Generation, Use, Disposal, and Management Options for CCA-Treated

May 1998

Helena Solo-Gabriele, Principal Investigator Jennifer Penha Vandin Catilu University of Miami

Timothy Townsend, Co-Principal Investigator Thabet Tolaymat University of Florida

State University System of Florida FLORIDA CENTER FOR SOLID AND HAZARDOUS WASTE MANAGEMENT 2207 NW 13 Street, Suite D Gainesville, FL 32609

Report #98-1 TABLE OF CONTENTS

TABLE OF CONTENTS i LIST OF FIGURES ii LIST OF TABLES ii LIST OF ABBREVIATIONS AND ACRONYMS iv UNITS OF MEASURE iv ABSTRACT v

CHAPTER I I.1 Motivation 2 I.2 Background 2 I.3 Objectives 8 CHAPTER II, INVENTORY OF CCA-TREATED WOOD IN FLORIDA II.1 Characteristics of the Florida Wood Treatment Industry in 1996 10 II.2 Generation and Disposal of Cca-treated Wood 14 II.3 Disposal Reservoirs for Cca-treated Wood Waste 20 CHAPTER III, MANAGEMENT OPTIONS III.1 Waste Minimization 34 III.2 Reuse 38 III.3 Recycling 39 III.4 Energy Recovery and Wood as Fuel 41 III.5 Disposal 41 CHAPTER IV IV.1 Changes in Wood Treatment Industry and Implications to Wood Disposal 45 Sector IV.2 Recommendations 46 IV.3 Conclusions 48 IV.4 Acknowledgments 49

REFERENCES 50 APPENDIX A: WOOD TREATERS AND WOOD TREATER QUESTIONNAIRE A-1 APPENDIX B: STATISTICS FOR THE WOOD TREATMENT INDUSTRY B-1 APPENDIX C: QUESTIONNAIRE FOR FACILITIES THAT USE WOOD AS A C-1 SOURCE OF FUEL AND LIST OF FACILITIES SENT QUESTIONNAIRE

i LIST OF FIGURES

Figure I-1 Distribution of Treatment Chemicals in 1970 and 1996 4 Figure I-2 Volume of Treated Wood Products 5 Figure I-3 Number of Treatment Plants per State and Wood Deterioration 5 Zones Figure II-1 Location of Wood Treatment Plants Surveyed 11 Figure II-2 Mass-Balance for CCA-treated Wood 14 Figure II-3 Quantity of Wood Product Treated with Waterborne 17 Preservatives, Florida Figure II-4 Projected Disposal Quantities for CCA-Treated Wood, Florida 19 Figure II-5 Sample Preparation Process 22 Figure II-6 Predicted (Measured)Wood Concentration Versus Actual 24 Concentration Figure II-7 Stoichiometric Comparison of Copper and Chromium for CCA 28 Type A, B, and C and Comparison with Experimental Data

LIST OF TABLES Table I-1 Composition of CCA-Type A,B, and C 3 Table I-2 Retention Requirements for CCA-Treated Wood 3 Table I-3 Metal Concentration (mg/kg) in CCA-Treated Wood and Other 7 Wood Types: Average Values and Ranges. Number of experimental values per data point range from 2 to 3 for CCA- treated wood and 5 to 48 for other wood types Table I-4 TCLP Values for CCA-Treated Wood and Other Wood Types: 7 Average Values and Ranges. Number of experimental values per data point range from 1 to 2 for CCA-treated wood and 4 to 6 for other wood types Table I-5 Elemental Metal Concentrations (mg/kg) for wood mixtures 7 which are sorted and not sorted at wood processing facilities Table II-1 Quantity of CCA-Treated Wood Sold Within Florida in 1996 13 Table II-2 Comparison of the Results of the Questionnaire with 15 Extrapolation Methods for 1996. Table II-3 Disposal of CCA-Treated Wood in Florida and US (Estimated). 18

ii LIST OF TABLES(Con’d)

Table II-4 Sampling Sites and General Facility Descriptions 21

Table II-5 FCCA (%) in Wood Waste 29 Table II-6 Response to Questionnaire. 30 Table II-7 Fuel Composition for Facilities that Burn Wood Mixtures 31 Table II-8 Metals Concentrations in Wood Fuel 31 Table II-9 Quantities of Wood Burned at Facilities Accepting Wood Waste 32 and Estimated Quantities of CCA-Treated Wood (1996) Table III-1 Summary of Management Options for CCA-Treated Wood 43 Waste Table A-1 Wood Treatment Plants Located in Florida A-2 to A-3 Table A-2 Wood Treatment Plants Located Within 150 miles of Florida A-4 (Alabama Plants) Table A-3 Wood Treatment Plants Located Within 150 miles of Florida A-5 (Georgia Plants) Table A-4 Wood Treatment Plants Located Within 150 miles of Florida A-6 (Mississippi Plants) Table B-1 Number of Plants, N, and Void Volumes of Treating B-2 Equipment, V Table B-2 Production of CCA-Treated Wood and Quantity of Chemical B-3 Utilized Table B-3 Production of Wood Treated With Waterborne Preservatives B-4 and Quantity of Chemical Utilized. Table B-4 Production of Wood Treated With Waterborne Preservatives, B-5 by Product Type,U.S. Statistics Table C-1 List of Facilities Sent a Questionnaire Inquiring About Wood C-6 to C-7 Burning Practices

iii LIST OF ABBREVIATIONS AND ACRONYMS

ACA Ammoniacal Copper Arsenate ACC Acid Copper Chromate ACQ Alkaline Copper Quat ACZA Ammoniacal Copper Zinc Arsenate As Arsenic AWPA American Wood Preservers Association AWPI American Wood Preservers’ Institute CCA Chromated Copper Arsenate C&D Construction and Demolition Cr Chromium Cu Copper CZC Chromated Zinc Chloride DEP Department of Environmental Protection EPA Environmental Protection Agency FAC Florida Administrative Code MSW Municipal Solid Waste RCRA Resource Conservation and Recovery Act TCLP Toxicity Characteristics Leaching Procedure

UNITS OF MEASURE ft3 cubic feet lb/ft3 pounds per cubic foot lbs. pounds mg/kg milligrams per kilogram mg/L milligrams per liter

iv ABSTRACT

High metals concentrations found in CCA-treated wood has prompted Florida regulators to re-examine policy for the recycling and disposal of wood waste. Upon re-examination, it was first recognized that limited information was available concerning disposal practices for CCA-treated wood waste. The objectives of this research are to fill the information gap by developing an inventory for CCA-treated wood in Florida and by identifying current and alternative practices for its disposal. The inventory developed through this research includes a description of the wood treatment industry in Florida during 1996, the quantities of wood product generated and disposed, and the identification of primary disposal reservoirs for the waste. Management alternatives focused on waste minimization, re-use, recycling, and ultimate disposal of CCA-treated wood. Results indicate that a significant amount of CCA-treated wood is entering the construction and demolition (C&D) waste stream. A significant amount of wood within this waste stream is recycled as boiler fuel. In the process CCA is inadvertently burned for energy recovery purposes. If current practices are continued, metals concentrations in wood ash will increase due to accumulations of the CCA chemical. The increase will likely reach levels which will characterize the ash as hazardous. A hazardous designation will increase costs for ash disposal and will make burning wood for energy recovery purposes cost prohibitive. In order to avert this situation, efforts should focus on identifying alternative management options for CCA-treated wood waste. In the absence of good alternative structural materials and chemical preservatives, "disposal- end" management will be the primary means for controlling the ultimate fate of the wood waste. Reuse of CCA-treated wood should be promoted through waste exchange programs. The most promising recycling alternative appears to be cement-based composite materials. Disposal-end management should also focus on improved sorting practices at C&D recycling facilities and proper practices for disposing CCA-treated wood. Our second year research which investigates sorting and ash treatment technologies represents one step in attaining this goal.

v CHAPTER I MOTIVATION, BACKGROUND, AND OBJECTIVES

1 I.1 MOTIVATION

Data (Atkins and Fehrs, 1992; McGinnis, 1995; Fehrs, 1995) suggest that elevated metal concentrations in wood and wood ash are associated with a metal-based preservative referred to as CCA. Laboratory analysis of CCA-treated wood indicates that ash samples are considered hazardous due to exceeded toxicity levels for chromium and arsenic as specified in the Resources Conservation and Recovery Act (Gaba and Stever, 1995). Especially notable is that toxicity criteria are exceeded for the wood ash even when CCA-treated wood represents a small fraction of the total wood fuel. Given that CCA-treated wood can deem an ash hazardous when present at low levels, statutes that regulate the disposal of combustor ash and exemptions provided to some wood burning facilities (FAC, 62-702) are being re-reviewed. The exemptions release facilities from submitting ash management plans. It is not clear whether facilities with exemptions burn CCA-treated wood nor is it clear how the wood ash is disposed. Given these uncertainties, research is needed to determine disposal practices for CCA-treated wood in Florida.

I.2 BACKGROUND

I.2.a Wood Treatment Chemicals and Treatment Process

The process involves impregnating the wood with chemicals that protect the wood from biological deterioration and to delay combustion due to fire. The most common process includes pressure-treatment in which the chemical is carried into the wood by a carrier fluid under pressurized conditions. Treatment chemicals utilized during the wood preserving process are separated into four major categories (AWPI, 1994). These categories include: waterborne preservatives including CCA, oilborne preservative including pentachlorophenol, , and fire-retardants. The purpose of the first three chemicals is to prolong the useful life of wood products by protecting them against insect and fungal attack. Wood exposed to the outdoor atmosphere and in direct contact with soil and water are more prone to decay and therefore usually require treatment. The fourth preservative, fire-retardants, delay the combustion process when wood is subjected to fire. Fire-retardants represent the smallest fraction of the wood treatment market. Formulations for fire retardants include ammonium salts, borates, phosphates, bromides, and antimony oxides. Creosote is a heavy black-brown liquid produced by condensing vapors from heated carbon-rich sources, such as coal or wood. The resultant preservative is sometimes mixed with tar oils and petroleum oils. Oilborne preservatives utilize oil to carry the treatment chemical into wood. Oilborne preservatives include copper naphthenate, zinc naphthenate, and pentachlorophenol. The most common of these is pentachlorophenol which is a crystalline aromatic compound. Both pentachlorophenol and creosote impart a dark color to the wood, have an odor, and result in an oily surface which is difficult to paint. Wood treated with either chemical is flammable and contact with skin may cause irritation. Most common uses for creosote treated wood include railroad and bridge ties. Pentachlorophenol is used to treat utility poles and crossarms (Milton, 1995). Neither pentachlorophenol- nor creosote-treated wood should be used inside residences.

2 Waterborne preservatives utilize water as the carrier fluid during the treating process. The water is evaporated from the wood shortly after treatment leaving behind the treatment chemicals. The most common waterborne chemicals are metal oxides. These chemicals include chromated copper arsenate (CCA), acid copper chromate (ACC), ammoniacal copper arsenate (ACA), chromated zinc chloride (CZC), and ammoniacal copper zinc arsenate (ACZA). The most common of these waterborne preservatives is CCA which represents over 90% of the U.S. waterborne preservative market (AWPI, 1996). CCA is composed of the oxides or salts of chromium, copper, and arsenic. The copper in the wood serves as the fungicide whereas the arsenic protects the wood against insects. The chromium fixes the copper and arsenic to the wood. CCA can be separated into Type "A", "B", or "C" depending upon the relative proportions of metals (table I-1). The relative proportions range from 35-65%, 16-45%, 18-20% for chromium, arsenic, and copper, respectively. The amount of CCA utilized to treat the wood or retention level depends upon the particular application for the wood product (table I-2). Low retention values (0.25 lb/ft3) are permissible for plywood, , and timbers if the wood is used for above ground applications. Higher retention values are required for load bearing wood components such as pilings, structural poles, and columns. The highest retention levels (0.8 and 2.5 lb/ft3) are required for wood components which are used for foundations or saltwater applications. The primary advantages in the use of CCA-treated wood are that it produces no odor or vapor and its surface can be easily painted. At low retention values it does not change the general appearance of the wood, maintaining the aesthetic quality of natural wood. The wood is suitable for use indoors and is generally used for interior parts of a wood structure in contact with the floor. Drawbacks of the wood are a strong green color at high retention values. It should not be used in applications where it is in contact with food or drinking water. CCA is used to treat primarily lumber, timbers, posts, and plywood. Its use in treating other products, such as poles and pilings, has seen relative increases as well.

CCA-Type A CCA-Type B CCA-Type C

Chromium as CrO3 65.5% 35.3% 47.5% Copper as CuO 18.1% 19.6% 18.5%

Arsenic as As2O5 16.4% 45.1% 34.0% Table I-1: Composition of CCA-Type A,B, and C (AWPA, 1996)

Application Retention Value (lb/ft3) Above ground: lumber, timbers, and plywood 0.25 Ground/Freshwater contact: lumber, timbers, plywood 0.40 Salt water splash, wood foundations: lumber, timbers, and plywood 0.60 Structural poles Foundation/Freshwater: pilings and columns 0.80 Salt water immersion: pilings and columns 2.50 Table I-2: Retention Requirements for CCA-Treated Wood (AWPA, 1996)

3 I.2.b Market Trends in Wood Treatment Industry

Creosote is the oldest of the preservatives with a history dating back to the pre-1900s. Pentachlorophenol and CCA are relatively new with commercial use beginning in the 1940s and 1970s, respectively. The production of treated wood products with creosote and pentachlorophenol increased at moderate rates between the 1960s and 1980s and has declined in recent years. The use of CCA, on the other hand, has increased at a very rapid rate since its inception and today it is present in over 70% of the total treated wood product sold. In 1996, waterborne preservatives, creosote, oilborne preservatives, and fire-retardants represented 79%, 14%, 6%, and 0.6% of the market, respectively (figure I-1) whereas 26 years earlier, in 1970, the relative distribution was 16%, 51%, 26%, and 7%, respectively. The total volume of treated wood products has significantly increased at well. In 1970, the total volume of treated wood products was 248 million cubic feet of which 39 million cubic feet were treated with CCA. By 1996, this figure increased to 591 million cubic feet for all products and 467 million cubic feet for CCA-treated products (figure I-2). Assuming that the service life for treated wood products is approximately 25 years1, industry statistics indicate that the total quantity of treated wood disposed will increase in the near future and that the characteristics of the waste stream will also change. Today in 1998, the disposal sector will observe that a larger quantity of creosote- and pentachlorophenol- treated wood waste is disposed than wood treated with waterborne preservatives. Given trends in production, increases in the disposal of wood treated with waterborne preservatives, and especially CCA, are anticipated.

