﻿                  UNITED STATES ENVIRONMENTAL PROTECTION AGENCY
           SECTOR POLICIES AND PROGRAMS DIVISION
           OFFICE OF AIR QUALITY PLANNING AND STANDARDS
           OFFICE OF AIR AND RADIATION


DATE:January 7, 2021 

SUBJECT:Documentation of Phone Conference with [Koppers, Inc.]

FROM:John Bradfield (EPA/OAR/OAQPS/SPPD/NRG)

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TO:EPA-HQ-OAR-2021-0133
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The purpose of this memorandum is to discuss the phone conference between John Bradfield of the U.S. Environmental Protection Agency (EPA) with [Heath Huschak and Leigh Ann Richardson] of [Koppers, Inc.] on December 22, 2020] regarding manufactured preservatives for use in the wood preserving process. This information will be used in the technology review for the National Emission Standards for Hazardous Air Pollutants for Wood Preserving Area Sources (Subpart QQQQQQ).  

Other reason for a written response is that we wanted broad input from within.
I.  New Preservative Technology

Q1. What new preservatives and/or active ingredients have been introduced into the wood preserving industry since 2007? What products are they used on? What are the relative costs for new/old preservatives?

      Koppers has introduced Creosote Petroleum Solution in 2007-2008. More details on this product is addressed in response to questions Q5 and Q6 below.  
      
      Koppers has not developed any new pesticide active ingredients since 2007.  We have added several registrations for active ingredients through the utilization of the EPA FIFRA data cite-all method.  

Q2. Are there new preservatives and/or active ingredients currently being evaluated/registered under FIFRA/AWPA? If yes, what types?

None known

Q3. Is it easier/cheaper to control HAP emissions from wood preservatives through P2 (material/ingredient substitution) or add-on controls?

      Every wood preservative active ingredient and end use product requires EPA registration under FIFRA.  In order to ensure pesticide formulations are effective for the end use application of the treated wood article, years of research and testing is required to satisfy AWPA standardization and EPA regulatory requirements.  Pesticide active ingredients are typically not modified or changed due to these processes.  The research period to prove efficacy of the treated wood article against biological decay is a minimum of 7-10 years before a pesticide active ingredient can be commercialized.  
      
      For these reasons, HAP content of a pesticide formulation used at wood preservation facilities is often not apt for substitution. 

Q4. Are there any "greener" alternatives to creosote?  What are the technical issues for treating railroad ties/switches and/or utility poles?

      The AWPA standardized treatments for railroad ties and switch ties have not significantly changed for decades.  There are both oil-type and waterborne options for treating wood for railroad uses.  The concept of "greener" alternatives is subjective and cannot be easily defined due to sourcing and production of raw materials and various use applications.  I refer you to Life Cycle Assessment of Creosote-Treated Wooden Railroad Crossties in the US with Comparisons to Concrete and Plastic Composite Railroad Crossties published in 2013 in the Journal of Transportation Technologies.  This can be obtained free of charge by accessing Rail Tie Association website at: Creosote LCA.
      
      As compared to railroad uses, there are even more preservative options for treating utility poles.  The same "greener" issues also apply to these treatments. The most common treatment for utility poles is currently pentachlorophenol, followed by CCA. Copper Naphthenate and creosote are also used, but at much lower volumes.
      
      Each preservation type is bound by the treated article end use application.  Every preservative system has attributes that make it more, or less favorable for a condition of use.  Technical issues relating to treating wood vary both with the tree species and preservative system.   Although some formulations may contain less HAP-relevant components, this does not necessary equate to them being "greener" when other sustainability measures are considered.

Q5. How are companies reducing HAP emissions from creosote?  We noted permits with specific naphthalene content (mass fraction, by weight) limits for incoming materials and total facility emission limits for naphthalene, POM, biphenyl, dibenzofuran, and quinoline.

      The regulatory environment for creosote treating plants is largely dependent upon the state agency permitting programs.  Some of the emphasis on specific limits are based on the control of odors.  Koppers has employed several measures to control odors.  Here are some of these examples:
      
Condensation and collection of entrained aerosols from work tank roof vents through installation of individual or combined vent header devices;
Post treatment ventilation to aid in cooling of treated wood charges and capture post-vacuum emissions within the cylinder prior to opening the door and removing the charge trams from the cylinders.
Scrubber systems 
      
      The condensation and post treatment ventilation systems are present at every plant that manufactures treated wood with creosote, CCA and pentachlorophenol. The post treatment purge captures a volume equal to 2 treatment cylinders of air. Scrubbers are used at several Koppers plants and the plants of competitors.  There is not a lot of consistency in the scrubbing systems, though. Some scrub with water, some with oil or diesel fuel, some scrub air only from the treatment tanks, some scrub air only from the vacuum system. 
      
