  

Meeting Summary - EPA and AF&PA Participants on Wednesday May 28, 2008

Discussion of Forest Products Industry Fuels vs. Solid Waste 

Participants

 

(In person)

Paul Cassidy, EPA

Richard Kinch, EPA

Matt Hale (10 minutes only), EPA 

Tim Hunt, AF&PA

Rob Kaufmann, Georgia Pacific

Amy Schaffer AF&PA

Rich Wasserstorm, AF&PA

Victor Dallons, Weyerhaeuser

(On Phone)

Steve Woock, Weyerhaeuser

Marceia Cox, International Paper

John Pinkerton, National Council for Air & Stream Improvements

Ginny Holton, Packaging Corporation

AF&PA provided oral and written positions; their written material is
presented below.

During the course of the 3 hour meeting, AF&PA made the following oral
statements.

---   AF&PA mills get the majority of their secondary materials from a
closed loop process; materials at the mills don’t leave the production
process.   Some mills do however get some secondary materials from other
mills, e.g., tire derived fuel and sawdust.     

---   AF&PA discussed their materials that are used as fuels: 
Wastewater treatment residues, biomass, processed biomass, OCC rejects,
turpentine, biogases, rectified methanol, Reinjection char, tall oil,
and other miscellaneous biomass materials.  

---   AF&PA largely doesn't consider contaminants to be an appropriate
issue for what is not a solid waste.  “Contamination does not always
equal waste, as long as it is on-site and recycled.”  For example,
when we discussed CCA lumber, they expressed the points that the
material does have significant fuel value and their devices are
permitted to limit air emissions.  Railroad ties are another example of
a material that can be effectively burned in a well controlled unit.  Of
particular importance to AF&PA are materials generated by the facility
which have not been discarded -- they believe such material is simply
not a waste and does not need to be assessed for legitimacy as a fuel.

---    We discussed the concept of adequate fuel value.  AF&PA opposes
the 5,000 BTU/lb limit associated with the comparable fuels rule, and
similar to CIBO's position, AF&PA advocates something like "net positive
BTU value".  AF&PA discussed the potential for net positive heating
value as something that was easier to obtain given the new combustion
technologies.  There was also a discussion of BTUs/dry lb versus "as
fired" values.  Heating values, depending on the type of material and
whether you are talking dry vs.as fired ranged from 3,000 BTUs/lb to
12,000BTUs/lb.  AF&PA indicated some of their combustion devices are
specifically designed to handle wet materials.  EPA expressed interest
in getting further information on the BTU content of their fuels, the
nature of the materials, whether they were previously discarded, and the
extent of processing that occurred prior to use.

---   The industry is looking to utilize materials outside their
facility as fuels.  AF&PA has obtained permits from Oregon, Washington,
and Maine to use construction debris and/or urban wood as a fuel
material.  This also includes materials from disasters, and even mining
landfills for wood waste.  With regard to the latter, AF&PA indicated
the situation they are aware of involved segregation of "clean" wood to
the “greatest extent practicable” from treated wood and painted
wood.  They indicated however that even with such efforts it is still
possible that someone could find a piece of treated wood or a piece with
some paint on it within the clean wood to be burned-- this was followed
up with a discussion about the need for some kind of recognition that de
minimus levels of contaminated materials should not render the material
a solid waste.

---   The industry does use tire derived fuel, which involves processing
tires to create small chunks of rubber without the metal.

---   AF&PA uses off-spec used oil, and takes the position that such
material is not a solid waste.  Also as part of general operational
practices, oil may be spilled and saw dust used as an absorbent -- the
material then going to combustion as a fuel, likewise oily rags may be
used as a fuel – AF&PA does not view these as solid wastes.

AF&PA raise some questions that EPA needs to further think about.

From our prior discussions my understanding is that off-spec used oil is
a solid waste.  Is that the case, and is there any flexibility there? 
With regard to oily rags generated within the facility or spilled oil
that they pick up with saw dust -- because it has never left the
facility, do the used oil provisions apply?

Conceptually, AF&PA sees material that is generated within the facility
as being exempt from any questioning regarding legitimacy.  I assume
that runs counter to EPA basic construct for hazardous waste, and needs
to be a consideration for non-hazardous wastes.

There was mention of burning plastics that cover wire.  These can be
polyvinylidene fluoride, a thermoplastic fluoropolymer.  Like PVC the
fluoropolymers can have close to 60% halogens -- in this case fluoride. 
If we decide PVC is a solid waste, we probably also need to include the
fluoropolymers.  Buried here is the issue that if the 112 and 129
standards don't regulated fluoride does that have any bearing on whether
the material is a waste - maybe this just leaves OAR in an awkward
position with the fluoropolymers being a solid waste, and possibly the
129 rules not addressing fluoride (the prior boiler and CISWI standards
regulated HCl and dioxins/furans, but there were no fluoride standards
-- the earlier chloride standards were different between 112 and 129 and
because the limits are structured differently it is difficult to make
any comparisons between the two -- but again, there was nothing for
fluoride.)

Glues are a significant issue for AF&PA.  For the panel manufacturers,
there are cut-off and other residuals that contain glues.  Are there
specific types of glues that are of concern?  (Greg Helms)  Is the issue
urea formaldehyde, phenol resorcinol formaldehyde or isocyanate glues? 
In the curing/drying process, are we really left with contaminants of
significant concern during combustion?