1970 1996

Fire Retardants Fire Retardants Creosote 7.2% 0.6% 14.6% 15.8% 5.7% Waterborne Creosote Preservatives, CCA Oilborne Preservatives 50.6% (Pentachlorophenol)

26.4% Oilborne Preservatives 79.1% Waterborne Preservatives, (Pentachlorophenol) CCA Volume of Treated Wood Products Volume of Treated Wood Products 248 million cubic feet 591 million cubic feet

Figure I-1: Distribution of Treatment Chemicals in 1970 and 1996.

1Average service life of 25 years corresponds to lumber and timbers which represent the bulk of the CCA market. It is recognized that other products, such as utility poles, have a longer service life.

4 All Products 600

500 CCA

400

300 All Products

200

Volume, million cubic feet 100 CCA 0 1970 1996 Year Figure I-2: Volume of Treated Wood Products

I.2.c Significance of Wood Treatment Industry in Florida

Wood within the southeastern region has a greater potential for deterioration because the climate is very conducive for the proliferation of insects and fungi (figure I-3). Florida, because of its long coastline, has an additional demand for treated wood products for marine applications. Such a demand is reflected by the distribution of treatment plants throughout the U.S. Of the 491 treatment plants nationally, 25 are located in Florida and an additional 100 are located along Florida's northern border, within Georgia, Alabama, and Mississippi. These four states alone house 25% of the treatment plants nationwide. Treated wood products will ultimately require disposal. A management plan for treated wood waste is needed for Florida due to a significant wood treatment industry within and near its borders.

A B NH 1 D WA MT ND MN VT 0 1 13 2 9 ME SD WI OR ID 1 WY 3 11 MI NY MA 10 5 IA 2 11 6 3 NE 2 IL IN OH PA 19 NV UT 2 RI 1 CO KS 9 7 11 WV CT CA 1 2 MO NJ 5 0 9 1 11 9 KY 8 VA 20 2 NM OK AR TN 7 NC 28 AZ 3 1 17 MS AL SC 17 MD 2 GA TX 21 39 6 LA 40 D 28 15 AK FL 0 C 25 E

HI Wood Deterioration Potential 5 A = Low D = High B = Moderate E = Severe C = Intermediate

Figure I-3: Number of Treatment Plants per State and Wood Deterioration Zones. (Data from AWPI, 1995 and AWPA Standards, 1996)

5 I.2.d Background Metals Concentrations in Treated Wood

Background metal concentrations were obtained from several experimental studies (Atkins and Fehrs, 1992; Fehrs, 1995; McGinnis, 1995) in order to determine the differences between CCA- treated wood and other wood types. These data were arranged into several categories including burned and unburned wood, homogenous wood and wood mixtures, and elemental analysis versus toxicity characteristics leaching procedure (TCLP). For comparative purposes the tables include federal regulatory criteria for: a) TCLP limits and, b) for land application of sewage sludge. If a waste fails the TCLP test it is considered hazardous unless it has been provided a regulatory exemption2. The TCLP protocol involves subjecting a waste sample to an acidic solution to extract contaminants. The waste fails the TCLP test if the extract exceeds a preset concentration. These concentrations are provided in the second column of table I-4. Regulatory limits for the land application of sewage sludge have been utilized in some cases to regulate the land application of other wastes. Two sets of limits are established for elemental metal concentrations. "Ceiling concentrations" represent maximum values for land application whereas land applied wastes which meet the stricter "pollution concentrations" are subject to less regulatory oversight. Both ceiling and pollution concentrations are included in tables I-3 and tables I-5 for comparative purposes. One should also note that Florida maintains a stricter set of soil clean-up goals. These goals have been considered as guidelines for regulating land application of wastes in Florida. These guidelines provide elemental concentrations for residential and industrial land uses. Florida's guidelines are also included in tables I-3 and I-5 for comparative purposes. Data indicate that untreated wood and wood treated with resins and other chemicals such as creosote and pentachlorophenol have significantly lower concentrations of arsenic, chromium, and copper than CCA-treated wood (table I-3). This is the case if either unburned or ash samples are considered. Arsenic standards appear the most critical in limiting potential uses of CCA-treated wood and other wood types. CCA-treated wood, whether unburned or ashed, exceeds federal criteria for land application, whereas ash from "other wood" types is near federal limits. Only unburned wood in the "other than CCA-treated wood" category meet federal limits. All wood and ash categories listed in table I-3 exceed Florida's clean-up goals for arsenic. TCLP analysis indicates that "other" wood types (either unburned or ash) will meet regulatory limits (table I-4). Unburned samples of CCA-treated wood contain TCLP levels which are close to the federal regulatory limits for arsenic, whereas ash samples of CCA-treated wood considerably exceed these limits for arsenic. For mixtures of different wood types, sorting does appear to lower the concentration of arsenic, chromium, and copper (table I-5). For the data presented in table I-5, samples in the sorted category meet federal regulations, whereas unsorted wood is close to the federal limit for arsenic. Wood in both categories exceed Florida's clean-up goal for arsenic.

2 Please note that an exemption has been provided to arsenically treated wood products. Refer to 40 CFR Section 261.4 (B9).

6 Metal Regulatory Limits Unburned Ash Federal1 Florida2 Other Wood CCA Treated Other Wood CCA Treated Ceiling Pollution Industrial Residential (mg/kg), Cow (mg/kg), CCCA (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) (mg/kg) Arsenic 75 41 3.7 0.8 2.0 1200 67 33000 (0.26-7.2) (290-2050) (7.5 - 79.7) (8980 - 45000) Chromium Not Not 430 290 7.0 2100 51 16000 Applicable Applicable (0.3 - 21) (1740 - 2360) (13 - 143) (1780 - 22500) Copper 4300 1500 140,000 105 3.7 1100 120 22000 (1.1 - 3) (1040 - 1070) (43.5 - 164) (2720 - 31500) 1 Federal Register 40 CFR Part 503.13, Standards for the Use or Disposal of Sewage Sludge, Subpart B, Land Application 2 Florida Department of Environmental Protection Table I-3: Metal Concentration (mg/kg) in CCA-Treated Wood and Other Wood Types: Average Values and Ranges. Number of experimental values per data point range from 2 to 3 for CCA-treated wood and 5 to 48 for other wood types.

Metal Regulatory Unburned Ash Limits1 (mg/L) Other Wood CCA Treated Other Wood CCA Treated (mg/L) (mg/L) (mg/L) (mg/L) Arsenic 5 0.11 8 0.20 180 (0.07-0.38) Chromium 5 0.01 2.3 1.8 0.2 (0.4-4.1) (BDa-3.4) Copper Not -- --- 0.29 0.06 Applicable (0.04 - 0.76) 1 Federal Register 40 CFR Part 261.24, Identification and Listing of Hazardous Waste, Toxicity Characteristic a BD = Below Detection Table I-4: TCLP Values for CCA-Treated Wood and Other Wood Types: Average Values and Ranges. Number of experimental values per data point range from 1 to 2 for CCA- treated wood and 4 to 6 for other wood types.

Metal Regulatory Limits Elemental Analysis for Unburned Wood Federal1 Florida2 Mixtures (mg/kg) Ceiling Pollution Industrial Residential No Sorting Some Sorting (mg/kg) (mg/kg) (mg/kg) (mg/kg) Arsenic 75 41 3.7 0.8 74 7.5 (4.8-10.2) Chromium Not Not 430 290 240 14 Applicable Applicable (12- 17) Copper 4300 1500 140,000 105 352 19 (16-37) 1 Federal Register 40 CFR Part 503.13, Standards for the Use or Disposal of Sewage Sludge, Subpart B, Land Application 2 Florida Department of Environmental Protection Table I-5: Elemental Metal Concentrations (mg/kg) for wood mixtures which are sorted and not sorted at wood processing facilities.

7 I.3 OBJECTIVES

The goals of this project were to estimate the magnitude of CCA-treated wood disposed in Florida and to determine the ultimate fate of the wood upon disposal. Furthermore, research was needed to identify available management options for the discarded wood. These options are intended to assist regulators in developing cost-effective policies that will minimize environmental impacts associated with the disposal of CCA-treated wood. These goals were accomplished through the following two objectives. Our first objective was to develop an inventory for CCA- treated wood within Florida. The inventory includes a description of the wood treatment industry within Florida, the quantities of treated wood products generated over time, and a projection of disposal quantities into the future, as well as an evaluation of current disposal reservoirs for the wood waste. The second objective was to compile a list of available management options. Management options for CCA-treated wood waste focused on waste minimization, re-use, recycling, and disposal alternatives.

8 CHAPTER II INVENTORY OF CCA-TREATED WOOD IN FLORIDA

9 CHAPTER II, INVENTORY OF CCA-TREATED WOOD IN FLORIDA

The inventory described in the following pages is separated into the following three topics: a) characteristics of the treatment industry during 1996, b) generation and disposal of CCA-treated wood, and c) current disposal reservoirs for discarded CCA-treated wood. Each topic is separated into two parts: a methods and a results section.

II.1 CHARACTERISTICS OF THE FLORIDA WOOD TREATMENT INDUSTRY DURING 1996 II.1.a Methods Characteristics of the wood treatment industry were determined by compiling the results of a questionnaire sent to wood treatment plants within the State of Florida and within 150 miles of its borders. The 150 miles was chosen to represent a reasonable maximum distance for the transport of treated wood products to end use markets. The task included compiling a list of treaters and developing a questionnaire designed to determine the quantities and general characteristics of CCA-treated wood products sold within the State. The list of wood treatment plants was compiled from four different sources. These sources included the American Wood Preservers' Institute (AWPI) statistical reports of 1995 and 1996, a database inquiry through the Southern Forest Products Association (SFPA) (Leslie Moran, personal communication, 1997), a database inquiry through the U.S. Environmental Protection Agency's Toxic Release Inventory, and Random Length's "Big Book" which is a buyer's and seller's directory for the forest products industry. Each of the wood treating companies were called to verify addresses and to confirm their status of operation. The names and locations of active wood treaters is given in figure II-1. Addresses and contact numbers are provided within appendix A. The questionnaire inquired about the treatment process utilized by each plant, the quantity of wood treated, the characteristics of the treating process, and the type of products generated. A draft of the questionnaire was reviewed by Dr. George Parris of AWPI, who agreed to support the research efforts by serving as a contact person for companies who had inquiries about the questionnaire. The initial mailings were followed by a second mailing and telephone calls. A copy of the cover letter and questionnaire sent to wood treating plants is included within appendix A. The amount of CCA-treated wood generated was estimated by adding: 1) the reported quantities for the responding plants and, 2) an estimate of the quantities produced by the non- responding plants. Statistics of the non-responding plants were estimated from void volume ratios. The void volume is the cylindrical volume of pressure treating equipment available at wood treating plants that utilized CCA. Void volumes for plants using other treatment chemicals, in addition to CCA were determined by dividing the plant's total void volume by the number of different chemicals used. Void volumes for non-responding plants were obtained from the AWPI statistical report of 1995. Our computation for the quantity of wood produced by non-responding plants, QNR, is given by the following expression. V Q ' NR × Q NR R equation(II-1) VR

3 where: QR = the quantity of CCA-treated wood in ft produced by reporting plants; V NR = void volume of non-reporting plants; and VR = void volume of reporting plants.

10

II.1.b Results A total of 27 treatment plants are located within Florida. Another 46 are located within 150 miles of its northern border. Nineteen of the 46 are located in southern Georgia, 18 are located in southern Alabama, and 9 are located in southeastern Mississippi. The 150 mile boundary for Florida imports is supported by the results of the questionnaire. For the responding plants, only those located within 90 miles of its borders had wood products exported into Florida. None of the responding plants outside of 90 miles had products imported into Florida.

Florida For the 27 treatment plants located in Florida, 17 responded to the questionnaire. Twelve of the 17 sold 50% or greater of its total plant production in Florida. Two of the respondents have considerable overseas markets. One of the two sells CCA-treated products exclusively overseas. The other sells 70 to 75% of its products overseas. The amount of chemical utilized in 1996 by individual plants ranged from 27,000 to 1,800,000 pounds. The total waterborne treated product sold within Florida by individual companies ranged from 97,000 to 5,000,000 ft3 for 1996. Fourteen of the 17 respondents listed the type of preservative utilized. Eleven of these utilize CCA Type C, two utilize CCA Type A, and one does not utilize waterborne preservatives. Retention values utilized by the reporting plants varied from 0.25 lb/ft3 to 2.5 lb/ft3. Forty-eight percent of the wood product is treated with a 0.25 lb/ft3 retention value, 17% with a 0.6 lb/ft3 retention value, and 17% with a 2.5 lb/ft3 retention value. Retention values of 0.4 and 0.8 lb/ft 3 were the least common. The most common products produced by the treating plants are lumber and timber. Other products include poles, pilings, posts, plywood, agricultural stakes, and guardrail posts. By far the most common type of wood utilized is Southern Yellow . However, treatment of other types of wood including Honduran and Brazilian Pine was also noted.

Georgia Eleven of the 19 plants located in southern Georgia responded to the questionnaire. Five of the 11 respondents export a fraction (from 9 to 50%) of their product to Florida. Five of the remaining six do not export products to Florida and one company was not able to quantify the amount of its product imported to Florida. The type of treatment chemical utilized by the responding plants is exclusively CCA Type C. The retention value utilized most frequently by these plants was 0.4 lb/ft3. The total CCA-treated product sold in Florida by individual plants ranged from 100,000 ft3 to 1,800,000 ft3 for 1996. The product sold by individual plants corresponded to 55,000 to 825,000 pounds of chemical. The most common wood product sold by the responding plants was lumber and timber. Southern Yellow Pine is used exclusively by the responding plants.