      Lastly, a significant change that has positively impacted the creosote treating plants is the adoption of Creosote Petroleum Solution treatments for the majority of railroad uses.  The addition of 15-20% petroleum fuel oil, on average, has lowered the overall HAP content of the treating solution as compared to full coal tar creosote treating solutions.   The HAP content of the petroleum fuel oil is very low so, consequently, the dilution brings about an equivalent HAP reduction.
      
      Some permitting bodies have attempted to limit the amount of individual HAP components in the FIFRA registered pesticide product that may be used at a treating facility.  We continue to engage with these agencies to ensure requirements and approvals granted under FIFRA are respected.  
      
      Specifically, to the question about naphthalene, we have historically served a limited number of internal and external treating customers that operate with naphthalene limits in their permits in the 10% range (% of treating solution). We believe Koppers produces some of the lowest naphthalene-containing creosote serving the US market.  Our creosote treating solutions, on average, are in the 3-8% range, which at times is more than 50% lower than other US creosote suppliers.  Our capability is based on continued investment in world class coal tar distillation facilities including the recent completion of a new Naphthalene Distillation unit in Stickney, Illinois.  This unit became fully operational in 2019 with a capital cost in excess of $100 million.   
      
      Prior to 2019, Koppers had operated four U.S. creosote production facilities and now it only operates one, the Stickney plant. That plant also produces naphthalene. Koppers also has plants in Denmark and Australia.
      
      Naphthalene is monitored in every batch for two reasons.  We want to maximize the naphthalene recovery and transfer the recovered product to the Stickney naphthalene plant.  Also, as noted above, some treaters have a specification limiting the amount of naphthalene in the creosote they purchase, so they require that information from their suppliers.
      
         
Q6. We also noted some facilities using add-on controls (e.g., condenser/ scrubber systems) to reduce HAP/VOC emissions from creosote operations.  Are there new (since 2007) creosote mixtures or solutions being used today?  What was the motivation  -  odor issues?

      See response to Q5.  The primary motivation for the use of Creosote Petroleum Solution treatments by our railroad customers was based on a combination of updated efficacy data for the formulation and creosote shortages experienced in the early 2000's.  The supply of crude coke oven tar has contracted in North America due to the closure of coke ovens.  As a result, the available creosote supply has declined in direct proportion to that raw material loss.  There are no alternative raw material sources. Creosote must be produced from coke ovens processing bituminous coal. Though no new coke ovens are being built, none are expected to close soon. Currently, though, at least one coke oven is on `hot idle' and not producing coke. One of the incentives to develop a creosote product which uses petroleum as an extender was the historical reduction in the number of coke plants. When the railroads accepted the efficacy of creosote extended with petroleum, it became one of the standard creosote products.  

Q7. Are there any HAP issues/concerns with fire retardants?  Most seem to be borates and contain no HAP.

      Koppers markets two flame retardant systems for use at our customer treating plants.  FlamePRO(R) is an ammonium phosphate-based product and FirePRO(R) is a borate-based product.  These formulations do not contain HAPs.  More information may be obtained by accessing the links here:
FlamePRO(R)
FirePRO(R)

Q8. What Koppers products can meet which AWPA standards? (AWPA U1, UC3B, UC4A, UC4B, UC4C, UC5A, UC5B, UC5C)U1, UC3BU1, UC3BU1, UC3B

      See Table 1 at end of document

II.  Old Preservative Technology

Q1. Pentachlorophenol (PCP or Penta) is still used for some utility poles and other outdoor/commercial applications. It typically has some associated HAP (dioxin) emissions from impurities  -  permits show some facilities have switched, but not all  -  is the industry waiting to see if another manufacturer steps in?  Are impurity levels better today than pre-2007?

      All KUIP penta plants will convert away from penta in 2021. The first conversion will start in second quarter of 2021 and complete others by 2022. We do not see any other manufacturer stepping up to produce penta once KMG exits the market in December 2021. 
      
      We do not have any data to show that levels of impurities are any better today than in 2007. 
      
      More information may be obtained in our public release at www.koppers.com.
      
Q2. CCA was discontinued for residential/household use in 2003 but is still used for outdoor/commercial applications. It was typically replaced with ACQ or CA (which contain no HAP)  -  permits show several facilities have switched from CCA to other products, but not all  -  why not?
      
      The voluntary withdrawal of CCA residential uses did not impact those treaters that serve utility and agricultural markets.  CCA continues to be one of most effective wood preservative systems in existence and is essential for the utility pole, marine piling and agriculture sectors.   

Q3. Some permit application changes mentioned industry concerns about a possible "quat" shortage and switching from ACQ to CA products.  Was that a real issue/concern?

      More recently, "quat" shortages are related to disinfectant and sanitizer production in response to COVID-19. 

Q4. How long have borate products been marketed as insecticides?

      Inorganic Boron containing products have been standardized for at least 25 years by AWPA under heading P25 Standard for Inorganic Boron (SBX).  

Q5. Borates are generally expected to leach from wood upon exterior exposures. Koppers markets a Borate pre-treatment for exterior creosote products. How does the exterior Koppers product differ from the product marketed into interior applications?

