)fluoranthene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Chrysene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Dibenz(a,h)anthracene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Fluoranthene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

Fluorene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

Indeno(1,2,3-cd)pyrene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Naphthalene 3.40 U 3.40 1 12/14/12 03:23 12/13/12

Phenanthrene 6.80 U 6.80 1 12/14/12 03:23 12/13/12

Pyrene 3.40 U 3.40 1 12/17/12 13:09 12/13/12

Surrogate Name % Rec Control Limits Date Analyzed Q

2-Fluorobiphenyl 72 30 - 118 12/14/12 03:23

p-Terphenyl-d14 0 41 - 146 12/14/12 03:23 *

p-Terphenyl-d14 124 41 - 146 12/17/12 13:09

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

22 of 26

Superset Reference:
Lab Code: JQ1208161-01

Sample Name: Method Blank

Organochlorine Pesticides by Gas Chromatography

NA

As Received

ug/Kg

Basis:

Units:

Analysis Method: 8081A

Prep Method: EPA 3541

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

Chlordane 34.0 U 34.0 1 12/18/12 15:29 12/18/12

Surrogate Name % Rec Control Limits Date Analyzed Q

Decachlorobiphenyl 62 32 - 170 12/18/12 15:29

Tetrachloro-m-xylene 59 10 - 147 12/18/12 15:29

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

23 of 26

Superset Reference:
Lab Code: JQ1207868-01

Sample Name: Method Blank

TCLP Organochlorine Pesticides by Gas Chromatography

NA

As Received

mg/L

Basis:

Units:

Analysis Method: 8081A

Prep Method: EPA 3510C

Pre-Prep Method: EPA 1311

Pre-Prep Date: 12/6/12

NA

T1201895

Date Received:

Date Collected:

Service Request:

Solid

Railroad Crosstie Derived Fuel (CDF)

M.A. Energy Resources, LLC (MAER)

Sample Matrix:

Project:

Client:

Analyte Name Result MRL Dil. Date Analyzed Date Extracted Q

gamma-BHC (Lindane), TCLP 0.000200 U 0.000200 1 12/11/12 16:47 12/11/12

Heptachlor, TCLP 0.000200 U 0.000200 1 12/11/12 16:47 12/11/12

Methoxychlor, TCLP 0.000400 U 0.000400 1 12/11/12 16:47 12/11/12

Toxaphene, TCLP 0.00500 U 0.00500 1 12/11/12 16:47 12/11/12

Surrogate Name % Rec Control Limits Date Analyzed Q

Decachlorobiphenyl 76 10 - 160 12/11/12 16:47

Tetrachloro-m-xylene 80 22 - 126 12/11/12 16:47

Analytical Report

COLUMBIA ANALYTICAL SERVICES, INC.

Now part of the ALS Group

Printed 1/29/2013 2:18:30 PM 12-0000232496 rev 00

24 of 26

Superset Reference:
25 of 26
26 of 26
ADDRESS 3860 S. Palo Verde Road, Suite 302, Tucson, AZ 85714

PHONE +1 520 573 1061 

FAX +1 520 573 1063

Page 1 of 1 Rpt-T1201895 M.A. Energy Resources LLC MAER Sorcher,

 12/26/2012

formerly Columbia Analytical Services, Inc

Client: M.A. Energy Resources, LLC (MAER)

9225 Indian Creek Pkwy, Suite 670

Overland Park, KS 66210

Attn: Mike Sorcher

Project: Railroad Crosstie Derived Fuel (CDF) Date Received:

CDF 11/27/12 T1201895-001 27.98 0.58 0.81 6,595 9,157 16.1

CDF 11/27/12 T1201895-001 52.72 5.79 0.16 32.28 0.080 0.04 0.01

Note:

Sample air dried at 35°C then ground to < 1mm prior to analysis. 

D6722

Mercury

Lab #:

Lab #:

Ash

Nitrogen Sulfur

D4239

Oxygen

Sample ID: D5373 mod

Sample 

Date & 

Time

Sample ID:

Sample 

Date & 

Time As Received

wt%

Moist. Free

ppb wt% Moist. Freewt%

Moisture,

Total

D7582 - Automated TGA System D5865

Moist. Free

wt%

Carbon

D5373

Hydrogen

December 26, 2012

November 27, 2012

Certificate of Analysis

As Received

BTU/lb

Moist. Free

BTU/lb

Heating Value

5050/9056

As Received

wt%

Moist. Free

wt%

Chlorine Fluorine

Moist. Free

wt%

Moist. Free

wt%

Moist. Free

wt%

Moist. Free

wt%
ADDRESS 3860 S. Palo Verde Road, Suite 302, Tucson, AZ 85714

PHONE +1 520 573 1061 

FAX +1 520 573 1063

Page 1 of 1 Rpt-T1201895 M.A. Energy Resources LLC MAER Sorcher,

 12/26/2012

formerly Columbia Analytical Services, Inc

Client: M.A. Energy Resources, LLC (MAER)

9225 Indian Creek Pkwy, Suite 670

Overland Park, KS 66210

Attn: Mike Sorcher

Project: Railroad Crosstie Derived Fuel (CDF) Date Received:

CDF 11/27/12 T1201895-001 < 5 < 10 <0.5 < 0.5 < 2.5 < 2.5 < 10

CDF 11/27/12 T1201895-001 63 < 5 < 5

Note:

Sample air dried at 35°C then ground to < 1mm prior to analysis. 

Results with '<' are below the detection limit. 

Arsenic Beryllium Cadmium Chromium Cobalt

Total Dissolution / ICP- OES

Lead

Wendy Hyatt, Project Chemist

Sample ID: Total Dissolution / ICP- OES

Sample 

Date & 

Time

Lab #:

Mangenese Nickel Selenium

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Moist. Free

mg/kg

Certificate of Analysis

Sample ID:

Sample 

Date & 

Time

Lab #:

Antimony

December 26, 2012

November 27, 2012