Alabama Nine of the 18 plants located in southern Alabama responded to the questionnaire. Only three of the responding plants export treated wood product to Florida. The amount exported ranges between 1 to 5.3% of the product produced by an individual company. Six of the 18 companies do not export to Florida and in three cases their Florida plant does all the treating. The treatment chemical utilized was exclusively CCA Type C. The retention value utilized most frequently was 0.25 lb/ft3. The total waterborne treated product sold in Florida by individual plants ranged from 22,000 ft3 to 111,000 ft3 for 1996. The wood product sold by individual companies within

12 Florida corresponded to 500 to 28,000 pounds of the CCA chemical. The most common wood products sold by Alabama's companies in Florida are lumber, timber, plywood, and landscape timber. Southern Yellow Pine was the major species treated. Other species treated to a lesser extent included Douglas fir and Radiata.

Mississippi Of the 8 treatment plants located in southeastern Mississippi, five responded. None of these plants sell their products in Florida.

II.1.c Summary A total of 28.3 million cubic feet of CCA-treated wood was sold within Florida during 1996. This quantity corresponds to approximately 12.6 million pounds of the chemical. Of this amount approximately 6.0, 2.3, and 4.3 million pounds are in the forms of chromium oxide, copper oxide, and arsenic oxide, respectively. Of the total quantity of CCA-treated wood sold in Florida, roughly 17.5 million cubic feet are produced within the State, whereas 10.8 million cubic feet are produced outside. Responding plants located in Florida reported a total of 8.2 million cubic feet. A value of 9.3 million cubic feet is estimated from equation II-1 for non-responding plants in Florida. Responding plants in Georgia and Alabama reported a total of 4.2 million cubic feet of product sold within Florida. A value of 6.6 million cubic feet is estimated from equation II-1 for non-responding plants located outside Florida.

Quantity of CCA-Treated Wood Sold in Florida CCA Chemical Utilized (106 ft3) (106 lbs)

Amount Produced Amount Produced Total CrO3 CuO As2O5 Total in Florida in Al. & Ga. 17.5 10.8 28.3 6.0 2.3 4.3 12.6 Table II-1: Quantity of CCA-Treated Wood Sold Within Florida in 1996

13 II.2 GENERATION AND DISPOSAL OF CCA-TREATED WOOD

The purpose of this task was to forecast disposal quantities into the future. This projection is based upon an a mass balance approach given estimates for the quantities of CCA- treated wood generated over time and assumptions concerning the service-life for treated wood.

II.2.a Methods

The mass balance approach used to forecast disposal quantities is illustrated in figure II-2 and is represented by the following equation: dB ' A&C equation(II-2) dt where: B = mass of CCA-treated wood in use at any time t; dB/dt = Rate of change of B with respect to time (mass/time); A = mass of CCA-treated wood generated per unit time; and C = mass of CCA-treated wood disposed per unit time. Efforts focused on quantifying, each term in equation II-2.

Generation Use Disposal A B C

Figure II-2: Mass-Balance for CCA-treated Wood

Measures of "A" were computed from industry statistical reports. Industry statistics were gathered from the American Wood Preservers' Association (AWPA) for 1964 to 1993 with the exception of 1982, 1989, and 1992 for which no reports were available. The statistics for 1994 to 1996 were obtained from the American Wood Preservers Institute (AWPI). Each report, with the exception of 1990 to 1994 and 1996, provided a list of active treatment plants along with their location and size of pressure treating equipment. Furthermore, data were available on either a regional or national basis concerning the amount of chemical utilized and the quantity and types of wood products treated with the chemical. For any given year, statistics for Florida were extrapolated from regional or national statistics using the relative number of plants (method 1) or relative void volume of pressure treating equipment (method 2) corresponding to that year. For example, the amount of the CCA chemical utilized in Florida, QCCA,FL, was computed from

14 regional statistics and the relative number of plants as: N ' FL equation(II-3) QCCA,FL QCCA,SE × NSE

and from void volumes as: V ' FL QCCA,FL QCCA,SE × equation(II-4) VSE

where: QCCA,SE = the amount of CCA chemical utilized in the southeastern region, lbs; NFL= number of treatment plants located in Florida; NSE = number of treatment plants located within the southeastern region; VFL = void volume of treatment plants located in Florida; VSE = void volume of treatment plants located in the southeastern region. A yearly tabulation of N and V for Florida, the southeastern region, and the U.S. are given in table B-1 of appendix B. Our extrapolation procedure was checked with the results of the wood treater questionnaire (table II-2). As given in this table, the void volumes published by the AWPI for 1995 were within 5% of the void volumes determined from our questionnaire. The small differences between the results are due to two additional treatment plants which were identified through the current study. The extrapolation procedures (methods 1 and 2) appear to over-estimate the quantity of wood product and under-estimate the amount of chemical utilized, when compared to the results of our questionnaire. When comparing the void volume estimate (method 2) with the results of the questionnaire, method 2 over-estimates the quantity of wood product by 10% and the amount of chemical utilized is under-estimated by 30%. These differences are significant and should be considered when interpreting the results of our disposal forecast. Basically, given the assumptions involved accuracies greater than 50% should not be expected through our forecast. The values quoted should be considered "order-of-magnitude" estimates.

Computation Method Number of Plants Void Volume Quantity of CCA- CCA Chemical ( ft3) treated Wood Utilized Produced in FL, (106 lbs.) (106 ft3) Method 1: No. of Plants 25 36 9.7 Published by AWPI in 1995 Method 2: Void Volumes 57,300 31 8.3 Published by AWPI in 1995 Method 3: Questionnaire 27 60,500 28 12.6 Table II-2: Comparison of the Results of the Questionnaire with Extrapolation Methods for 1996

Statistics were also compiled for the types of wood products treated with CCA. The general characteristics of CCA-treated wood products is necessary in tracking the waste through the disposal stream. For example, these results can be used to determine whether sorting at disposal

15 facilities should focus on lumber and timbers or utility poles. Estimates for the quantity of CCA-treated wood in use, "B", is based upon an average service life for wood products and an assumed waste fraction when the wood is first used. Computations are performed for the amount of wood product disposed (ft3) and the quantity of CCA chemical (pounds) associated with this wood. When treated wood is first used, an immediate waste stream is produced in the form of construction off-cuts. Our computations assume that approximately 2.5% of the annual production is generated as off-cut waste (Cooper, 1993). For purposes of estimating chemical quantities, our computations assume that no chemical is lost from construction off-cuts. The service life of wood products is dependent upon product type. Lumber, timbers, and fence posts used in residential applications, for example, generally have short service lives, on the order of 20 to 30 years (Cooper, 1993). Although the structural integrity of these products does not warrant disposal in many instances these products are often discarded for aesthetic reasons due to the effects of weathering. Other products such as utility poles and crossties, on the other hand, generally have longer service lives. Florida Power and Light the largest electric utility company in Florida, for example, estimates an average service life of 41 years for their CCA- treated utility poles (Keith Drescher, personal communication, 1998). Stake tests conducted by the Forest Products Laboratory (Gutzmer and Crawford, 1995) suggest that the service life of CCA-treated wood products may be even greater than 40 years, especially for products treated with high retention levels. Given these differences in average service lives, our assumptions for computation purposes were as follows. First it was assumed that the average service life of poles and crossties is 40 years. We assume that 25% of these products are in use for 35 to 37 years, 50% of the products are in use for 38 to 42 years, and the remaining 25% are in use for 43 to 45 years. For lumber, timbers, fence posts, and other products, the assumed average service life is 25 years. For computation purposes, it is assumed that 25% of these products last 20 to 22 years, 50% last 23 to 27 years, and the remaining 25% last 28 to 30 years. The production quantities for poles, crossties, lumbers, timbers, and fence posts are based upon industry statistics as summarized in table B-4 in appendix B. For purposes estimating the chemical quantities it is assumed that 20% of the chemical is lost for wood disposed after 20 years (Cooper, 1993). Please note that our assumptions do not account for treated wood taken out of service due to accidental damages and losses. For instance, our assumptions do not include treated wood removal due to destruction through car collisions, destruction during large storms, or removal due to home renovation activities. The value of "C" is then computed from equation II-2 as C = A - dB/dt.

II.2.b Results

Generation (Refer to Tables B-1 to B-4 in Appendix B) Waterborne wood preservatives were a small fraction of the wood preserving market prior to the 1970s. During the 1970s the use of waterborne preservatives, and specifically CCA, began to escalate dramatically. Approximately 10 million pounds of waterborne wood preservatives were utilized in the U.S. during 1964 (table B-3 in appendix B). Most of these waterborne preservatives consisted of chromated zinc arsenate (Boliden Salts), acid copper chromate (Celcure), chromated zinc chloride, flour chrome arsenate phenol (Osmosalts and Tanalith/Wolman Salts). Only 8 percent of the waterborne market at this time consisted of CCA

16 (Green Salt). Nevertheless, once CCA was introduced into the wood preserving industry, its use began to escalate dramatically. By 1995, 147 million pounds of waterborne preservatives were utilized for wood treating purposes and over 90% of the waterborne preservatives utilized was CCA. Other waterborne chemicals used to a lesser extent in 1995 include ACZA, ACQ, ACA, ACC. It is also interesting to note that the introduction of CCA within the wood treating industry caused a shift in the chemicals used for treating wood products (table B-4, appendix B). For example, in 1964, approximately 38% of all lumber and timbers produced were treated with waterborne preservatives. This percentage increased to 99% by 1996. A similar trend was observed for poles where 0.3% of the total product was treated with waterborne preservatives in 1964; however, by 1996 this figure increased to 38%. Our generation estimates for Florida (figure II-3 below and table B-3 in appendix B) show a similar trend as observed for the U.S. In 1964 it is estimated that approximately 2 million cubic feet of wood product treated with waterborne preservatives were produced within Florida. By the early 1970s this figure reached a value of 3 to 4 million cubic feet. From the 1970s to the 1990s the amount produced increased by a factor of 10 with a production of roughly 30 million cubic feet in 1995. The amount of wood product generated in Florida corresponds to roughly 1 million pounds of the treatment chemical in 1964. By 1980 this value increased to 4 million pounds and by 1995 the amount reached a value of 10 million pounds.

50 45 AWPI, 94 40

35

30

25

20

Million cubic feet . 15

10

5

0 64 66 68 70 72 74 76 78 80 82 84 86 88 90 92 94 96 Year

Figure II-3: Quantity of Wood Product Treated with Waterborne Preservatives, Florida

17 Disposal Projected disposal quantities are provided in table II-3 and figure II-4. Results indicate that the quantities of CCA-treated wood disposed in the U.S. and Florida are expected to increase dramatically in the near future. Our analysis indicates that roughly 3.7 million cubic feet of treated wood product were disposed in Florida in 1996. By 2006 we expect to find 14 million cubic feet within the disposal stream and by 2016, 31 million cubic feet are expected. These disposal quantities correspond to the disposal of 0.7 million pounds of the chemical during 1996. We anticipate that by 2006 this figure will quadruple and by 2016 it will reach a value of 6 million pounds.

Year CCA-Treated Wood Disposed 106 ft3 Florida US 1995 3.7 31.0 1996 3.7 34.6 1997 3.8 36.9 1998 3.9 40.6 1999 4.3 47.1 2000 4.8 54.2 2001 5.2 62.8 2002 6.1 76.5 2003 7.3 94.9 2004 8.9 116.9 2005 11.2 141.5 2006 13.7 171.2 2007 15.8 203.7 2008 18.2 239.6 2009 20.6 270.0 2010 22.8 293.5 2011 24.8 313.6 2012 26.7 336.6 2013 28.1 359.1 2014 30.0 375.6 2015 30.9 386.4 2016 31.0 397.3 Table II-3: Disposal of CCA-Treated Wood in Florida and US (Estimated).

18 35

30

25

20

15

10 Million cubic feet

5

0 1995 1997 1999 2001 2003 2005 2007 2009 2011 2013 2015 Year

Figure II-4: Projected Disposal Quantities for CCA-Treated Wood, Florida

19 II.3 DISPOSAL RESERVOIRS FOR CCA-TREATED WOOD-WASTE

Efforts during this phase focused on estimating the quantities of CCA-treated wood disposed through construction and demolition (C&D) recycling facilities and through wood-burning operations. It is recognized that other disposal reservoirs, such as municipal solid waste landfills and incinerators or composting operations, may accept CCA-treated wood. However, these reservoirs are considered small relative to the volume disposed through C&D and wood waste cogeneration facilities.

II.3.a Methods: Construction and Demolition (C&D) Waste Stream

C&D waste represents one of the larger components of the municipal waste stream. C&D is composed of a variety of materials, including concrete, asphalt, metal, drywall, paper, , and wood. Wood is used as a primary building component in most residential structures in Florida. CCA-treated wood in the C&D waste stream comes from both remnants of new construction, as well as demolished structures. As part of residential construction, CCA-treated wood is used in areas of the structure where contact with the external environment is likely. This includes any wood in contact with the foundation, foundation piles, and outdoor wood fixtures. The following relationship was used as a basis for determining the amount of CCA-treated wood entering Florida's C&D facilities yearly (MCCA [tons/year]).

MCCA = [MC&D]*[Fwood]*[FCCA] equation (II-5)

MC&D refers to the total amount of C&D waste entering Florida C&D facilities [tons/year], Fwood represents the fraction of wood in Florida's C&D waste stream [ton/ton], and FCCA is the fraction of CCA-treated wood in total wood stream [ton/ton].

The amount of C&D waste entering Florida’s landfills and recycling facilities (MC&D) was estimated using existing generation estimates, as well as specific data from recycling facilities in

Florida. The fraction of Florida’s C&D waste stream which is composed of wood (Fwood) was estimated using existing C&D waste composition estimates, ongoing C&D waste composition work, and data from C&D recycling facilities. The methodology used to estimate FCCA included a number of steps: collection of wood samples, sample preparation, analysis for concentrations of copper and chromium in the prepared samples, mass balance computations, and method validation. The steps necessary for the computation of FCCA are provided below.

Sample Collection Samples were collected from 12 C&D recycling facilities or waste wood recovery facilities. Only chipped wood was collected. A composition analysis based on sorting unprocessed wood was not used because of the large volume of material which would have to be sorted to collect a representative sample, and because of the difficulty in visually identifying CCA-treated wood. Samples were collected in 35-gallon plastic containers. Composite grab samples were collected, with a minimum of 20 grabs from each pile; and at some sites duplicate samples were collected. The facilities that were visited are termed for this paper as A through M and a description of these facilities and the types of samples collected are presented in table II-4.

