Faison, George 

From: 

Sent: 

To: 

Cc: 

Subject: 

Faison, George 

Wednesday, August 05, 2015 5:28 PM 

'Greg Baumann' 

Miller, Jesse 

RE: Call 

Hi Greg- some thoughts on the sampling approach. 

1. Obtain the same information 

required in the regs 

to justify our request as if we were filing a petition -in general agree. The petition info 

2. Samples 

includes info on "balancing legitimacy criteria" but this concept would not apply to a letter. 

clarification 

from ties should be obtained from a diverse area preferably multiple geographical areas -agree, if the 

3. Samples 

letter is to be applicable at various combustion sites or come from multiple processors. 

mixture cont

should 

aining 

be 

CuNa-treated 

processed with 

wood 

other materials at an operating plant- Since the clarification letter will pertain to a 

address inter-processor variability, 

and C&D wood (or other material) being com busted, then it will be important to 

operations and compositions 

as well as intra-processor variability at each processor to address the range of 

which is addressed 

of this mixture that could occur. Therefore, with respect to inter-processor variability 

in #2, samples should ideally be taken from a selection of processors/geographical 

should reflect 

regions, and 

the range of possible mixtures of CuNA-treated + C&D wood feedstocks available. It is recommended 

the general percentages of 

that 

wood). For 

composition of the mix be recorded for each sample (e.g., 40% CuNA ties, 60% C&D 

days to provide 

intra

a 

-p

data 

rocessor variability, there should ideally be at least two unique samples taken on different operating 

in duplicate or 

set that reflects operational variability at the site. Lastly, each sample taken should be analyzed 

triplicate (preferable) 

should be used 

to ensure the analytical precision of the test. A standard sampling technique 

for all samples taken at all facilities and to ensure there are no sampling errors being introduced 

actual sample collection. 

in the 

copper 

4. Samples 

naphthenate 

should be taken from feed stock prior to burning for analysis at a lab and should not be segregated (e.g. only 

#3 notes above on notin

tie 

g 

material 

how much 

but composite of whatever the processor is grinding)- this is fine, but refer to #2 and 

of the feed stock consists of CuNa-treated 

5. Samples 

ties, vs C&D or clean biomass. 

requirements 

then should go to a lab with multiple replicates for HAP analysis and Btu analysis compliant with 

sample are nec

found 

essary 

in 40 CFR 241- agree, see 113 for suggested sampling protocol ideas. Multiple replicates for each 

intra-processor variability. 

to ensure analytical precision. Multiple samples/analyses are required for a facility to determine 

include 

6. Explain 

the 

in 

processing 

detail the entire 

of 

process from ties coming out of track through final processing.- agree, and should also 

the overall mix, since the clarification 

other material). 

letter will apply to a mixture of ties and C&O wood (or 

George Faison 

U.S. Environmental Protection Agency 

OSWER, ORCR 

1200 Pennsylvania Avenue, NW 

Mail Code 5303P 

Washington, DC 20460 

Phone - (703)305-7652 

faison.george@epa.gov 

From: Greg Baumann [mailto:gregb@nisuscorp.com] 

Sent: Wednesday, August 05, 2015 11:53 AM 
To: Faison, George 

Subject: Call 

George, 

We appreciate the call today. You and Jesse were kind to follow up with some new thoughts. 

Just to confirm my understanding of information needed to request a clarification letter, we should: 

1. Obtain the same information to justify our request as if we were filing a petition 

3. 

2. 

Samples 

Samples from ties should be obtained from a diverse area preferably multiple geographical areas 

should be processed with other materials at an operating plant 

copper 

4. Samples 

naphthenate 

should be taken from feed stock prior to burning for analysis at a lab and should not be segregated (e.g. only 

tie material but composite of whatever the processor is grinding) 

5. Samples then should go to a lab with multiple replicates for HAP analysis and Btu analysis compliant with 

requirements found in 40CFR241 

6. Explain in detail the entire process from ties coming out of track through final processing. 

we 

I just 

would 

want 

like 

to make sure that we understand what should be done as we draft our protocol. After our protocol is drafted, 

list sampling 

to submit to you for your thoughts to make sure that we cover what you are requesting. The protocol will 

sending a 

technique as well as locations and what data are ~o be collected from the samples. This will eliminate 

letter of request with incomplete process and/or data. 

Thank you again for your time. 

Greg 

Greg Baumann 

Vice President, Technical Services and Regulatory Affairs 

Nisus Corporation 

100 Nisus Drive 1 Rockford, TN 37853 

865.577.6119 (office) 1 865.214.2739 (mobile) 1 865.577.5825 (fax) 1 

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