﻿                  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 Arch Wood Protection, Inc. ("Lonza")

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 Teri Muchow, Angela Ballisty, Michael Collins and Eric Lummus of Arch Wood Protection Inc. ("Lonza") on December 17, 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).  

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?

 Lonza offered to forward a list of their new product registrations since 2007.     

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

Generally, there are no new active ingredients being developed. It is very expensive to bring active ingredients to the market. Most pesticides are developed initially as agricultural pesticides. 

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

Lonza does not have any HAP control experience.  CCA applications do not need controls, because of the formulation. 

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

`Green' is not well defined here, so it's a difficult question to answer. 

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.

Lonza does not produce creosote products so we have no knowledge on this subject. 

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?

Lonza does not produce creosote products so we have no knowledge on this subject. 

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

There are no HAP in Lonza Fire Retardant products. 

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

The best reference here is the AWPA book of standards. It has a complete list of active wood preservation chemistries. 

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? 

Lonza does not produce pentachlorophenol products so we have no knowledge on this subject. 

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 market for CCA industrial products hasn't changed much since 2003. 

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?

There is not a quarternary shortage.  Quarternary is a disinfectant and it has been diverted to address Covid 19 issues. ACQ is used in similar markets as Copper Azole so, since there is an alternative, the market impact has been minimal. 

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

Borates have been registered as pesticides for a long time.  This is not a new development since 2007. 

Q5. Borates are generally expected to leach from wood upon exterior exposures. Lonza markets an exterior fire-retardant treatment. How does the exterior Lonza product differ from the product marketed into interior applications?

Wolman FRX is not manufactured by Lonza, we only market it.  We suggest you contact the manufacturer, Chemco. 


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.  

Our emulsion treated product has been on the market 30 years. 

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

Lonza is not familiar with any changes in this area.  

IV.  Wood Products

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

Lonza is not familiar with any changes in this area. The products have not changed.  

IV.  Green Certifiation

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

Our website lists all our certifications. The list of green certifications is constantly getting longer. Consumers don't generally distinguish between the features of the different certifications, however. Certifications don't seem to drive the marketplace. 


