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


DATE:January 19, 2021 

SUBJECT:Documentation of Phone Conferences with Western Wood Preservers Institute

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 conferences between John Bradfield of the U.S. Environmental Protection Agency (EPA) with Butch Bernhardt of Western Wood Preservers Institute (WWPI) on December 28, 2020 and January 8, 2021 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).  

WWPI provided the following information regarding current wood preservation treatments for utility poles and crossarms as well as industry trade groups for pole manufacturers.  Also provided was information on recent changes and anticipated changes in treatments as a result of the Stockholm Convention listing decision for pentachlorophenol. 
 
Utility Poles/Crossarms
The Osmose Utility Services Map shows the percentage, by treatment type, of the installed poles, not the current percentages of treatment.
Though once the dominant utility pole treatment, Creosote is now rarely used outside of Texas.
80-90% of current Southern Pine Poles and crossarms are treated with CCA, the remainder with Pentachlorophenol or creosote.
90-95% of current Western Species Poles (mainly Douglas Fir and Western Red Cedar) and crossarms are treated with Pentachlorophenol, the remainder with Copper Naphthenate.
CCA is not an effective treatment for western wood species.
When Pentachlorophenol supply is exhausted, the anticipated replacements are Copper Naphthenate and DCOI.
One utility pole manufacturer, William Meredith, has already switched to DCOI.
Pentachlorophenol is shipped as a liquid concentrate to the south, but as a solid bar to the west.
Once the manufacture of Pentachlorophenol ends, as anticipated, there is likely to be a stockpile of 2-5 years of treatment chemicals
There are approximately 150 million installed utility poles and their average age is approximately 45 years. 
The largest percentage of installation dates in the current poll inventory dates back to the 1950's and 1960's. 
Poles can be used until they lose 30% of their carrying capacity, which can be measured/estimated. 
Without follow up treatment, according to the Osmose Utility Services map, the average pole `reject age' varies from 44 to 55 years of service, depending on geography and climate.
There are several in-service pole treatments, applied at the ground level, where most fungal/insect attacks occur, that can extend pole lifetimes by 10-15 years.
There is recently a dual treatment for utility poles, where the pole is first treated with a borate, followed by Pentachlorophenol, CCA or Copper Naphthenate. The dual treatment is expected to extend pole lifetimes by 20%. Though borates are water soluble, the upright nature of poles causes the borate treatment to leach downward to the ground level, where it is most needed and effective. The dual treatment reduces checking, which can open up treated wood to pest attacks.
Other Notes
Currently Nisus is the only supplier of Copper Naphthenate, but Koppers announced in early 2020 that it would begin production of that treatment.
Steel, composite plastic and concrete ties and poles do not compare favorably to wood when subjected to Life-cycle analyses.
Pentachlorophenol is listed as an industrial chemical to be eliminated under the Stockholm Convention.  It is already banned in Europe. Canada, Mexico and the U.S. are all signatories to the convention, but a country-by-country `opt-in' is required to remove a chemical from production and use.
Mexico has opted-in to the Pentachlorophenol provisions.  Since the only North American production facility of Pentachlorophenol is in Mexico, production will end there in 2021.
Canada's Pesticide Management Regulatory Authority, part of Environment Canada, is currently reviewing an opt-in plan and is expected to opt-in.
The U.S. has not opted-in to the convention but has proposed to remove pentachlorophenol's pesticide registration.
The North American Wood Pole Council is a federation of three wood preserver trade groups  -  the Western Wood Preservers Institute, the Southern Pressure Treaters Association and the Wood Preservation Canada.
 

