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FROM: Morgan Hoff & Timothy Brand
members of West Valley Citizen Air Watch 10377 Vista Knoll Blvd.,
Cupertino, CA 95014 (408)733-5570

Critique of Dames & Moore Report "Analysis of Emissions Test Results and Residual By-Products from Facilities Using Tires as a Fuel Supplement" IWM-C5064

DATE: January 12, 1998
D&M General Critique


Simply stated, D&M is junk science. The data is sloppy and scientifically inadmissible. The method used to analyze the data is bad science and the authors donit admit or perhaps never realized that their conclusions were clearly not statistically significant. Due to its many severe faults in data and methodology the Dames & Moore report "Analysis of Emissions Test Results O" should be set aside as simply not credible. Overview Simply stated, the purpose of the Dames & Moore report "Analysis of Emissions Test Results and Residual By-Products from Facilities Using Tires as a Fuel Supplement" IWM-C5064 (D&M) is to answer two questions:

1. Can one prove with statistical significance that the emissions from industrial fires do not increase when tires are added as a fuel supplement? Typical industrial fires would be associated with cement kilns, industrial boilers, lime kilns.
2. Can one prove with statistical significance that adding tires as a fuel supplement to industrial fires is safe from the viewpoint of health effects?


A good way to answer the two questions above would be to collect data from industrial fires at several facilities, confirm that the only variable was the use of tires as a fuel supplement and individually determine for each facility what impact the addition of tires had on emissions and health risks. This is not what D&M did.

Instead D&M collected the data and did the converse. On a chemical by chemical basis, across all the reporting facilities, D&M created two groups. They were "baseline" i.e., without tires and "with tires as a fuel supplement". As an example, one data set might be "CO emissions at all facilities, without tires" and the complement would be "CO emissions at all facilities, but with tires as a supplement". D&M compared the range and mean of the "with" and "without" case for each chemical, reached statistically insignificant conclusions but failed to report the lack of significance.

A partial critique follows. There are many, many other problems in D&M that are not enumerated below.

The Data is Scientifically Inadmissible. The data comes from diverse types of facilities burning diverse fuels but that is an observation, not an indictment. D&M table 4-1 is the only place in the report we can find information on the facilities. The table lists 27 unique facilities but 29 combinations of facilities and fuels so we will refer to it below as 29 facilities. Here are just a few facts that should cause one to seriously question the data from these facilities.

S Between 41% and 62% (12 to 18 of 29) of the facilities are not in California and consequently not subject to the Californiais tough pollution regulations and monitoring. The inclusion of "dirty" facilities hides the facts and trends by expanding the emission ranges. The 12 to 18 facilities are in New Jersey, Illinois, Michigan, Kansas, Idaho, Texas, Florida, Washington, Wisconsin and New York. (footnote#1)

S In 7% (2 of 29) of the facilities the primary fuel is "unknown".

S In a different 7% (2 of 29) of the facilities the primary fuel is listed as some form of tires ("Whole TDF" or "Chip TDF"). This is supposed to be a study comparing emissions and health risks with and without tires as a fuel supplement. What sense does it make to compare "the burning of tires" to "the burning of tires WITH TIRES". There will be no difference. Is this a typo in the table or an example of ignorance?

S 65% ( 19 of 29) of the facilities do not list enough information to calculate the percent of tires in the fuel mix.. This information is necessary to correlate the input (% of tires in fuel mix) to the output (change in emissions or health risk). D&M attempts a correlation without this necessary information.

S On the flip side, only 14% (4) of the facilities are in California
AND
appear to include enough information to calculate the percent of tires in the fuel mix.

S Consequently the other 86% of the facilities should be tossed out of the study or carefully scrutinized for appropriateness prior to inclusion. But currently that 86% is included in the study and represents a large source of misinformation.

S Even if one sees no reason to reject the non-California inputs, the 65% of facilities for which one canit calculate the percent of tires in the fuel mix should be excluded. So at a minimum, the data from two out of three facilities should be discarded.

S There is no reason to believe that the data is representative or unbiased. It is a voluntary submission from facilities with a self interest in lowering fuel costs by making the way smooth for tire burning in California. There is no guarantee that the most damaging information was submitted.

S The facilities are not reasonably identified. D&M table 4-1 "Facilities Responding to Information Request" doesnit include the city, county or state of the facilities.

S There is no link in the report between a given facility and its data in the bar charts. For example, there is no identification of facility "C01" or any other facility on D&M figure 4-4 "Difference of TDF versus Baseline for Carbon Monoxide". There is no facility identification on any figure showing emissions. It serves to make the results untraceable and unverifiable. The report is a dead end. One can not, from this report, answer the simple question "Did emissions increase on a facility by facility basis when TDF was used?" Is this muddying of the waters intentional or simply bad science?


The Method Used to Analyze the Data Is Bad Science

S D&M says that it normalized the emission data among the sources but there is no evidence of normalizing. D&M confuses the picture by comparing the same emission chemical across all facilities without normalizing. Here is what D&M did to build a data set for CO emissions across the 29 facilities:

It put all of the "per plant CO emission data without tires as a supplement" in one set and all of the "per plant CO emission data with tires as a supplement" in another set.

The facilities in D&M table 4-1 range in capacity by a factor of 30 to 1 (footnote #2) but all the data was combined un-normalized. This fact is borne out by the units shown for what is supposed to be normalized emissions. In all cases the units are lb/hour, that is, all of the emissions from each plant. They are not scaled to the size of the facility as would be indicated by emission units of (lb/hour) per Mbtu/hr. D&M takes the smoke stack emission from plant XYZ and a plant that is 30 times as large consuming 30 times the fuel and emitting more and just puts them in the same set. Then it calculates the mean and standard deviation and is surprised that the range of emissions across the facilities is 1,000:1 or 10,000:1.