20 Site Samples General Facility Description A 2 Processing facility of wood waste: separated C&D, pallets B 1 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. C 2 Processing facility of wood waste: Separated C&D, pallets D 4 Mixed C&D waste recycling facility. Wood separated up front and in mechanical separation system. E 2 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. F 1 Mixed C&D waste recycling facility. Wood separated up front. G 1 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. H 2 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. I 2 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. J 1 Mixed C&D waste recycling facility. Wood separated up front and in manual recovery system. K 1 Mixed C&D waste recycling facility. Wood separated up front. M 1 Mixed C&D waste recycling facility. C&D is initially crushed, wood is separated by floatation. Table II-4: Sampling Sites and General Facility Descriptions

Sample Preparation Although the sample wood chips were size-reduced at the source, they were still too large to provide a representative sample for analysis of metals, and additional sample processing steps were deemed necessary. First, the samples were passed through a size reduction device (chipper- shredder). The entire contents of the 35 gallon containers were passed through the shredder twice. In addition to bringing the sample size of most pieces to less than 1 inch, this process provided mixing. Sample mass was measured before and after chipping to determine any loss in the shredding process. Remaining large pieces in the samples were further size reduced using stainless steel sheers. During these two steps impurities such as nails and wires were removed from the samples and characterized. The samples were then placed on a plastic tarp, mixed for 10 minutes, and six 1200 g subsamples were randomly collected and placed in plastic containers. Each of the six grab samples was composed of at least 20 grabs from throughout the pile. Three of the six samples were then dried in an oven at 105 EC. Moisture content was determined. The dried samples were then ashed in a muffle furnace at 550 EC, and the volatile solids content was calculated. All of the ash was then transferred to teflon lined glass jars and stored in a refrigerator at 4EC.

21 Sample Analysis The ash was analyzed for copper and chromium. The measurement of copper and chromium involved digesting the ash using EPA Method 3050B. The digestates were analyzed on a Perkin Elmer 5100 Atomic Absorption Spectrophotometer using Flame Atomization.

Chipped Wood Sample in 35-gallon Container

Size-Reduce Sample Using Chipper- Repeat Shredder Once

Mix Sample for 10 minutes

Collect six 1200g Sub- samples from random grabs throughout the pile

Dry (105C) and then ash (550C) approximately 700 g of each subsample.

Analysis ash for Copper, and Chromium.

Figure II-5: Sample Preparation Process

22 Mass Balance Computations It was theorized that the mass of copper and chromium in a wood sample would result from two sources: a) from CCA-treated wood and, b) from other wood types. Other sources of metals were assumed negligible. A literature review on background metals concentrations in wood indicated that CCA-treated wood and its ash contain higher chromium, copper, and arsenic concentrations than other wood types including clean wood, wood treated with creosote, pentachlorophenol, resins, and adhesives. The difference in metals concentrations was several orders-of-magnitude between these two general categories of wood (Please refer to table I-3, Chapter 1). Given the extreme differences in metals concentrations, a mass balance based upon metals concentration data can be utilized to estimate FCCA. This mass balance is given quantitatively by:

MTCT,m = MowCow,m + MCCACCCA,m equation (II-6) Total Metal Mass Metal Mass from Other Wood Metal Mass from CCA-treated Wood

where: Mj = mass of wood. Subscript j corresponds to wood type where: T = recycled wood waste, ow=other wood, and CCA=CCA-treated wood. Cj,m corresponds to metals concentrations (mass metal per mass wood), where CT,m is the concentration of the recycled wood waste, Cow,m is the metal concentration corresponding to other wood types, and CCCA,m is the metal concentration corresponding to CCA-treated wood. One mass balance is developed for each metal as provided by subscript m, where m = Cu corresponds to copper and m = Cr corresponds to chromium.

Values of CCCA,m and C ow,m were measured experimentally in the laboratory. C CCA,m were 3 obtained by processing CCA Type C with a 0.25 lb/ft retention level. Cow,m were obtained by processing clean wood. Re-arranging equation II-6, the fraction of the recycled wood waste stream composed of

CCA-treated wood, Fm, is computed as, M C & C F ' CCA ' T,m ow,m CCA,m & equation (II-7) MT CCCA,m Cow,m

Validation To validate the methodology, wood samples with known treated wood concentrations were analyzed. Type ?C” 0.25 lb/ft3 CCA-treated wood was purchased from a local hardware store. The treated wood was then passed twice through the chipper shredder, in a similar manner as the other wood samples. Treated wood was mixed with untreated wood to achieve concentrations of 1%, 5%, and 10% by mass. The mixture was then dried and the moisture content was measured. The dried wood sample was then ashed in a muffle furnace at 550 EC. After ashing, the sample was placed in a teflon lined glass jar and stored at 4 EC.

During analysis samples were digested and measured for Cu and Cr concentrations. The FCCA values were calculated using the same methodology as the waste wood samples and compared to the theoretical values. The predicted or measured CCA wood concentration (FCCA) is plotted in figure II-6 versus the actual concentration. The bold line indicates a 1:1 relationship. As can be seen, the method provided accurate prediction of FCCA using both copper and chromium.

23

II.3.b Methods: Wood Burning The objective of this task was to estimate the quantity of CCA-treated wood that is burned for disposal or energy recovery purposes. The task included: a) developing a list of wood burning facilities within the State of Florida, b) determining the quantities and characteristics of the wood fuel at these facilities, and c) estimating the quantities of CCA-treated wood burned from mass balance considerations.

List of Wood Burning Facilities A list of wood burning facilities was developed through a database established by the Florida Department of Environmental Protection (DEP). The database was searched for facilities that have received air emission permits and which burn specific types of waste. Specifically the following waste categories were searched: wood/bark waste, bagasse, solid waste, wood commercial/industrial space heaters, solid waste disposal - government/commercial/institutional, wood refuse, trench burner wood, trench burner refuse, fire fighting structure wood pallets. This search was facilitated by Kathy Anderson and Yi Zhu of the DEP. The initial list contained approximately 200 facilities. This list was further narrowed by removing facilities that did not burn wood. This narrowed list is based upon more detailed descriptions of the fuel stream as available through the database and through follow-up phone calls. The shortened list of facilities which were considered to potentially include wood boilers and wood cogeneration plants is provided in appendix C.

Quantities and Characteristics of Wood Fuel Quantities and characteristics of the wood fuel at each of the facilities was determined through a review of DEP permit applications, field visits, and through a questionnaire sent to each of the facilities. A review of DEP permit applications in June 1997 provided information concerning fuel and ash quality for major wood burning operations within the State. These data were compiled for purposes of estimating the quantity of CCA-treated wood at each site. Field visits were also conducted in June 1997 to three facilities: the Okeelanta cogeneration plant, the Ridge cogeneration plant, and the Koppers wood boiler operation. Data concerning wood fuel quality, quantity, and operational practices were obtained from each facility. To further obtain data a questionnaire3 was sent to each of the facilities considered to potentially burn wood (table C-1 in appendix C). The questionnaire inquired about the quantity of wood burned as well as characteristics of the wood fuel stream. Chemical composition data of the wood fuel and ash were requested if available. Following each mailing, telephone calls were made to the plant manager to assure receipt of the questionnaire. For facilities that did not respond, a second copy of the questionnaire was sent.

Quantities of CCA-Treated Wood Burned Mass balance was used in conjunction with metals concentration data to estimate the quantity of CCA-treated wood that was burned through wood boiler and wood cogeneration facilities. The same mass balance equations were utilized as for wood waste recycling (equation II-6 and II-

7), except in this case metals concentration data (Cow and CCCA) were based upon literature values (Please refer to table I-3, Chapter 1). Values of CT were provided by the wood burning facilities or through review Florida DEP permit applications. Since data were available for copper,

3Copy of questionnaire and cover letter included within appendix C.

25 chromium, and arsenic, three mass balance equations were developed from equation II-6 and therefore three values were computed for the fraction of the wood fuel stream composed of

CCA-treated wood (FCCA). An overall average value of FCCA, Average is given by:

F % F %F F ' Cr Cu As equation (II-8) CCA,Average 3

where: FCr,FCu,FAs are the average fractions computed from chromium, copper, and arsenic results, respectively. The quantity of wood burned at each facility, QW, was computed as follows:

N Q ' R ( H ( D equation (II-9) W 100

where: N = percentage of fuel composed of wood; R = average feed rate for plant (ton/hr); H = number of hours of operation per day (hr/day); D = number of days of operation per year (days/yr).

The amount of CCA-treated wood burned at each facility, QCCA, in units of tons per year was then computed from values of FCCA,Average as:

' ( equation (II-10) QCCA QW FCCA,Average

3 The value of QCCA can be converted to units of ft /yr (PCCA) utilizing an average density for wood of 30 lb/ft3 (Lide, 1992; AWPA, 1996). This conversion is given as:

Q ( 2000 lbs./ton P ' CCA equation (II-11) CCA 30 lbs per cubic foot

II.3.c Results: C&D Waste Stream

The amount of C&D waste generated (MC&D) in Florida in 1995 was estimated by the Florida DEP as 5,200,000 tons. While much of the information used to calculate this number is debatable, the amount generated as compared to MSW falls in line with other C&D waste estimates.

The amount of wood in C&D waste, (Fwood), varies from the type of construction or demolition project. The National Association of Homebuilders estimates that 24% of waste generated from a single-family wood-frame house is composed of wood (NAHB, 1995). At a C&D waste competition study in Illinois, wood was found to be the largest component of the waste stream at 27% (MWA, 1992).

26 CCA Fraction in C&D Waste Wood, FCCA A total of 61 samples were ashed, digested and analyzed for copper and chromium concentrations. The concentrations ranged from 39 to 15,726 mg/kg of nonvolatile solids (NVS) for copper and from 10 to 29,145 mg/kg of NVS for chromium. The copper and chromium concentrations in the ashed samples were compared to determine if a relationship consistent with CCA-treated wood was observed (figure II-7). Included in figure II-7 is the best fit line (for the entire data set) and the theoretical chromium to copper ratio for CCA Types A, B, and C. These results confirm that it is very likely that the copper and chromium measured were the result of Type C CCA-treated wood. The copper and chromium concentrations in the ashed samples were then used in the equations developed previously to calculate the fraction of CCA-treated wood in the collected samples (FCCA). The mass balance was based on the assumption that the Cu and Cr were from the volatile solids (VS) fraction present in the sample (wood). Thus the VS results were important. Consider two ash samples with the same metal concentration. The one with the greatest VS

content would have the lesser FCCA, because those metals would have been a result of more wood (more VS). The VS content ranged from 58% to 98% for the collected samples. Samples that were predominately wood had the greatest VS content, and samples mixed with some soil had the lowest.

The results of the FCCA calculations are presented in table II-5 for each sample by both copper and chromium. The FCCA predicted using copper ranges from "below detection" to 26%. The F CCA predicted by chromium ranges from "below detection" to 29%. It is important to again note, 3 that FCCA is the percentage of 0.25 lb/ft Type C CCA-treated wood needed to account for all of the copper and chromium measured. If the Cu and Cr were the result of a 0.6 lb/ft3 retention

level, the FCCA number would be only 43% of the number in table II-5. The average FCCA for all samples was 6.1% based on copper and 5.6% based on chromium. The values utilized for the samples that were below detection was 0.4%. It is observed that samples collected at given sites tended to follow similar patterns. Sample 2 from site C had the highest calculated CCA fraction. CCA-treated wood was readily observed in the unprocessed fraction at this facility, including a number of pole cut-offs which were likely greater than 0.25 lb/ft3 standard retention. Site D had two samples that were below 1%. These samples corresponded to material at a site that processed both yard waste and C&D wood waste. The

samples with FCCA values less than 1% were collected primarily from the vegetation fraction.

27

Site Sample Number of FCCA, (%) Average Number Replicates Copper Chromium (%) 0.25 TypeC 0.25 TypeC A 1 3 4.2 3.3 (3.7-5.0) (3.1-3.7) 3.8 2 3 3.1 2.7 (2.6-3.9) (2.0-3.6) 2.9 B 1 3 4.7 5.1 (4.2-5.1) (4.8-5.3) 4.9 C 1 3 1.3 1.2 (0.9-1.7) (0.8-1.4) 1.2 2 3 22.1 23.6 (19.7-26.0) (20.2-28.8) 22.9 D 1 3 9.9 6.4 (9.1-10.7) (6.0-7.2) 8.2 2 3 BD BD (BD,BD) (BD,BD) BD 3 3 3.2 2.6 (2.9-3.8) (1.5-3.4) 2.9 4 3 BD BD (BD,BD) (BD,BD) BD E 1 3 8.3 7.6 (7.8-8.7) (7.2-8.0) 8.0 2 3 5.8 5.8 (5.4-6.3) (5.5-6.5) 5.8 F 1 4 9.3 6.7 (7.6-10.2) (5.9-7.4) 8.0 G 2 3 6.0 6.1 (5.3-6.8) (5.6-6.6) 6.1 H 1 3 4.9 5.0 (4.3-5.3) (4.5-5.5) 5.0 2 4 4.4 4.4 (3.0-5.6) (3.0-5.4) 4.4 I 1 3 4.6 3.7 (2.2-6.1) (2.6-5.5) 4.2 2 3 5.2 4.4 (5.0-5.4) (3.5-5.7) 4.8 J 1 3 8.7 8.0 (6.1-10.1) (6.4-9.0) 8.3 K 1 3 11.2 10.2 (9.4-13.9) (9.0-11.3) 10.7 M 1 3 4.6 4.4 (4.2-5.1) (4.1-4.6) 4.5 BD: Below Detection (Detection Limit Varies from 0.1 to 0.8%)

Table II-5: FCCA (%) in Wood Waste

29 Summary

The fraction of C&D wood waste (FCCA) that is composed of CCA is estimated from experimental data as 5.9%. During 1995, Florida generated an estimated 5,200,000 tons of C&D waste and roughly 25% of the C&D waste was composed of wood. Using equation II-5, the amount of CCA- treated wood that is found within the C&D waste stream is roughly 77,000 tons. This value is equal to 4.6 x 106 ft3 assuming an average wood density of 33 lb/ft 3. The mass balance from section II.2 indicates that the total quantity of CCA-treated wood disposed within the State is approximately 3.7 x 106 ft3. Given the uncertainties in our estimates it is interesting to note that both the amount disposed within the C&D waste stream is of the "same-order-of-magnitude" as the total disposal quantity predicted through methods described in section II.2. Our interpretation of these results is that most of the CCA-treated wood waste is likely disposed through the C&D waste stream.

