USWAGTreated Wood Activities

Jim Roewer, USWAGAPPA Supply Management

Conference May 2, 2007

USWAG Overview

USWAG engages in regulatory advocacy pertaining to RCRA, TSCA, and HMTA USWAG’s Mission is to address the regulation of utility wastes, byproducts and materials in a manner that protects human health and the environment and is consistent with the business needs of its members Comprised of over 80 utilities, power producers, energy companies and utility trade associations

Treated WoodActivities & Goals

Working to preserve the continued availability of treated wood for industrial uses

Maintain the option of secondary use of poles & crossarms

Maintain the non-hazardous waste status of discarded treated wood

USWAG Treated Wood Guidelines

Developed in response to regulatory/policy pressuresDemonstrates industry commitment to treated wood product stewardshipConsistent with utility practicesSupports continued use of treated wood products

USWAG Treated Wood Guidelines

Purchasing Policies to Reflect Treatment StandardsEvaluate Alternatives to Treated WoodRe-Use Treated Wood Within Utility SystemProvide Notification to Secondary UseProperly Dispose of Treated Wood Explore Alternative Management Options Ensure Program AwarenessCoordinate With Other Industry Groups

Establish purchasing policies that reflect appropriate treatment standards

Companies should endeavor to have purchasing documents, specifications, or procedures requiring that new treated wood products meet AWPA standards or specific utility company requirementsAddresses bleeding, leaching concerns

Evaluate, where applicable, treated wood alternatives

Treated wood preferred productReliability & cost concerns paramountAlternatives may be used depending on specific concernsCompany-specific factors, customer needs, structural support requirements, and economic impacts affect decision

Assessment of Treated WoodandAlternate Materials for Utility Poles1010964Final Report, June 2004Prepared forElectric Power Research Institute3412 Hillview AvenuePalo Alto, California 94304EPRI Project ManagerM.E. McLearnTransmission and Distribution Soil and Water Issues

Utility Solid Waste Activities Group701 Pennsylvania Avenue, Fifth FloorWashington, D.C. 20004-2696USWAG Project ManagerJ.R. RoewerUSWAG Executive Director

Reuse treated wood products within the utility system

Life extension (e.g., groundline treatment of in-service poles)Reuse of poles to reduce the amount of treated wood removed from service and purchase of new treated wood products

Ensure that secondary users are informed with regard to the proper handling, use, and disposal of treated wood products

Secondary use applications conserve natural resources and landfill space Provide information to secondary users re appropriate handling, use, and ultimate disposal Ensure stewardship through treated wood life

Secondary Use Information May Include:

Caution: This wood has been treated with an EPA registered wood preservative and may contain chromated copper arsenate, pentachlorophenol, creosote, or other registered wood preservatives Wear a dust mask and goggles when cutting or sanding treated wood Wear gloves when working with treated wood Ask for the consumer safety information sheet or other safety information that may be available

Secondary Use Information May Include:

Do not use treated wood in circumstances where there may be direct contact with domestic animals or livestock which may crib (bite) or lick the wood Do not use treated wood in circumstances where the wood may become a component of food or animal feed, such as structures or containers for storing silage or food Ensure that the treated wood is properly disposed of after its intended use. Removal and disposal by ordinary trash collection is generally acceptable, though it may advisable to check with local officials regarding proper disposal options

Arrange for proper disposal of treated wood that is not reused

Treated wood destined for disposal rather than reuse is managed in accordance with Federal and State laws governing solid waste disposal

Continue to explore and utilize alternative management options

Secondary use (sale or donation to the public) critical optionSecondary use consistent with EPA’s preferred policy of resource conservation and reuseUSWAG will explore and expand alternative reuse/recycling and disposal options

Options for Disposal/Reuse

Sale/Donation for ReuseDimensional Lumber Paper ManufactureEnergy RecoveryIncincerationChipping/CompostingLandfilling

Options for Disposal/Reuse

Sale/Donation for Reuse Most Popular Option CIS/CSIS Information Transfer End Use concerns

Options for Disposal/Reuse

Dimensional Lumber Remanufacturing Issues End Use Concerns

Paper Manufacture Preservative Extraction Issues Non-commercial Scale

Options for Disposal/Reuse

Energy Recovery Air Permitting Issues Regulation & Management of Ash

Issues

Incineration Air Permitting Issues Regulation of Ash Costs >> Energy Recovery

Options for Disposal/Reuse

Chipping/Composting Not Common Practice Use as Daily Cover Leachability Issues

Landfilling Second Most Frequently Used Option Costs = f (Landfill Capacity)

Ensure program awareness

Establish system to ensure personnel are aware of and understand the guidelinesEnsure guidelines are understood and supported at all levels of the company.

Continue to coordinate with other industry groups

Telecommunications & railroad industriesEncourage adoption of treated wood management guidelinesEnsure the proper management of treated wood products by all groups

Treated Wood Guidelines

Submitted to EPA Under review by EPA OCG, OSW, OPPTDraft MOU between EPA & USWAG Referenced in GLBTS status reportFinalization?

USWAG Goals

Preserve Use OptionsContinued Disposal as Non-hazardous WasteMaintain Secondary Use Options

Questions?

jim.roewer@uswag.org202/508-5645

www.uswag.org