S Dirty and/or large facilities, those with high per plant emission rates, swamp out the others. The mean and extremely large ranges are driven by the big emission numbers. This hides trends.

S The data is terribly sloppy and this is why the conclusions in D&M are not statistically significant or supportable and should be rejected.

S D&M misapplies statistical analysis. Here is an example from page 25.   "Mean NOx emission rates showed a decrease when using TDF with values of 243 lb/hr and 192 lb/hr for baseline and TDF test results, respectivelyOOO.." Consolidating the numbers in that quote and including range data from D&M Table 4-6 we get this table.


Without TDF With TDF
Compound Units Max Min Mean Standard Deviation Max Min
Mean Standard Deviation
NOx lb/hr 972 19.6 243 215 606 8.3 192 152


The above standard deviations are a huge fraction of their respective mean.
The standard score for the difference of these means is 1.04 (footnote#3), corresponding to a 70% confidence level. That means there is a 30% chance that the two means, NOx emissions with and without TDF, are from the same population. Translated, there is a 1 in 3 chance that there was no reduction in NOx and so the conclusion is statistically not significant. A rule of thumb is that a 99% confidence level is considered highly significant, a 95% confidence level is considered probably significant and a level less than 95% is not significant. The 70% confidence level mentioned above is thus clearly not significant. D&M reached a conclusion "Mean NOx emission rates showed a decrease when using TDFO" but after doing the calculations it failed to report that the difference was clearly not statistically significant. Sloppy data led to large ranges and large standard deviations while sloppy analysis led to conclusions without statistical significance. D&M is full of such lapses from sound scientific methodology.

S It is very important to properly understand this last point. It does not say the data shows no statistically significant difference between NOx emissions with and without tires as a fuel supplement, that there is no difference in the NOx emissions for the two cases and therefore it is safe to burn tires. It instead says that the data is so sloppy that using it we can not determine with any reasonable statistical significance whether the NOx emissions went up or whether they went down.

If these statistical terms, the mean and standard deviation, are confusing, think of the NOx data in terms of a collection of physical balls of differing weights. The "no tire" balls group has a mean weight of 243 lbs and a standard deviation of 215 lbs. That is equivalent to saying that we have 95% confidence the "no tire" balls weigh the mean + 2*standard deviations = 243 +430 lb or between -187 lb and 673 lb. Similarly the "tire" balls weigh 192 + 304 lb or between -112 and 496 lb. Immediately we see there is a huge overlap in weights between the two groups and it is very difficult to tell the two groups apart. Secondly we recognize that what we know about the ballsi weights is ridiculously imprecise and that is the reason for our confusion. This is exactly what the statistical values, the mean and standard deviation, tell us about the NOx and other emissions.
The data is so imprecise that we can not responsibly use it to distinguish the "no tires" and "tires" cases. We can not responsibly use it to judge whether the emissions went up, went down or didnit change when we added tires to the fire. The burden of proof is to show that adding tires to industrial fires does not increase the emissions or health risk. The data is simply not good enough to prove that adding tires to an industrial fire, like a cement kiln, is safe.

Response to the Four Results of D&M, p ES-3. D&M Result #1 "The analysis is based on air emission measurements at 28 facilities out of which cement kilns located in California comprised the largest data set." S Refer to critique of data above. A larger data set is facilities not in California.

D&M Result #2 "The change in health risk due to toxic air emissions from facilities using tires as a fuel supplement is not significantly different from the same facilities using typical fuels, such as coal." S This statement is the key justification for the California Integrated Waste Management Boardis (CIWMB) vigorous pursuit of tire burning, but as explained above it is not supported by the data.
S The D&M conclusions were developed by wrong headed analysis and lack statistical significance so they are meaningless. S A more accurate and succinct conclusion would have stated that the study was inconclusive because the TDF impact was less than the large uncertainties in the data sets collected.


D&M Result #3 "Greater variability in health risk occurs between different facilities, combustion practices, and air emission control systems [than the variability for a each pollutant across all facilities with and without tires as a fuel supplement]."
S This statement only goes to highlight the extremely sloppy data and the inappropriateness of using it in the first place.


D&M Result #4 "This comparison of health does not include the incremental health risk if the tires are landfilled or stockpiled. This incremental health risk would be associated with the use of typical fuels for landfill operation if the tires were landfilled or the risk of catastrophic fires if stockpiled."
S This observation has no numbers or probabilities to give it weight. The probability of a catastrophic fire is not addressed. The unspecified "incremental health risks" are alluded to without supporting data and there is no concept of the size of these hypothetical problems. Furthermore, the report doesnit acknowledge techniques such a baling which radically reduce water pooling, pest populations and the likelihood of a stockpile fire.
Conclusion Regarding D&M
S Due to its many severe faults the Dames & Moore report "Analysis of Emissions Test Results O" should be set aside as not credible.


---------------------------
1 The range in this percentage exists because D&M Table 4-1 does not identify the state where the facility is located. We investigated to identify the locale of each facility and were able to identify the state for all but six facilities.

2 This is based on the D&M Table 4-1 Heat Input field and the Production Rate field.

3 standard score of difference of means = difference in means / standard deviation of the difference of the means {this next footnote is damaged below here because it includes equiations that don't readily translate into text}
= where mean(X1) is the mean of sample set 1 having N1 elements and is the standard deviation of the set.
= (243 - 192) /
= 1.04 which corresponds to a 70% confidence level for a two-tailed test.

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