II.3.d Results: Wood Burning Responses were received from 27 of the 45 facilities sent questionnaires4 (table II-6). Additional information concerning 3 of the 27 responding facilities was obtained from field visits and review of permit applications. Six of the 20 facilities that did not respond could not be reached by telephone or mail. Of the 27 responding facilities, 13 utilized wood as a fuel source, 7 did not utilize wood as fuel, 2 utilized a small amount of wood for start-up purposes, 3 were not burning facilities, and 2 chose not to participate. Of the 13 facilities which utilized wood, 7 utilized another fuel besides wood. The characteristics of these other fuels includes mixtures with rubber tires, , pecan hulls, bagasse, black liquor, and fossil fuels. The amount of ash generated by each of the responding facilities ranged from 1,000 to 11,000 tons per year. Most of the ash was landfilled or stock-piled. Small quantities of ash were utilized as landfill cover or as recycled material. Some ash and metals data was supplied. Response Percentage Number Utilize Wood as a Fuel Source 28 % 13 Do Not Use Wood As a Fuel Source 15 % 7 Utilize Small (Insignificant) Amounts of Wood 4 % 2 Not a Burning Facility 6 % 3 Do Not Wish to Participate 4 % 2 No Response 43 % 20 Total 100 % 47 Table II-6: Response to Questionnaire.

After reviewing the available information for the 13 facilities that burn wood in Florida, 10 of the facilities accept some form of recycled wood waste from construction and demolition facilities. It is therefore suspected that these 10 facilities can potentially burn treated wood. Information concerning these 10 facilities is provided in the summary below. Numbers are used instead of company names for confidentiality purposes. Plants were numbered from 1 through 10 in order of the amount of

4A list of the facilities that were sent questionnaires is provided within table C-1 within appendix C.

30 wood burned per year. Plant 1 burns the most whereas plant 10 burns the least.

Plant # Other Fuel (%) Wood Waste, N (%) 1 50 50 2 0 100 3 67 33 4 17 83 5 0 100 6 37 63 7 24 76 8 30 70 9 76 24 10 0 100 Table II-7: Fuel Composition for Facilities that Burn Wood Mixtures

Metals concentration data for the wood fuel were available from only two wood burning plants. These data and the computed fraction of CCA-treated wood is given in table II-8.

Plant CT,Cr CT,Cu CT,As FCr FCu FAs FCCA,Average No. (mg/kg) (mg/kg) (mg/kg) (%) (%) (%) (%) 1a 27.2 19.1 21.4 0.97 1.40 1.62 1.3 6b 12.6 40 NMc 0.27 3.31 ---- 1.8 aData obtained from DEP permit applications bProvided through Wood Boiler Questionnaire cNot Measured Table II-8: Metals Concentrations in Wood Fuel

It is noted from the data that the values from plant 1 appear to be more reliable given that the standard deviation of the results (0.33%) is significantly lower than the standard deviation for plant

6 (2.2%). Given the lack of data on fuel quality, the values of FCCA,Average for the remaining plants were assumed equal to 1.3%. Testing of the wood fuel is highly recommended to obtain a more

accurate estimate of FCCA,Average for other facilities. Given our assumptions and equation II-11, the total amount of CCA disposed via wood burning facilities is estimated at 2.5 x 106 ft3/year. The total amount disposed, as estimated from section II.2, is 3.7 x 106 ft3/year. These values suggest that wood burning/cogeneration facilities can account for up to 67% of the CCA disposed during 1996. The 67% estimate should not be considered an absolute value in light of the uncertainties in our assumptions. What is noted from these numbers is that both estimates are within the "same-order-of-magnitude" and that they support the hypothesis that a significant fraction of CCA-treated wood waste generated within the State is used for energy recovery purposes.

31 Plant Total Wood CCA-treated (estimated)

Number Burned, QW 3 tons/year tons/year ft /yr QCCA PCCA 1 678,000 9,000 602,000 2 547,000 7,300 485,000 3 321,000 4,300 285,000 4 300,000 4,000 270,000 5 287,000 3,700 249,000 6 257,000 4,600 308,000 7 151,000 2,000 134,000 8 73,000 980 65,000 9 40,000 530 36,000 10 26,000 350 23,000 Total 2,680,000 36,760 2,457,000

Table II-9: Quantities of Wood Burned at Facilities Accepting Wood Waste and Estimated Quantities of CCA-Treated Wood (1996).

32 CHAPTER III MANAGEMENT OPTIONS

33 CHAPTER III, MANAGEMENT OPTIONS

Management options for CCA-treated wood waste include waste minimization, reuse, recycling, and ultimate disposal. Reuse is distinguished from recycling by the amount of processing needed to find new uses for the wood. Reuse requires minimal processing (i.e. the original piece of discarded wood remains intact with minimal cutting) whereas recycling requires a significant change in the character of the wood waste prior to using it for another purpose (e.g. chipping and binding with adhesives for wood based composite materials). Treatment technologies for extracting metals from CCA-treated wood are included within recycling alternatives since metal extraction increases the potential for recycling the wood fiber. The preferred management options are presented first with the least preferred options following. A summary of these management options is included at the end of this chapter in table III-1.

III.1 WASTE MINIMIZATION

Waste minimization includes the use of alternative structural materials and alternative chemical preservatives. A description of these alternatives are provided below. Prolonging the service life of CCA-treated wood products through retreatment is also considered a means for waste minimization. Consider for example that a company requires 100 CCA-treated utility poles for a period of 100 years. If the service life of the pole is 25 years then 400 poles (100 * (100/25)) must be purchased during the 100 year period. If the service life of the pole is increased to 50 years then only 200 poles (100 * (100/50)) must be purchased during the same 100 year period. Therefore, by increasing the service life of a CCA-treated pole from 25 to 50 years, the amount of wood product utilized (and therefore the amount ultimately disposed) decreases by 50%. The net effect of retreatment technologies is to reduce the quantity of CCA-treated wood waste within the disposal stream.

III.1.a Alternative Structural Materials Wood has several unique characteristics which make it a good structural material. Wood has a high strength to weight ratio and it is easily fastened, cut, and painted. Wood is also a "renewable resource" whose availability can be replenished through tree planting. This property is contrasted with other building materials, such as steel, concrete, aluminum, and brick, which are obtained from Earth's finite reserves. Furthermore, less energy is required to process wood when compared to other materials (Milton, 1995). Treating wood has its advantages by prolonging the service life of wood products. At some point however, the disadvantages of using CCA from a disposal perspective outweigh the positive aspects. If the objective is to reduce the quantity of CCA chemical found within the waste stream, waste minimization should be considered a priority.

Plastic lumber "Plastic lumber" is an alternative to CCA-treated wood for some applications. Plastic lumber is composed of recycled plastics such as polyethylene, polypropylene, polystyrene, and polyvinyl chloride. Plastic lumber can be used in walkways, decks, park benches, picnic tables, fence posts, and playground equipment. It is skid resistant, insect resistant, and durable. The service life for plastic lumber is 35 to 50 years. Its utilization allows for the recycling of plastic and the reduction

34 of the use of CCA-treated wood (Gunzburger, 1991). Disadvantages with the use of plastic lumber include its lower strength.

Utilization of wood with natural resistance As trees grow they produce chemical by-products or extractives. These extractives are harmful to the outer area of the tree which is also called the cambium layer. In order to protect this layer, extractives are deposited within dead cells located within the heartwood center. These extractives are often toxic to insects and fungi, thereby providing the heartwood portion of the tree natural protection against decay (Milton, 1995). The type and quantity of extractives produced by a tree differs from species to species, and therefore some tree species have naturally more resistance than others. Tree species characterized by natural resistance include American chesnut, western red cedar, mahogany, and teak. It is also important to note that extractives are found only within the heartwood layer. Even for species considered durable, wood surrounding the heartwood (i.e. sapwood) must be removed or treated for durability. Durable species are more expensive, scarce, and slower to grow, than non-durable species. The scarcity of durable species is due in part to extensive harvesting and re-planting with fast growing non-durable species (Milton, 1995).

Other alternative materials Other structural materials that can be used instead of treated wood include concrete, steel, aluminum, brick, fiberglass, and stone. Life-cycle analysis of these products indicates that untreated wood requires the least amount of energy to process (Milton, 1995). Life-cycle analysis for treated wood products is currently underway through an independent research project (Reaven, personal communication).

III.1.b Alternative Chemical Preservatives

Creosote and pentachlorophenol Creosote and pentachlorophenol preservatives are recommended only for wood used outdoors and for uses with limited human contact. These limitations are due to skin irritation and odors emitted by the preservatives. These preservatives nevertheless can be used as alternatives to CCA for outdoor applications that have limited human contact. Examples include utility poles which today are treated to a considerable extent with CCA. Advantages associated with creosote and pentachlorophenol are the lower metals concentration associated with these preservatives. Although some concerns have been raised concerning emissions, burning creosote and pentachlorophenol has advantages over CCA. When burned, the ash from creosote and pentachlorophenol has lower metals concentrations, and the oils associated with these preservatives, facilitate the combustion process reducing the need for fuel oils when these wood types are incinerated.

Phytoalexins Trees produce several chemicals which protect them from insects and fungi. These chemicals are collectively referred to as phytoalexins. Phytoalexin chemicals include cotonefuran, glaucine, mansonone F, suberin, tropolones, and gamma-thujaplicin to name a few. Suberin is a component of the bark layer of trees. Tree bark is usually the last component to degrade after a tree has died and this resistance to decomposition has been attributed to suberin, a complex polyester. It has

35 also been observed that tropolones are also produced by bacteria. The process of manufacturing tropolones via bacterial engineering has been patented in anticipation of its potential application in wood preservation. Utilization of phytoalexins, nevertheless, is currently restricted to non- commercial testing because of the difficulty in extracting or producing large quantities of the chemical (Fahy, et. al., 1993).

Copper naphthenate Copper naphthenate is usually added to an organic solvent which serves as a carrier fluid during the treating process. Due to the need for organic solvents to dissolve the chemical, wood treated with the chemical has a characteristic odor. This disadvantage can be avoided through the use of water soluble forms of copper naphthenate, which are less commonly used. Other disadvantages of the chemical include its lack of resistance to some strains of fungi (Fahy, et. al., 1993) and the strong green color that it imparts to wood. Brown dyes have been added to the preservative in an attempt to make the treated product more appealing (Summers, 1995). As for creosote and pentachlorophenol, copper naphthenate may be substituted for CCA in outdoor applications. Copper naphthenate contains elevated copper concentrations which must be addressed during disposal.

Alkaline Copper Quat (ACQ) ACQ is manufactured by Chemical Specialties Inc., located in Charlotte, North Carolina. The formulation recommended by the manufacture is ACQ Type D which is composed of a 2:1 ratio of copper oxide to quat. Quat is an abbreviation for quaternary which is a chemical term used to describe a molecule with four functional groups. The "quat" molecule used in ACQ is didecyldimethyl ammonium chloride or more simply termed DDAC. The carrier liquid is water. A strong base is added to the water to increase its pH. ACQ is also known as Ammoniacal Copper Quaternary Ammonium. A major advantage of this chemical preservative is that it does not contain arsenic or chromium, therefore reducing some of the environmental concerns associated with the disposal of these compounds. Furthermore, quat is considered to have low human toxicity. Another major advantage is that ACQ has been standardized by the American Wood Preservers' Association and formulations have been developed for use outdoors in above ground, ground contact, for freshwater, and for marine splash zone contact. The service life of ACQ treated wood is similar to that of CCA and ACZA (Archer, personal communication, 1998). Disadvantages of the chemical include elevated copper concentrations which must be addressed during disposal and the alkaline nature of the chemical. Treatment with this chemical may require the need for a scrubbing system for neutralization of alkaline vapors produced during the treating process (Fahy, et. al., 1993).

Ammoniacal copper zinc arsenate (ACZA) ACZA is capable of penetrating western wood species more effectively than CCA and thus ACZA is utilized primarily in the western states as an alternative to CCA. Treatment with ACZA requires an additional step for wastewater neutralization since the chemical is dissolved in an alkaline solution during treatment. Disposal of ACZA treated wood is subject to the same drawbacks as CCA due to elevated metals concentrations. Although levels of chromium are not as high within ACZA, zinc represents a significant concern upon disposal.

36 Ammoniacal copper arsenate (ACA) Use of ACA alleviates the disposal concerns associated with chromium. However, the chemical does contain elevated concentrations of copper and arsenic.

Borates Borates are used in the United States and in other countries. In the United States the application of borates to wood is performed through a pressure treating process similar to that used for other waterborne preservatives (Staats, personal communication, 1998). Borates are added to water in the form of disodium octoborate tetrahydrate. This chemical is then injected into the wood under pressure using similar equipment that is used for treating wood with other waterborne preservatives. In New Zealand, however, borates are applied in a much different fashion (Burton, et. al., 1990). The application of the chemical in New Zealand typically requires vaporization of trimethyl borate. Trimethyl borate reacts with the wood to form boric acid and methyl alcohol (Turner, et. al., 1990). Primary advantages in the used of borates are that they provide resistance to wood at very low retention levels thereby requiring less chemical on a per unit wood volume basis. It does not discolor the wood and is considered to have low toxicity (Nunes, et. al., 1995). Disadvantages of the chemical are that it is leached from the wood by water and therefore use of the wood is limited to indoor applications. Other disadvantages include that the wood must be very dry (4 to 6% moisture content) during chemical application and, for vapor-phase application of borates, the wastewater produced during treatment is contaminated with methanol (Cogan, personal communication, 1997).

Plastic Coated Wood Plastic can be used to protect the outer surface of the wood thereby circumventing the need for additional chemical treatment. Use of this type of product is very uncommon and issues have been raised concerning cracking and resistance of the plastic coating (Fahy, et. al., 1993).

Other chemicals Other chemicals that have shown some preservative capacity include propiconazole, isothiazolone, cholorthalanil, and copper citrate. Experiments have shown that both propiconazole and isothiazolone are effective against insects and fungi. Isothiazolone is not effective against marine borers and therefore not recommended for marine applications. These chemicals have not been included within the AWPA book of standards (Fahy, et. al., 1993) since limited information exists on their long-term performance.

