EPA Proposal Classifies Wood Fuel from Construction, Demolition

[Bio­mass indus­try push­ing for even less reg­u­la­tion of their dirt­i­est fuel source. ‑Ed.]

- by Erin Voegele, March 27, 2014. Source: Bio­mass Magazine

On March 27, the U.S. EPA released a pro­posed rule to amend its Non-Haz­ardous Sec­ondary Mate­ri­als reg­u­la­tion under the Resource Con­ser­va­tion and Recov­ery Act. The NHSM rule was final­ized in Feb­ru­ary 2013 and estab­lish­es stan­dards and pro­ce­dures for iden­ti­fy­ing whether non-haz­ardous sec­ondary mate­ri­als are sol­id wastes when used as fuels or ingre­di­ents in com­bus­tion units.

Infor­ma­tion pub­lished by the EPA explains that if a mate­r­i­al is clas­si­fied as sol­id waste under RRA, a com­bus­tion unit burn­ing it must meet Clean Air Act sec­tion 129 emis­sion stan­dards for sol­id waste incin­er­a­tion units. Alter­na­tive­ly, if the mate­r­i­al is not con­sid­ered a sol­id waste, com­bus­tion units that burn it are required to meet the CAA sec­tion 112 emis­sion stan­dards for com­mer­cial, indus­tri­al and insti­tu­tion­al boilers.

The NHSM rule, final­ized on Feb. 7, 2013, estab­lished par­tic­u­lar non-haz­ardous sec­ondary mate­ri­als as cat­e­gor­i­cal non-waste fuels, pro­vid­ed cer­tain con­di­tions are met. Accord­ing to the EPA, enti­ties burn­ing such mate­ri­als do not need to eval­u­ate them under the gen­er­al case-by-case stan­dards and pro­ce­dures that would oth­er­wise apply to non-haz­ardous sec­ondary mate­ri­als used in com­bus­tion units.

With the new amend­ment, the EPA is propos­ing to add three new mate­ri­als to this list. The first new cat­e­go­ry is con­struc­tion and demo­li­tion wood processed from con­struc­tion and demo­li­tion debris accord­ing to best man­age­ment prac­tices. The sec­ond includes cer­tain paper recy­cling resid­u­als and the third is cre­osote-treat­ed rail­road ties that are processed and com­bust­ed in unites designed to burn both bio­mass and fuel oil.

Bio­mass Pow­er Asso­ci­a­tion Pres­i­dent Bob Cleaves released a state­ment not­ing that the draft rule cor­rect­ly clas­si­fies wood waste mate­ri­als as fuel when used for ener­gy, there­by pro­vid­ing reg­u­la­to­ry cer­tain­ty for its use by bio­mass pow­er facilities.

“As the pro­posed rule points out, mil­lions of tons of wood pre­vi­ous­ly used for oth­er pur­pos­es are dis­card­ed every year. For decades, this type of wood has been used by the bio­mass indus­try to sup­ple­ment oth­er wood waste like tops and limbs of trees, forestry residue, and thin­nings. EPA’s draft rule makes clear that using these fuels should be encour­aged. EPA’s pol­i­cy is a com­mon sense approach to bio­mass ener­gy by pro­mot­ing sus­tain­able ener­gy recov­ery prac­tices while avoid­ing green­house gas emis­sions through land­fill­ing,” Cleaves said. “We con­tin­ue to study the rule and its impli­ca­tions, but we are opti­mistic that this sig­ni­fies an impor­tant step for the EPA in pro­mot­ing the use of wood and wood byprod­ucts for energy.”

A pub­lic com­ment peri­od will open once the pro­pos­al is pub­lished in the Fed­er­al Reg­is­ter. Addi­tion­al infor­ma­tion, includ­ing a copy of the pro­posed rule, is avail­able on the EPA web­site.