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From: Backfisch Don (NORALNM) [ mailto:Don.Backfisch@noralinc.com ]
Sent: Friday, August 02, 2013 3:01 PM
To: Putney, David Subject: FW: ICR data

David,

Attached are the ERT spreadsheets with the correcte d PCB data. Below is Scott Brown’s response concerning the roof data reporting.

Don, The footnote on table 1-2 states that the lb/h r results are based on the total flow rate per meth od 14. It is also reiterated in the second to last paragraph on page 1-4. I am not sure what David wants me to do in regards to this.

We will amend the report as to the PCB revision.

Scott B.

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

Don Backfisch

From: Scott Brown [ mailto:sbrown@cleanair.com ]
Sent: Friday, August 02, 2013 1:40 PM
To: Backfisch Don (NORALNM) Subject: RE: ICR data

Don, Attached are the ERT spreadsheets with the PCB data corrected. I will hold off on issuing a revi sed report
until all issues have been dealt with.

Scott B.

From: Backfisch Don (NORALNM) [mailto: Don.Backfisch@noralinc.com ]
Sent: Friday, August 02, 2013 7:24 AM
To: Scott Brown ( sbrown@cleanair.com ) Subject: FW: ICR data

Further comments from David Putney on the ICR repor t. I will pass his comments on to you as I receive them. When we have responded to all of his comments and questions, we will need to submit a corrected “final” report and spreadsheet.

Don Backfisch

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From: Putney, David [ mailto:putney.david@epa.gov ]
Sent: Thursday, August 01, 2013 4:23 PM
To: Backfisch Don (NORALNM) Subject: RE: ICR data

Don,

It would be preferable to get a corrected report an d spreadsheets since those items will eventually be added to the docket for this rulemaking action. That is, it would probably better to simply put the correcte d versions in the docket as opposed to the originals with addi tional documents to show corrections. Also, I agree with your approach of addressing all the issues before r esubmitting the report. However, it would be good t o know the answers to my questions when you get the inform ation. That is, please inform me of the lab’s respo nse when you get it – as opposed to waiting until the r evised report is completed.

I actually have a follow up comment/question to my email from yesterday. Based on a quick review of th e secondary potline PCB emissions (presented in Table 2-4 of the final report), it appears that those em issions (in units of lb/hr) are based on the downcomer flow rat e (as opposed to the roof vent flow rate). For exam ple, when I attempted to reproduce the Mono PCB emission s associated with run 1 on the roof 2 duct, I came up with emissions values of 1.65 E-04 lb/ton and 1.71 E-03 lb/hr. These match the values in your summary spreadsheet but not the lb/hr emission value in Tab le 2-4 of the Final Report. However, the lb/hr emis sion rate
for Mono PCB does match if I use the downcomer flow rate instead of the roof vent flow rate. This coul d be a source of confusion during the public comment perio d. You may want to either modify the table in the r eport to clarify that the lb/hr values are based on the d owncomer flow rates, or modify the emissions values to represent emissions based on roof vent flow rates.

Also, as mentioned in my previous email, the report ed PCB emissions values appear to be overestimated by a factor of 1,000 as a result of the lab reporting th eir results in units of picograms (pg) but those re sults being changed to units of nanograms (ng) in the spreadshe ets and Final Report tables. (See for example, the mass value for Mono PCBs from run 1 on the roof 2 duct – cited as 250 ng in the spreadsheets and Table 2-4 in the Final Report as opposed to 250 pg as shown in the l ab data on page G-149 of the report). This would ce rtainly be something that should be revised before putting the document in the docket.

Thanks,

David Putney, Environmental Engineer U.S. Environmental Protection Agency Office of Air Quality Planning and Standards Sector Policies and Programs Division 109 T.W. Alexander Drive, RTP, NC 27711 Mail Drop D243-02 Ph: (919) 541-2016 Fax: (919) 541-3207

Email: putney.david@epa.gov