III.1.c Methods to Increase Product Service Life

Supplemental treatments Supplemental treatments include water sealants and plastic coverings for CCA-treated wood products. These treatments help to maintain the CCA chemical within the wood product thereby providing greater protection against decay. For example, formulations for water proofed pressure treated wood have been developed which protect wood against cracking, splitting, and warping, thereby increasing the service life of these wood products (Archer, personal communication, 1998).

37 Chemical re-treatment Chemical retreatment can extend the service life of wood products. Typical applications include reapplication of chemicals to utility poles at the ground-line, which is generally the area where chemicals are lost the quickest. Care should be taken during the chemical retreatment process to avoid contamination of the environment. Chemicals that can be utilized for re- treatment or maintenance purposes include (Summers, 1995):

C CCA: CCA can be reapplied to the wood product to extend its service life. Regulatory restrictions are placed upon its handling. C Dursban: Dursban contains 0.5% chlorpyrifos, which acts as a pesticide. Chlorpyrifos has low volatility and bonds easily with organic matter. The chemical has a tendency to decompose when subject to light and water. C Timberfume: Timberfume contains 99% chloropicrin, which is used within the agricultural industry as a crop and soil fumigant. Drawbacks with the chemical include its volatility and its tendency to decompose when exposed to water and light. C Woodfume (Vapam): Woodfume consists of 32.7 sodium methyldithiocarbamate. Prior to contact with water, the chemical is non-volatile and bonds to organic matter. When in contact with water, the chemical is transformed to a volatile organic compound, methylisothiocyanate. C Misc Fume: Misc Fume consists of 97% methylisothiocyanate. The chemical does not bond strongly with organic matter, it is soluble in water, and is moderately volatile.

Other retreatment chemicals include Osmoplastic, hollow heart, and borate impel rods. Osmoplastic consists of roughly 45% sodium fluoride, 40% creosote, and 3% potassium dichromate. Hollow heart consists of 11% sodium flouride, 5% sodium dichromate, and 5% sodium arsenate.

Wood treatment process enhancement Several processes can be implemented during the wood treatment process that will help to distribute the CCA chemical more uniformly through the wood matrix and that will improve the fixation of the wood. These process enhancements improve the retention of CCA within the wood during its service life thereby providing more effective protection against decay. The distribution of CCA within the wood matrix is enhanced through the incisor method, which involves placing small incisions in the wood's surface. This process permits the preservative to more effectively penetrate the interior of the wood. This process is especially useful for hardwood such as white , lodgepole pine, and alpine fir. This process, however, does not provide a significant added benefit for treating Southern Yellow Pine, which is by far the primary wood species treated in the State of Florida. Southern Yellow Pine is extremely porous and generally behaves as a "sponge" during the treating process and thus incision is not necessary (Cogan, personal communication, 1997). Fixation of the chemicals to the wood is enhanced through rapid fixation processes (Fahy, et. al., 1993). Rapid fixation processes include hot air heating, hot water fixation, steam fixation, and hot oil heating.

38 II.2 REUSE

III.2.a Reuse for New Applications The most visible of the reuse opportunities include use of CCA-treated utility poles for fence posts, landscaping, and parking lots. Intact portions of large utility poles can be used for lower service lines and as guardrail posts. Construction off-cuts of lumbers and timbers can be used for smaller applications including composting bins, planter boxes, shipping crates, picnic tables, and walkway edging. Potential problems with these re-use options, however, is the generation of contaminated sawdust and human exposures to the sawdust. The demand for CCA-treated wood reuse purposes is apparently high within the State of Florida. The pole recycling facility operated at Florida Power and Light, for example, has observed a considerable demand for spent utility poles (Drescher, personal communication). However, it is important to note that reuse may carry some liability problems for the original generator of the waste (Doyle, et. al., 1992).

III.2.b Reuse for the Same Application The undamaged portions of CCA-treated wood poles can be spliced with adhesives to form intact utility poles. This process is being developed at Michigan State University (Felton and De Groot, 1996). III.3 RECYCLING

III.3.a Recovery of Untreated Portions of Treated Wood Products The untreated portion of treated wood products can be recovered as clean wood and used for other purposes. Examples, include the heartwood portion of treated utility poles which is not usually penetrated by preservatives during treatment (Felton and De Groot, 1996) and butt treated utility poles. For example, a wood recycling facility in British Columbia scrapes the outer two to three inches of the pole and converts the remaining clean portion into lumber ("Woody Materials Recycling", 1997). The main drawbacks with this form of recycling includes the disposal of the treated portions and generation of contaminated sawdust (Doyle, et. al., 1992).

III.3.b Wood based composites Wood based composites include flakeboard (Vick, et. al., 1996), oriented strand board, and particleboard. Wood based composites are potentially well suited for applications which contain high decay potential due to the presence of the preservative chemical. Wood based composites rely on adhesives such as urea-formaldehyde and phenol-formaldehyde for binding purposes. There is a difficulty in binding treated wood because of interferences from the treatment chemical (Felton and De Groot, 1996). These interferences are due to the brittle nature of CCA-treated wood fibers and the CCA chemical deposits themselves which prevent the adhesive contact with the wood. However, hydroxymethylated resorcinol (HMR) can be potentially used as a coupling agent between CCA-treated yellow pine and phenol-formaldehyde adhesives (Vick, et. al., 1996) thereby overcoming problems with adhesives. Smith and Shiau, 1998, in an independent study found that wood composite manufacturers are not in favor of using recycled CCA. Concerns cited were safety of workers and environmental problems that may arise when composite products are contaminated with treatment chemicals.

III.3.c Wood cement composites

39 Wood cement composites are highly pest and fire-resistant. They are generally lighter and possess better insulating properties than products made entirely of cement. Wood cement composites can be nailed, sawn, and machined with wood-working tools. At higher densities, however, the material must be predrilled for screws and nails (Moslemi, 1988). Applications include fire-resistant panels and highway sound barriers (Doyle, et. al., 1992). There are two distinct functions of wood in the cement-based composites. Wood fibers are usually used in board products for providing some tensile strength. Wood can also be added to cement in "chunks," where it simply functions as a low-density low-cost aggregate. Applications of these products include situations where the tensile strength is not critical. Research indicates that cement wood composites with CCA-treated wood are stronger than composites with untreated wood. This increase in strength has been attributed to the chromium in the wood which allows for a stronger bond between the wood and cement (Schmidt, et. al., 1994). Southern pine generally produces the best cement composites. The least desirable species are Douglas-fir, hemlock, and most hardwoods (Felton and De Groot, 1996).

III.3.d Wood gypsum composites As for wood cement composites, wood gypsum composites are highly pest and fire resistant (Felton and De Groot, 1996). Gypsum is water sensitive and therefore the use of wood gypsum composites is limited to indoor applications (Moslemi, 1988). Gypsum composites appear to be less sensitive to wood species than wood cement composites (Felton and De Groot, 1996). Applications of these composites include fireproof walls and ceilings, laminated paneling, and fireproof furniture (Moslami, 1988).

III.3.e Wood plastic composites Some technology exists for reconstitution of chipped treated wood with plastic. Considerable research is needed however to improve the economics of producing these products (Doyle, et. al., 1992).

III.3.d Extraction of Metals Once metals are extracted, the remaining wood pulp can be recycled for many different purposes including energy recovery, mulch, compost, fiberboard, particleboard, to name a few (C.T. Donovan Associates, Inc., 1994). Several researchers have investigated extraction technologies for CCA- treated wood waste. Smith and Shiau, 1997, tested the effects of several acids on sawdust and steam exploded CCA-treated wood. Their results showed that most of the metals were removed within the first 24 hours of treatment. Citric acid was best for removing chromium (18% removed) and copper (80% removed), whereas sulfuric acid was most effective at removing arsenic (27% removed). The extraction of copper was similar between sawdust and steam exploded pulp, but chromium and arsenic were removed more effectively from CCA-treated sawdust (Smith and Shiau, 1997). Bacteria can be used to convert the preservative chemical into a water soluble form. Once converted arsenic, chromium, and copper can be removed from the wood through a washing process and the wood can be used for other purposes. Bacteria convert the CCA chemical to water soluble forms for detoxification purposes only (Felton and De Groot, 1996). Bacteria can tolerate only low levels of the preservative and therefore, pre-treatment of the wood to remove the bulk of the preservative may be necessary prior to bio-conversion processes. Other drawbacks of the process include a wastewater contaminated with metals. Processes must be

40 employed to recover or remove metals from this wastewater.

III.3.f Mulching and composting (unburned wood) CCA-treated wood may be shredded and used as mulch in right-of-ways, potting soil, and animal bedding. However, such practices should be viewed with caution due to the potential for metals leaching. Land application regulations (see section I.2.d) may apply if CCA-treated wood is reused for such purposes. If these recycling options are considered, technologies for removing the CCA from the wood (Smith and Shiau, 1997; Felton and De Groot, 1996) should be considered prior to recycling as mulch. These technologies include biodegradation and solvent extraction. The economics of these technologies, however, may be cost prohibitive at this time.

III.4 ENERGY RECOVERY AND WOOD AS FUEL

Wood can be used for energy recovery purposes or as a fuel in certain industrial operations such as cement kilns. Wood utilized for energy recovery purposes has the advantage in that it lessens the dependence on fossil fuels and eases the landfill burden through volume reduction.

III.4.a Cement kilns Wood can be used to fuel cement kilns. The use of cement kilns has the added advantage in that the wood does not have to be chipped prior to introduction within the kiln and that inorganics within the wood including metals may be stabilized within the cement matrix. Emissions represent a potential problem which may make permitting such facilities difficult (Fahy, et. al., 1993). Other potential drawbacks include the need for a large and consistent wood waste stream and public perception. Although no ash is produced in cement kilns the metals in CCA-treated wood may increase the concentration of metals in cement kiln dust.

III.4.b Cogeneration Several large facilities exist within the State that utilize wood waste as a source of fuel (See section II.3). The primary advantage of these facilities is their energy production and volume reduction for the wood waste stream. Disadvantages include the need to preprocess the wood (i.e. chipping and shredding) prior to introduction within the boiler. Major disadvantages include potential air emission problems and the high metals concentrations that can be found in the wood ash. When incinerated, most of the chromium and copper are retained in the ash while at temperatures greater than 300 oC some arsenic is volatilized (Smith and Shiau, 1996). Amounts of arsenic volatilized ranges from 20 to 90% (Doyle, et. al., 1992). The metals that remain within the ash greatly restrict recycling opportunities for the ash residual. If CCA-treated wood represents a significant fraction of the fuel stream (>2% to 3%) TCLP limits will likely be exceeded resulting in a "hazardous" classification for the ash (Fehrs, 1995; Fehrs, 1996; McGinnis, 1995). Such a classification will greatly escalate ash disposal costs.

III.5 DISPOSAL

41 The least desirable disposal options include incineration without energy recovery and landfilling.

III.5.a Incineration without Energy Recovery Incineration of wood without energy recovery is a waste of a valuable resource. Efforts should focus on energy recovery if possible. Ash from these facilities must be ultimately disposed and emissions must be controlled. Excessive amounts of CCA-treated wood within this waste stream may increase metals concentrations in the ash or in air emissions to unacceptable levels.

III.5.b Landfills Landfills include both Construction and Demolition (C&D) Landfills and Municipal Solid Waste (MSW) landfills. C&D landfills are generally unlined and contain limited leachate monitoring systems. Wood is a significant component of the waste stream at these facilities nevertheless. The US EPA, 1995 reports that approximately 30% of the C&D waste stream in Florida is composed of wood. MSW landfill designs are usually more elaborate and include bottom liners and leachate collection systems. Groundwater monitoring is usually more extensive at MSW landfills. Landfill disposal can be in the form of chips. Large bulky objects such as telephone poles can be buried. Landfill disposal of treated wood is regulated on the basis of leaching characteristics of the wood, as determined by a standard leaching protocols (i.e. TCLP). The literature indicates that CCA-treated wood will pass the TCLP test on most occasions. In the few occasions where it may not pass TCLP tests, an exemption is provided at the federal level if the waste is generated by persons who utilized the wood product for its intended use as long as it is disposed by the end- user. Therefore, disposal of CCA-treated wood can follow disposal practices for regular solid waste. Current regulations however, do not exclude the ash from CCA-treated wood, from being classified as a hazardous waste. Gifford, et. al., 1997 conducted a study to determine the quality of leachate and factors affecting leachate quality when CCA-treated wood was exposed to natural weathering conditions in a simulated land disposal situation. The results of their lysimeter tests indicate that soil attenuates the leachate concentrations of Cu, Cr, and As. They conclude that in well constructed landfills where clay capping layers are placed between waste layers, there is a substantial capacity for the sorption of Cu, Cr, or As and thus reduce the risk of groundwater contamination. Landfill disposal of CCA-treated wood should be considered a last alternative when all other options have been exhausted. Landfill capacity within Florida is diminishing and large bulky materials such as CCA-treated wood waste should be discouraged from disposal within these facilities.

III.5.c Ash Disposal Wood ash has many potential recycling options including agricultural land and forest applications (Vance, 1996). In these applications wood ash is used as a liming agent in order to neutralize soil acids. The application of ash adds nutrients such as calcium, potassium, magnesium, and micronutrients to the soil. The application of wood ash also increases microbial activity which enhances nitrogen availability, mineralization, cellulose decomposition, and nitrogen fixation (Campbell, 1990). Wood ash can also be used to control the odor and moisture content of wastewater sludge (Campbell, et. al., 1997). This material can then be used as a soil amendment (Pepin and Coleman, 1984). Wood ash can also be used as an amendment for

42 compost produced from yard waste. The recommended ratio of wood ash to compost is 1:1. Higher ratios result in excessively alkaline pHs and high salt content which impedes the use of compost to enhance plant growth (Campbell, et. al. 1997). Recycling opportunities for ash however are limited if the ash contains elevated metal concentrations. Excessive amounts of CCA-treated wood ash would significantly degrade ash quality and will greatly limit recycling opportunities due to land application regulatory criteria (See section I.2.d). If ash quality degrades to a point such that TCLP limits are exceeded, the resultant ash will be classified as hazardous and the costs for disposal would escalate.