      Koppers railroad treating facilities perform treatment with borate and creosote utilizing a single cylinder, dual process.  We have developed a concise video that illustrates our treating process: Koppers Dual Tie Treatment Animation.  The creosote sap wood treatment acts as a hydroscopic barrier between the aqueous borate solution phase that has penetrated the heart wood.  Lastly, it should be noted that acceptable uses of creosote treated wood are only for external applications. 

III.  Preservative Treatment/Process

Q1. Are there new processes involving pre-, dual-, or post-application?  We noted things like a secondary emulsion treatment and KDAT.  

      None known

Q2. Are there any anticipated changes in treatments, applications, treatment processes or any notable process changes that have occurred since 2007?

      None known


IV.  Wood Products

Q1. Are there new (since 2007) wood products being pressure- or heat-treated with preservatives that we need to consider? 

      None known

IV.  Green Certification

Q1. What green certifications do Koppers and Koppers customers participate in and what is their green criteria? 

      Environmentally Preferable Products (EPP). Issued by SCS Global Services
      https://www.scsglobalservices.com/services/environmentally-preferable-product
      
      Koppers product technologies evaluated by SCS Global Services:
            MicroPro(R) (Micronized Copper Azole or MCA treatment)
            FlamePRO(R) (non-pesticidal, ammonium phosphate-based product)
      
      SCS Global Services is an internationally recognized third-party certifier of environmental claims in the green building, food, energy, and consumer product sectors. SCS certification signals that the EPP claim is backed by rigorous scientific review. EPP are widely recognized as having lower environmental impacts than typical products in the same category. SCS Global Services uses the most advanced life-cycle assessment (LCA) metrics to confirm that products meet this standard.
      
      Koppers MicroPro(R) technology is the first and only treated wood process to be EPP certified by Scientific Certification Systems based on a LCA.
      
      Koppers FlamePRO(R) Fire Retardant Treated Wood products meet all the necessary requirements to be certified Indoor Advantage(TM) Gold.
      
      Home Innovation NGBS Green Certified
      https://www.homeinnovation.com/
      
      Koppers product technologies certified by NGBS:
            MicroPro(R) (MCA)
            NatureWood(R) (Copper Azole)
            Advance Guard(R) (Borate)
            Hi-bor(R) (Borate, same as Advance Guard, but marketed in Hawaii)
      These products have been independently verified as eligible products for use in achieving points toward project certification under ICC-700 National Green Building Standard. Third-party verified certification program ensures homes and apartments are built in compliance with the National Green Building Standard. 
      The certification focuses on three primary attributes:
            Healthy Homes
            Lower Operating Costs
            Sustainable Lifestyle
      
      UL GREENGUARD
      https://spot.ul.com/greenguard/
      
      Koppers product technologies certified under Greenguard and Greenguard Gold evaluation criteria:
            MicroPro(R) (MCA)
            FlamePRO(R) (non-pesticidal, ammonium phosphate-based product)
            Advance Guard(R) (Borate)
            Hi-bor (Borate, same as Advance Guard, but marketed in Hawaii)
      
      GREENGUARD Certification is an internationally recognized product emissions certification labeling program for manufacturers of low-emitting indoor products, furnishings, and materials. Products can be certified under two certification programs.
            GREENGUARD - Gives assurance that products designed for use in indoor spaces meet strict chemical emissions limits, which contribute to the creation of healthier interiors.
            GREENGUARD Gold - Offers stricter certification criteria, considers safety factors to account for sensitive individuals (such as children and the elderly), and ensures that a product is acceptable for use in environments such as schools and healthcare facilities. Emission limits meet and exceed CDPH Standard Method and meet stringent standards for low volatile organic compound (VOC) emissions.
      
      Global GreenTag
      https://www.globalgreentag.com/
      
      Koppers product technologies certified under Global GreenTag evaluation criteria:
            MicroPro(R) (MCA)
      
      Global GreenTag is an internationally recognized ecolabel. Every product is fitness tested and certified under one of two leading certification programs using trusted scientific methods, GreenRate Level A Certification, and Global Green Tag Health Rate Gold Product Health Declaration. The Global GreenTag Product Health Declaration has been designed to provide an additional level of service to the green product sector in facilitating an easier industry understanding of both the health hazard and risk (if any) associated with any certified product/s. Every Global GreenTag PhD is independently peer reviewed by an external consultant toxicologist and member of the Australian College of Toxicology & Risk Assessment for Ingredient Hazard Assessment, Whole of Life Risk Assessment, and In Use Health (including VOCs).

Table 1. Koppers Preservative Systems and AWPA Use Category



      CA-B:  Copper Azole Type B (not a Koppers product)
      CA-C:  Copper Azole Type C
      MCA:  Micronized Copper Azole
      SBX:  Inorganic Boron
      CCA:Chromium Copper Arsenate
      CR:  P1 Creosote
      CR-S:  P2 Creosote
      CR-PS: 50/50 P1 creosote/petroleum




