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


DATE:January 25, 2021 

SUBJECT:Documentation of Phone Conference with Dr. Kevin Archer, Viance Chemical

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

--------------------------------------------------------------------------------
TO:EPA-HQ-OAR-2021-0133
--------------------------------------------------------------------------------


The purpose of this memorandum is to discuss the phone conference between John Bradfield of the U.S. Environmental Protection Agency (EPA) with Dr. Kevin Archer of Viance Chemical Corp. on November 13, 2020 regarding preservatives manufactured 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).  

Wood Preservation Facilities. Would you review our two lists?  We have 270 facilities where we have confirmed, with public and company information, that they are applying wood preservative treatments or fire-retardant treatments. We have about 90 facilities where the public info indicates that they may be applying treatments, but we don't have company information confirming that data.

I.  New Preservative Technology

Q1. What new preservatives and/or active ingredients have been introduced into the wood preserving industry since 2007, including preservative treatments that may have been available, but are now more common? What products are they used on? What are the relative costs for new/old preservatives?

[In 1992 Alkaline Copper Quaternary (ACQ) was standardized with the American Wood Protection Association (AWPA) and different formulations of Copper Azoles (CA) were standardized in 1995, 2002 and 2009. With the switch away from Chromium Copper Arsenate (CCA) in 2003 after EPA and industry agreed to cancel the registration for residential consumer products, ACQ and CA, became the primary commercial replacements.  CCA continued to be sold for industrial uses. So ACQ and CA dominated the waterborne treatment products up until about 2007. In 2008 DCOIT (4,5-Dichloro-2-N-Octyl-4-Isothiazolin-3-One) combined with Imidacloprid was standardized by Viance's predecessor, CSI. AWPA typically refers to this product as DCOI or EL2. Viance (CSI) then began marketing DCOI as an above ground treatment.  Micronized Copper Azole (MCA), a particulate version of CA, came into the market place around 2007, initially standardized by the ICC-ES for building code approval and then in 2016 MCA was also standardized by AWPA. Viance does not sell Micronized Copper Azole (MCA). MCA and EL2 (DCOI) now dominate the Southern Yellow Pine based home center market in the eastern United States. For example, Home Depot primarily sells MCA for above ground and in ground residential uses while Lowe's sells EL2 (DCOI) based treated wood products for above ground uses and MCA for ground contact applications.  84 Lumber based in PA sells EL2 (DCOI) for above ground uses and CA for ground contact applications.  ACQ is still used to treat western U.S. wood species, which are more difficult to pressure treat than Southern Pine and ACQ works better. Additionally, ACQ is darker green than MCA and DCOI, which is considered by some to be an aesthetic disadvantage. ACQ is also at a cost disadvantage to MCA and DCOI, since it requires higher retention rates to be effective.  In 2018, Viance registered an oil based DCOI for ground contact treatment and is marketing it for use in utility poles and cross arms.  It is competitive and as effective as Pentachlorophenol, Creosote and CCA when used for poles. Copper Naphthenate (CN), which Viance does not sell, is an older treatment that can also be used in utility poles.  CN has a strong odor which can be a problem in some markets, so it is more commonly used in railroad cross ties, where odor is not a consumer issue.  

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

[Not really. Because of the costs associated with registration historically wood preservative suppliers have developed products by reformulating existing agricultural pesticide treatment chemicals.  Thus, primary pesticide research is undertaken by the agricultural industry. Regarding recently developed products, Viance is heavily committed to DCOI for above ground and ground contact products and are not proposing any new chemical treatments for the immediate future.  The approval systems for wood preservative products do not encourage rapid product change. Building codes, working with AWPA, require 5 years of test data. Even with the agriculture industry as a resource, wood preservers have had to be very selective. Wood preservative chemical formulations need to be very robust because they are reused and subject to shear during the wood treatment process. In contrast agricultural pesticides because they tend to be spray applied are typically only used once so they are easier to formulate. Consequently, the reservoir of active ingredients is relatively small.] 

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

[Viance does not produce or market add-on controls. Viance does manufacture products, DCOI, CA, Borates and ACQ, which do not contain hazardous air pollutants.] 

Q4. Are there any "greener" alternatives to creosote?  What are the technical issues for railroad ties/switches and/or utility poles? DCOI is Viance's product. Does DCOI have  future in cross ties?. Does DCOI compete with Copper Napthenate?

[DCOI oil borne ingredient product (UP-23) is Viance's product for utility poles that is a greener alternative to creosote. We see a future for our DCOI in cross ties, too. We believe our product competes with both Creosote and Copper Naphthenate.] 

Q5. (May not be relevant) 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.

[We agree that this question is not directly relevant to Viance, except as a part of the competitive products issue, discussed above. The efficacy issue is the biggest roadblock to our ability to crack new markets. You have to prove your product works with treated railroad ties, where other treatments have been around since the end of the 19th century.  Again, we are not selling DCOI into RR ties today, but we expect to.] 