43 Waste Minimization C Alternative Structural Materials: Plastic Lumber, Concrete, Steel, Aluminum, Fiberglass, Brick, Stone, and wood species with a natural resistance to decay. C Alternative Chemical Preservatives: Creosote, pentachlorophenol, alkaline copper quat, copper naphthenate, borates, phytoalexins, etc.. C Increase Service Life: Supplemental treatments, chemical re-treatment, and wood treatment process enhancement. Reuse C Reuse for New Applications: Fence posts, landscape timber, parking lot bumpers, guardrail posts, composting bins, planter boxes, shipping crates, picnic tables, walkway edging, etc... C Reuse for Same Application: Splicing intact portions of spent utility poles. Recycling C Recovery of Untreated Portions of Treated Wood Products: Clean wood portions used for many different applications C Wood Based Composites: Flakeboard, oriented strand board, and particleboard. C Wood Cement Composites: Fire-resistant panels and highway sound barriers. C Other Composite Materials: Include wood gypsum composites that can be used for fire-resistant panels (indoor applications only) and plastic wood composites which are currently under development. C Extraction of Metals: Chemical and biological methods under development for unburned wood. C Mulching and Composting (unburned wood): Viewed with caution due to potential for metals leaching. Energy Recovery and Wood As Fuel C Cement Kilns: Advantages include no ash residual and stabilization of the metals in cement matrix. C Cogeneration: Requires shredding wood waste and disposal of ash residual. Excessive quantities of CCA-treated wood in fuel stream may cause ash disposal problems. Disposal C Incineration Without Energy Recovery: Some CCA-treated wood may be commingled in trash or wood fuel. Excessive CCA-treated wood may cause ash disposal problems. C Landfills: Currently can be accepted at C&D Landfills and MSW Landfills. C Ash Disposal: Wood ash has many recycling opportunities. However, elevated metals concentrations from excessive amounts of CCA may greatly limit these recycling opportunities. Table III-1: Summary of Management Options for CCA-Treated Wood Waste.

44 CHAPTER IV CONCLUSIONS AND RECOMMENDATIONS

45 IV.1 CHANGES IN WOOD TREATMENT INDUSTRY AND IMPLICATIONS TO THE WOOD DISPOSAL SECTOR

The chemicals utilized by the wood preservation industry have changed significantly since the 1970s. During the 1970s preservatives made of organic chemicals, such as creosote and pentachlorophenol, were the most widely used preservatives. During the 1970s and 1980s the use of waterborne preservatives, composed primarily of metal salts or oxides, began to increase dramatically. Given the trends in chemical usage by the wood treatment sector, changes in the composition of the wood waste stream are anticipated in the near future. These changes in the waste stream will have a significant impact upon disposal. Metals from discarded CCA-treated wood must be addressed. These metals are concentrated in the wood ash upon combustion and some metals may be lost through air emissions. Since creosote and pentachlorophenol are composed of organic compounds, both chemicals can be converted to carbon dioxide and other carbon-based chemicals by the action of micro-organisms or through combustion. There are some concerns associated with air emissions since some toxins can be produced if combustion temperatures are not properly maintained and if air pollution control devices are not used. However, the disposal issues associated with creosote and pentachlorophenol with respect to metal by-products are small relative to that for CCA. Management options chosen for discarded wood should consider the anticipated increases in metal by-products due to increased quantities of CCA-treated wood waste. Furthermore, the increase in CCA-treated wood waste will make discarded wood more difficult to manage. Products treated with creosote and pentachlorophenol are more easily regulated than wood treated with waterborne preservatives. Creosote- and pentachlorophenol- treated products, such as railroad ties, utility poles, and cross-arms, are generally used exclusively by industry which have more controls placed on their waste stream than wastes produced by the commercial and residential sectors. Even if these products are found within commercial and residential waste, they can be readily recognized because of their dimensions. Rarely is wood of these dimensions untreated. Therefore, if the disposal sector requires separate handling for creosote- and pentachlorophenol- treated wood waste, implementation can be accomplished through industrial waste regulations and through sorting poles and ties from other waste streams. What sets CCA apart from creosote- and pentachlorophenol-treated products is that CCA is used to treat products that have a considerable "clean" market. In other words, CCA is used to treat significant quantities of lumber, timbers, and plywood. Lumber, timbers, and plywood have uses within industrial, commercial, and residential sectors. Furthermore, these products also have a considerable market if untreated. Therefore, once CCA-treated wood is disposed, it is likely mixed with clean wood and this mixture is essentially found within all waste streams. Control of CCA-treated wood waste is much more difficult because its widespread use and because treated wood wastes can not be easily distinguished from clean products. The disposal sector, as a result, will be faced with a wood waste stream which is more difficult to manage and which contains a significantly larger quantity of CCA-treated wood. Methods are needed which enable the disposal sector to effectively handle this anticipated change in the wood waste stream.

46 IV.2 RECOMMENDATIONS

Waste Minimization Reduction of CCA-treated wood within the waste stream can be assured through waste minimization practices. Waste minimization can be accomplished through the use of alternative structural materials, alternative chemical preservatives, and by increasing the service life of CCA- treated wood products. The use of alternative structural materials and chemicals may be promoted on a large scale through procurement processes for public works projects. Procurement procedures should promote environmental preservation as well as economics. Several promising alternative chemicals were discussed in chapter III including, alkaline copper quat, borates, and phytoalexins. ACQ is already produced commercially and its use should be encouraged. Research to improve the economics of other promising chemical alternatives should be also encouraged. Although waste minimization is the most efficient means by which to control the amount of CCA-treated wood found in the waste stream, it is important to consider that a strong demand exists for CCA-treated wood products, especially in Florida. Until economical alternatives are identified for CCA-treated wood products, "disposal-end" management will be the primary means by which to control the ultimate fate of the wood.

Disposal-End Management The amount of CCA-treated wood that enters the wood fuel stream should be regulated such that the resultant ash does not exceed TCLP criteria. Earlier studies indicate that for values greater than roughly 2 to 3% CCA-treated wood by weight, the ash from combusted wood will likely be hazardous according to TCLP criteria. A wood mixture study should be implemented to determine a precise value for mixtures of CCA-treated wood with other wood types such that TCLP limits are not exceeded. This task is included within the research team's second year study.

Furthermore, efforts should focus on sorting C&D wastes. C&D waste is currently managed in Florida via two primary means. The traditional method of disposal is by landfilling. New regulations increasing requirements of such facilities, and existing stringent regulations in a number of counties, has resulted in the growth of C&D recycling. C&D recycling facilities typically accept mixed loads of C&D waste, and separate the materials by a combination of manual and mechanical means. C&D recycling facilities are typically required to remove the majority of CCA-treated wood from the "clean" wood sold to recycling markets. The primary market for wood recovered from C&D recycling operations in Florida is as fuel in industrial combustion units. The amount of CCA-treated wood in the fuel stream these industries accept is often required to be less than a specified level (e.g. 1%). Results have shown however, that the fraction of CCA-treated wood collected from C&D processing facilities around Florida is significantly higher than 1% on average. No given type or standard retention is defined, and it is extremely difficult to police this policy. Other than separation of large readily recognizable wood products, sorting of CCA-treated wood from other wood types is almost non-existent at C&D recycling facilities. Technologies do exist which can be used by the wood disposal sector for sorting purposes. These technologies, which are used widely by the wood treatment industry to test chemical retention levels, should be tested on wood waste. If results are positive, these sorting technologies should be promoted among the disposal sector. Our second year study investigates two potential sorting technologies.

47 Once CCA-treated wood is sorted from the remaining wood waste stream, it must be either reused, recycled, or ultimately disposed. There is currently a demand for CCA-treated wood waste for residential landscaping and for agricultural fencing. It is recommended that large users of CCA-treated wood (such as electric and telephone utilities) advertise the availability of the material through waste exchange programs such as the Southern Waste Information Exchange (1- 800-441-SWIX) to promote reuse of the material. Furthermore, it is recommended that centralized facilities be established for accepting CCA-treated wood waste from C&D recycling operations. At these centralized facilities, the wood can be re-distributed to potential users or can be disposed in a controlled manner. To facilitate the collection of CCA-treated wood from residential users it is recommended that a pamphlet be developed that informs users about proper disposal practices for the wood and about locations where the discarded CCA-treated wood will be accepted. These pamphlets should be distributed along with EPA's Consumer Information Sheets to individuals purchasing CCA-treated wood in Florida. One of the most promising recycling alternatives for CCA-treated wood waste are wood cement composites. The advantages of this alternative are: a) the stabilization of metals within the cement matrix, and b) the production of this composite material may economical for special applications requiring both a fire-resistant and light-weight material. Markets for wood cement composite materials should be investigated further. Disposal of CCA-treated wood via incineration should also be considered as a means for volume reduction and energy recovery as long as the combustion process is carefully controlled, emissions are properly handled, and the ash is disposed in an environmentally sound manner. Furthermore, studies have shown that the ash from CCA-treated wood contains between 5 to 15% chromium, copper, and arsenic, by weight. Given that the metals content in the ash is high, there may be opportunities for removing the metals in a concentrated form for recycling purposes. Research is needed to determine whether the metals can be extracted from the wood ash. Such an extraction, if successful, may open new opportunities for treating wood ash and recycling the CCA chemical.

48 IV.3 CONCLUSION

As a structural material, wood has many positive and unique characteristics. One major disadvantage of wood however is that it is subject to decay by insects and fungi. This disadvantage is especially detrimental when the wood is utilized outdoors, especially in areas of warm and humid climate such as Florida. To overcome this disadvantage, chemical preservatives are added to wood. These preservatives act as pesticides and fungicides, thereby protecting wood. Disposal of treated wood, however, also includes the disposal of the preservative chemicals found in them. The point at which the disadvantages of treated wood outweigh its advantages is not exactly known. However, what is known is that there is currently a high demand for treated wood products, and especially CCA-treated wood, in Florida. The demand for this product will continue until economical alternatives are found. This wood will continue to be found within the wood waste stream for years to come with quantities increasing significantly in the future. Current management practices for CCA-treated wood will not be acceptable in the near future. Combustion of the treated wood waste with other clean wood results in high metals concentrations in the ash. The quality of the combined ash is questionable at this time. Nevertheless it is anticipated that ash quality will degrade further resulting in a material that would be classified as hazardous according to toxicity criteria as defined through RCRA. The research team recommends several alternatives for improving the management of CCA-treated wood waste. These alternatives are outlined in section IV.2 and include improved sorting at C&D recycling facilities and improved methods for handling the waste upon disposal. Our second year research which investigates sorting and ash treatment technologies represents a next step in attaining this goal.

49 IV.4 ACKNOWLEDGMENTS

This research was funded by the Florida Center for Solid and Hazardous Waste Management. The authors acknowledge the Executive Director of the Center, Mr. John Schert, and his staff for their suggestions and for their assistance with information dissemination. The authors also thank the following members of the Technical Advisory Committee for their feedback throughout the course of the project: Kathy Anderson of the Florida Department of Environmental Protection, Kevin Archer of Chemical Specialties Inc., Lee Casey of Metro-Dade County Department of Solid Waste Management, Kenneth Cogan of Hickson Corporation, Keith Drescher of Florida Power and Light, Jeffrey Fehrs of C.T. Donovan and Associates, Bill Gay of Langdale Forest Products, George Parris of the American Wood Preservers' Institute, Mike Provenza of Robbins Manufacturing, Chih-Shin Shieh of the Florida Institute of Technology, Donald Surrency of Koppers Industries, David Stephenson of the Southeastern Regional Biomass Energy Program, August Staats of Osmose Wood Preserving, and George Varn Jr. of Varn Wood Products.

50 REFERENCES APWI, 1995 and 1996. Preserving Industry Production Statistical Reports. AWPI, Fairfax, VA.

Atkins, R.S. and Fehrs, J.E., 1992. Wood Products in the Waste Stream: Characterization and Combustion Emissions. Energy Authority, Report 92-8, Vol. 1. New York State Energy Research and Development Authority, New York.

AWPA, 1965 to 1975. Proceedings of the American Wood Preservers Association, AWPA, Granbury, TX.

AWPA, 1996. Standards. American Wood-Preservers' Association, Granbury, TX.

Burton, R., Begervoet, T., Naheri, K., Vinden, P., and Page, D., 1990. Gaseous Preservative Treatment of Wood. Paper prepared for the 21st Annual Meeting of the International Research Group on Wood Preservation, Rotorua, New Zealand.

Campbell, A.G., Folk, R.L., and Tripepi, R.R., 1997. "Wood ash as an amendment in municipal sludge and yard waste composting processes." Compost Science and Utilization (5): 62-73.

Cooper, P.A., 1993. "Disposal of treated wood removed from service: the issues." Proceedings of the Carolinas-Chesapeake Section of the Forest Products Society. Presented at the May 13, 1993 meeting on Environmental Considerations in the Use of Pressure- TreatedWood Products. Published by the Forest Products Society, Madison, WI.

C.T. Donovan Associates, Inc., 1994. A Sourcebook on Wood Waste Recovery and Recycling in the Southeast. Southeastern Regional Biomass Energy Program, Muscle Shoals, Alabama.

Donovan, C.T. and Fehrs, J.E., 1993. Environmental Issues: New techniques for Managing and Using Wood Fuel Ash. C.T. Donovan Associates, Inc., Burlington, VT.

Fahy, C., Glitten, M., Orcult, M., and Wallace, T. 1993. Spent Pressure Treated Wood: An Analysis of Management Options. Tufts University, Medford, MA.

Fehrs, J.E., 1995. Air Emissions and Ash Disposal at Wood-burning Facilities. C.T. Donovan Associates, Inc., Burlington, VT.

Fehrs, J.E. and Donovan, C.T. 1996. "Ash from the combustion of treated wood: characteristics and management options." Proceedings of the Second Biomass Conference of the Americas: Energy, Environment, , and Industry, p. 120-129.

Felton, C., and De Groot, R.C., 1996. "The recycling potential of preservative treated wood." Forest Products Journal, 46(7/8): 37-46.

Florida Administrative Code, 1995. Section 62-702, Solid Waste Combustor Ash Management; Section 62-256, Open Burning and Frost Protection Fires.

51 Florida Department of Environmental Protection, 1995. Solid Waste Management in Florida. Fl. DEP, Bureau of Solid and Hazardous Waste, Tallahassee, Florida.

Florida Department of Environmental Protection, 1997. Solid Waste Management in Florida. Fl. DEP, Bureau of Solid and Hazardous Waste, Tallahassee, Florida.

Gaba, J.M. and Stever, D.W., 1995. Law of Solid Waste Pollution Prevention and Recycling. Clark Boardman Callaghan/Thomas Legal Publishing, Inc.

