### Fai s on , G e orge From : Se nt : To : Cc: Subj ect: Faison , George Wednesday, August 

### 05, 20 1 5 5:2 8 PM 'Greg Baumann' Miller, Jesse RE: Call Hi Greg- some thoughts on the sampling approach. 

### 1. Obtain the same information to justify our request as if we were filing a petition -in general agree. The petition info required in the regs includes info on "bala ncing l eg itima cy criteria" but this co n cept would not app ly to a l etter. 2. Samples from ties should be obtained from a diverse area preferably multiple geograp h ical areas -agree, if the clarification letter is to be applicable at vari ous combustion sites or come from multiple processors. 3. Samples should be processed with other materials at an operating plant- Since the cla rifi cation letter will pertain to a mixture co ntai ning CuNa-treated wood and C&D wood (or other material) being com busted, th en it will be important to address inter-processor variability, as well as intra-processor variability at each processor to address th e range of operations and compositions of this mixture that could occur. Therefore, w ith respect to inter -p rocessor variability which is addressed in #2, samp l es should ideally be taken from a selection of processors/geographical regions, and should reflect the range of possib l e mixtures of CuNA-treated 

### + C&D wood feedstocks avai l able. It is recommended that the general percentages of compos ition of the mix be recorded for each sample (e.g., 40% CuNA ti es, 60% C&D wood). For intra -p rocessor variability, there should ideally be at least two unique samples taken on differ e nt operating days to provide a data set that reflects operational variability at the site. Lastly, each sample taken should be analyzed in duplicate or tripli cate (preferable) to ensure the ana lytical precision of the test. A standard sampling technique should be used for all samples taken at all fa ciliti es and to ensure th e re are no sampling e rrors being introduced in the actual sample collection. 4 . Samples should be taken from feed stock prior to burning for analysis at a lab and should not be segregated (e .g. only copper naphthenate tie material but composite of whatever the processor is grinding)- this is fine, but refer to #2 and #3 notes above on notin g how much of the feed stock consists of CuNa-treated ties, vs C&D or clean bioma ss. 5 . Samples then should go to a lab with multiple replicates for HAP analysis and Btu analysis comp l iant with requirements found in 40 CFR 241- agree, see 113 for suggested sampling protocol ideas. Multiple replicates for each sample are n ecessary to ensure analytical precision. Multiple samples/analyses are required for a facility to determine intra-processor variability. 6. Explain in detail the entire process from ties coming out of track through final processi n g.- agree, and should also include the processing of the overall mix, since the clarification letter will apply to a mixture of ties and C&O wood (or other material). George Faison U.S. Environmenta l 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] Se nt : Wednesday, August 05, 2015 11:53 AMTo: Faison, George Subj ect: 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 lette r, we should: 1. Obtain the sam e information to justify our request as if we were filing a petition 2. Samples from ties should be obtained from a diverse area preferably multiple geographical areas 3. Samples should be processed with other materials at an operating plant 4. Samples should be taken from feed stock prior to burning for analysis at a lab and should not be segregated (e.g. only copper naphthenate ti e 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 d etail the e ntire process from ties coming out of track through final processing . I just want to make sure that we understand what should be done as we draft our protocol. After our protocol is drafted , we would like to submit to you for your thoughts to make sure that we cover what you are requesting. The protocol will list sampling technique as well as locations and what data are

**~o** be collected from the samples. This will eliminate sending a letter of request with incomplete process and/or data . Thank you again for your time. Greg 

### Greg B a um a nn 

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