Q6. (May not be relevant) 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?

[We agree that this question is not directly relevant to Viance and we are not in the add-on controls business.] 

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

[Viance sells its borate products into the interior framing market, e.g., windows, sill plates, etc. It is a waterborne product. We are not aware of any concerns about the chemicals, DOT (Disodium octaborate tetrahydrate) is relatively safe.  DOT is an effective termiticide as well as a fire retardant, as long as there is no soil contact. DOT leaches out with exterior soil contact, due to its water solubility and diffusion.] 

Q8. What products does Viance produce that can meet which AWPA standards? (AWPA U1, UC3B, UC4A, UC4B, UC4C, 5A, 5B, 5C

[Viance sells products that can be used to meet these standards. All our products are AWPA standardized except for the Clearwood MW2 product, which is approved for WMDA's Millwork standards. 

The only product we sell (on behalf of our parent Venator) that is standardized for Salt-Water immersion use in UC5 is CCA. Creosote is an alternative to CCA in that application. The reason for that is the intense leaching environment and the saltwater organisms. Class 5 is a relatively small percentage of the market. Reinforced Concrete and Metal are the main competitors; wood has a better Energy/LCA story than the competitive products, though.] 


Q9. What can you tell us about Viance's corporate history?

[The corporate history of Viance was that the original company, known as Chemical Specialties, Inc., became CSI and was owned by Laporte. Laporte sold to Rockwood Specialties in 2000.  Rockwood Specialties, then formed a joint venture with Rohm and Haas in 2007. The new JV was called Viance LLC. Rohm and Haas sold to Dow, then Rockwood Specialties sold to Huntsman, then Huntsman spun off Venator, which retained the CSI holdings. Then Dow sold to DuPont. So now Viance is a JV owned by Venator and DuPont.] 

II.  Old Preservative Technology

Q1. (May not be relevant) 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?

[We agree that this question is not directly relevant to Viance, except as a part of the competitive products issue, discussed above, because of Penta's use in poles and ties.] 

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, but not all  -  why not?

[Viance does not produce CCA and only has marketing agreements for CCA sales into industrial markets, primarily poles. Our DCOI, CA and ACQ products are all successful products in the consumer markets formerly dominated by CCA.  CCA is a proven effective wood preservative treatment so it has maintained its competitive position in industrial and agricultural markets.] 

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?

[The primary reason CA and MCA products have displaced ACQ is competitive, as noted above. ACQ requires higher retention rates.  Douglas Fir and other western species are easier to treat with ACQ, but Southern Yellow Pine products have a much larger market share of the treated wood market.] 

Q4. Viance sells but does not produce CCA.  The products being marketed under the Viance `Supatimber CCA" brand appear to be focused on severe applications for Treated Wood. Which markets typically buy this product. Does Viance produce a non-CCA product that could substitute for any of these CCA products?  Which products produced to which standards?

[Again, the CCA market is industrial - agriculture fenceposts, Railroad Bridges, utility poles, marine pilings and permanent wood foundations. But our DCOI oil products are sold for bridge timbers, cross arms and utility poles and could be used elsewhere; we plan to market the product to the railroad tie industry. 


III.  Preservative Treatment/Process

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

[KDAT is not common because of kiln capacities. One reason is that treatment capacity far outstrips kiln capacity. Facilities with some kiln capacity are the ones marketing a small portion of their products as KDAT. On the other hand, Viance's mill work treatment is always KDAT. The secondary emulsion treatment added to CCA treated poles because the CCA treatment can make poles more difficult to climb. It is my understanding that Lonza and Koppers market a two-step CCA/oil emulsion treated product that they call Wolman ET or Durapine CCA respectively. CCA has a reactive chemistry and can react with oils, therefore CCA-ET is typically done in a 2-step process. First, the wood is treated with CCA, the retort is drained, and then the emulsion is added.] 

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

[Viance is not aware of any notable technology changes. Viance supplies replacement parts for treatment vessels but does not fabricate treatment equipment in house.  Viance's engineering team can design new plants but relies on independent contractors for fabrication of those plants.  Those suppliers may have products that improve efficiency such as transfer decks for moving treated wood in and out of the cylinder but pressure treatment equipment has not changed dramatically in a long time.] 

IV.  Wood Products

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

[The industry is now selling Zinc Borate to OSB to give it termite resistance.  Viance does not have a ZB product that they sell to OSB, however Viance had an ammoniacal copper product they sold, which imparted water resistance, termite resistance and dimensional stability, it was sold as a specialty product into Hawaii.  However, that market was not pursued after 2002. Because the composite panel producers that we were working with switched their focus away from value added specialty products to commodity products. Acetylated (chemically modified) wood based on treatment with acetic anhydride was standardized by AWPA in 2011.
Some companies are developing heat treated wood (heating in an oxygen free atmosphere in a kiln or oven) to protect it from microbial degradation. 



