p. 1 of 2 

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

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

To: Putney, David 

Subject: FW: ICR data 

David, 

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

concerning the roof data reporting. 

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

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

regards to this. 

We will amend the report as to the PCB revision. 

Scott B.

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

Don Backfisch 

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

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

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data 

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

until all issues have been dealt with.

Scott B. 

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

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

To: Scott Brown (sbrown@cleanair.com) 

Subject: FW: ICR data

 

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

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

a corrected “final” report and spreadsheet. 

Don Backfisch 

 
p. 2 of 2 

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

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

To: Backfisch Don (NORALNM) 

Subject: RE: ICR data

 

Don,

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

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

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

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

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

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

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

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

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

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

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

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

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

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

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

represent emissions based on roof vent flow rates.

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

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

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

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

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

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

Thanks,

David Putney, Environmental Engineer

U.S. Environmental Protection Agency

Office of Air Quality Planning and Standards

Sector Policies and Programs Division

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

Mail Drop D243-02

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

Email: putney.david@epa.gov