Gifford, J.S., Marvin, N.A., and Dare, P.H., 1997. Composition of Leachate From Field Lysimeters Containing CCA Treated Wood. American Wood-Preservers' Association, p. 292-306.

Gunzburger, G., 1991. Technical Properties of Plastic Lumber. BTW Products Publication, Pembroke Florida, p. 369-380.

Gutzmer, D.I., and Crawford, D.M., 1995. Comparison of Wood Preservatives in Stake Tests, 1995 Progress Report. U.S. Department of Agriculture, Forest Products Laboratory, Madison,Wisconsin. FPL-RN-02.

Lide, D.R. (ed.) 1992. Handbook of Chemistry and Physics, 72nd Edition. CRC Press, Boca Raton, FL.

McGinnis, G., 1995. Wood Ash in the Great Lakes region: Production, characteristics, and Regulation, McGinnis Institute of Wood Research, Houghton, Michigan.

McKeever, D.B.,1998. "Wood residual quantities in the United States." Biocycle: January edition.

Metro Waste Authority. 1992. Guide Book to Managing Construction and Demolition Debris.

Milton, F.T., 1995. The Preservation of Wood. Minnesota Extension Service, University of Minnesota College of Natural Resources.

Moran, L., personal communication, March 1997. Ms. Moran is an information services coordinator for the Southern Forest Products Association. Her mailing address is: P.O. Box 641700, Kenner, Louisiana 70064-1700.

Moslemi, A.A., 1988. "Inorganically bonded wood composites." Chemtech, August: p. 504- 510.

National Association of Home Builders. 1995. Residential Construction Waste Management a Builder’s Field Guide.

52 Nunes, L., Dickenson, D.J., and Murphy, R.J., 1995. Volatile Borates in the Treatment of Wood and Wood Based Panel Products Against Subterranean Termites. Paper prepared for the 26thAnnual Meeting of the International Research Group on Wood Preservation, Helsingor, Denmark.

Penha, J., 1998. CCA Treated Wood: Generation and Disposal Quantities in Florida and Available Management Options. Master of Science Thesis, University of Miami.

Random Lengths, 1997. The 1997 Big Book. Random Lengths Publications Inc., Eugene, Oregon.

Schmidt, R., March, R., Balantinecz, and Cooper, P.A., 1994. "Increased wood-cement compatibility of chromated treated wood." Forest Products Journal, 44(7/8): 44-46.

Smith, R.L. and Shiau, R., 1997. Steam Processing of Treated Waste Wood for CCA Removal. Technical Report published by the Center for Forest Products Marketing, Virginia Tech, Blacksburg, VA.

Smith, R.L., and Shiau, R., 1998. "An industry evaluation on the reuse, recycling, and reduction of spent CCA wood products." Forest Products Journal (48/2) (in press)

Solo-Gabriele, H.M., Townsend, T., Penha, J., Tolaymat, T., and Calitu, V., 1997. "Generation, use, disposal, and management options for CCA-treated wood." Proceedings of the fifth Annual Research Symposium of the Florida Center for Solid and Hazardous Waste, Tampa, FL. Report #S97-13. p. 41-48.

Turner, P., Murphy, R.J., Dickinson, D.J., 1990. Treatment of Wood Based Panel Products with Volatile Borates. Paper prepared for the 21st Annual Meeting of the International Research Group on Wood Preservation, Rotorua, New Zealand.

Vick, C.B., Geimer, R.L., and Wood, J.E., 1996. "Flakeboards from recycled CCA treated southern pine lumber." Forest Products Journal, 46(11/12): 89-91.

U.S. EPA. Toxic Release Inventory Database. Available through the internet: http://www.epa.gov/enviro/html/tris/tris_query.html SIC Code 2491. Database accessed May 1997.

U.S. EPA, 1994. Test Methods for Evaluating Solid Wastes, SW-846: Method No. 7190, Chromium (Atomic Absorption, Direct Aspiration), Method 7210, ?Copper (Atomic Absorption, Direct Aspiration), and Method 3050B, Acid Digestion of Sediments, Sludges, and Soils. U.S. EPA, Washington, D.C.

U.S. EPA, 1995. Construction and Demolition Waste Landfills, Draft Report. Washington D.C., PB95-208906. 530-R-95-018.

U.S. EPA, 1996. Federal Register, 40 CFR Part 503. Washington, DC.

53 Vance, E.D., 1996. "Land Application of wood-fired and combination boiler ashes: an overview." Journal of Environmental Quality (25/5).

Webb, D.A., and Davis, D.E., 1993. Spent Treated Wood Products: Alternatives and Their Reuse or Recyclability. Presented at the 47th Annual Meeting of the Forest Products Society, Clearwater, FL.

______, 1997. "Woody material recycling, recovering treated lumber." Biocycle, July: 34-37.

54 APPENDIX A: WOOD TREATERS AND WOOD TREATER QUESTIONNAIRE

A-1 Table A-1: Wood Treatment Plants Located in Florida

COMPANY MAILING CITY ST ZIP TELEPHONE ADDRESS CODE NUMBER 1 Aljoma Lumber Inc. 10300 N.W. 121 Way Medley FL 33152 (305) 556-8003 Plant Manager: Juan Moran 2 Anchor Wood Treating 3670 NW 79th St. Miami FL 33147 (305) 691-7711 Plant Manager: Jorge DeFema 3 Apalachee Pole Company P.O. Box 610 Bristol FL 32440 (904) 643-2121 Plant Manager : David Powell 4 Arnold Lumber Company Rt 1 Box 260 Bonifay FL 32425 (304) 547 - 5733 Plant Manger: Chris Jernigan 5 Coastal Lumber Company P.O. Box 1128 Havanna FL 32333 (904) 539-6432 Vice President: Bill Harlod P.O. Box 829 Weldon NC 27890 6 Cook Lumber & Treating, Inc. 4956 Lantana Road Lake Worth FL 33463 (561) 965 - 1633 Plant Manager: Fred Poston 7 Cook Lumber Company 1905 N. 66th St Tampa FL 33619 (813) 626 - 1411 Plant Manger: Joel Miller 8 Dantzler Lumber & Export Co. P.O. Box 6340 Jacksonville FL 32236 (904) 786 - 0424 Plant Manager: Chuck Galloway 9 E.D. Cook Lumber Company, Inc 5901 Beggs Rd Orlando FL 32810- (407) 293 -1811 Plant Manager: Harry Arolan -2609 10 Florida Fence Post Company P.O. Box 645 Ona FL 33865 (941) 735 - 1361 Office Manager: Linda Kiella 11 Florida Perma-Wood Treaters 4500 E. 11TH Ave. Hialeah FL 33013 (305) 685 - 7833 President: Stephen Rose 12 Great Southern Wood Preservers P.O. Box 759 Bushnell FL 33513 (352) 793 - 9410 General Manager: Jimmy Harris 13 Koppers Industries P.O. Box 1067 Gainesville FL 32602 (352) 376 - 5144 Manager: Don Surrency 200 N.W. 23rd Ave. 32609 14 Longleaf Forest Products, Inc. 1325 Yorktown St. Deland FL 32724 (904) 734 - 5161 President: Robert Wheeler 15 Ocala Lumber SaLes Co P.O. Box 1389 Ocala FL 34478- (352) 732 - 0167 Owner: Henry Moxon -1389 16 Pensacola Wood Treating 1813 East Gadster Pensacola FL 32501 (904) 433 - 1300 Plant Manager: Neil McMillan 17 Pride of Florida/Union Forestry P.O. Box 308 Raiford FL 32083 (904) 431 - 1912 Production Manager: Stan Lehman 18 Ridge Lumber & Treating Co P.O. Box 1651 Lakeland FL 33802- (941) 665 - General Manager: Pat Smith -1651 6311 19 Robbins Manufacturing Company 13001N.Nebraska Tampa FL 33612 (813) 971 - 3030 Plant Manager: Mike Provenza Ave. 1-800-282-9336

20 Robbins Manufacturing Company 3250 Metro Parkway Ft Myers FL 33916 (813) 334 - 2219 21 Robbins Manufacturing Company 7205 Rose Avenue Orlando FL 32810 (407) 293 - 0321

A-2 Table A-1 (con'd): Wood Treatment Plants Located in Florida

COMPANY MAILING CITY ST ZIP TELEPHONE ADDRESS CODE NUMBER 22 Southeast Wood Treating, Inc P.O. Box 561227 Rockledge FL 32956 (407) 631 - 1003 Plant Manger: Jerry Lindsey 23 Southern Lumber & Treating Co P.O. Box 7450 Jacksonville FL 32238 (904) 695 - 0784 Plant Manager: Robert Stovall 24 Sunbelt Forest Products P.O. Box 1218 Bartow FL 33830 (941) 534 - 1702 Plant Manager: Ken Delle Donne 25 Suwannee Lumber Mfg. Company P.O. Drawer 5090 Cross City FL 32628- (352) 498-3364 Plant Manager: Lee Childers -5090 26 Universal Forest Products, Inc P.O. Box 217 Auburndale FL 33823- (941) 965 - 2566 Plant Manager: Jon Scharfenberg -0217 27 Wood Treaters, Inc. P.O. Box 41604 Jacksonville FL 32203- (904) 358 - 2507 President: Stan Hill -1604

A-3 Table A-2: Wood Treatment Plants Located Within 150 miles of Florida (Alabama Plants)

COMPANY MAILING CITY ST ZIP TELEPHONE ADDRESS CODE NUMBER 1 Alabama-Georgia Preserving P.O. Drawer 9 Lafayette AL 36862 (334)864-9303 President: W.C. Brinson III (800)821-0755 F(334)864-0158 2 Baldwin Pole & Piling Company P.O Box Bay Minette AL 36507 - (334) 937 - 2141 Plant Manager: Tom Mcmillian Drawer 758 0758 3 Centreville Lumber Co. P.O. Box 94 Vance AL 35042 (205) 926 - 4606 Plant Manager : Russ Griffin 4 Everwood Treating Co., Inc. P.O Box 7500 Spanish Fort AL 36577 (334) 626 - 2080 Plant Manager: Jar Hudson 5 Great Southern Wood Preserving, P.O. Box 610 Abbeville AL 36310 (334) 585 - 2291 Inc. Plant Manager: Mitchell Weaver Ast. Plant Manager:Bryan Newman 6 Great Southern Wood Preserving, P.O. Box 987 Theodore AL 36590 (334) 438 - 6842 Inc. 7 Gulf Treating Co., Inc. P.O. Box 1663 Mobile AL 36633 (334) 457 - 6872 Plant Manager: Romean Upshaw 8 Kopper Industries P.O. Box 510 Montgomery AL 36101 (334) 834 - 5290 Plant Manager: Bill Hasley Ast. Plant Manager: Ed Davidson 9 Lee Lumber Co. P.O. Box 416 Centreville AL 35042 (205) 926 -9717 Owner: Don Lee 10 Louisiana - Pacific Corporation P.O. Box 388 Lockhart AL 36455 Plant Manager: Roy Ezell 11 Louisiana - Pacific Corporation P.O. Box 726 Evergreen AL 36401 12 Olon Belcher Lumber Co., Inc. P.O. Box 160 Brent AL 35034 (205)926-4666 General Manager: Brent Belcher F(205)926-4666 (near Centreville) 13 Stallworth Timber Co., Inc. P.O. Box 38 Beatrice AL 36425 (334) 789 - 2151 Plant Manager: Bill Black [email protected] (near Greensboro) 14 Southeast Wood Treating, Inc. P.O. Box 25 Louisville AL 36048 15 Swift Lumber, Inc. P.O. Box Atmore AL 36504 (334) 368 - 8800 Plant Manager: Dwight Grant Drawer 1298 16 T.R. Miller Mill Co., Inc. P.O. Box 708 Brewton AL 36427 (334) 867 - 4331 Plant Manager: James McGougin cdc.net/sprimus/trim/ (800) 633 - 6740 17 Walker - Williams Lumber Co., Inc. P.O. Box 170 Hatchechubbee AL 36858 (334) 667 - 7736 Plant Manager: Bobby Walker (800) 727 - 9007 (near Hurtsboro) 18 Willamina Lumber Hwy 219 Centreville AL 35042 (205) 926 - 4605 Plant Manager: Russ Griffin

A-4 Table A-3: Wood Treatment Plants Located Within 150 miles of Florida (Georgia Plants)

COMPANY MAILING CITY ST ZIP TELEPHONE ADDRESS CODE NUMBER 1 Ace Pole Company 6352 Blackshear GA 31516 (912) 449 - 4011 Plant Manager: C.M. Eunice Timberlane Ast. Plant Manager: Harold Flyod 2 Atlantic Wood Industries, Inc. P.O. Box 1608 Savannah GA 31402 - (912) 964 - 1234 Plant Manger: J. Frank Cliett 1608 3 Atlantic Wood Industries, Inc. P.O. Box 384 Vidalia GA 30474-0384 (912) 537-4188 Plant Manager: Guy Haltom 4 B & M Wood Products Inc. P.O Box 176 Manor GA 31550 (912) 283 - 0353 Plant Manager: Jim Stovall Rt. 1 (800) 451 - 0385 5 Baxley Creosoting Company P.O. Box 459 Baxley GA 31513 (912) 367 - 4646 Plant Manager: Lowton Morris 6 Cook County Wood Preserving P.O Box 637 Adel GA 31620 (912) 896 -4357 Plant Manager: David Sorrell 7 D & D Wood Preserving, Inc. P.O. Box 1802 Albany GA 31702 (912) 436 - 2638 Plant Manager: Russel Davis 8 Georgia - Pacific Corp. P.O. Box 668 Brunswick GA 31521 (912) 261-2974 Plant Manager: Carter Ramsey 9 Georgia - Pacific Corp. P.O. Box 799 Pearson GA 31642 (912)422-3247 Plant Supt: Stanley Wall F(912)422-7749 10 Langdale Forest Products Co. P.O. Box 1088 Valdosta GA 31603 (912) 333 - 2513 Plant Manager: Jim Langdale 11 Louisana - Pacific Corp. P.O. Box 130 Statesboro GA 30459 (912) 681 - 2048 Plant Manager: Bobby Whittington 12 Manor Timber Co., Inc. RTE #1 Box Manor GA 31550 - (912) 487 - 2621 Plant Manager: William F. 60 9601 Peagler 13 Mellco, Inc. P.O. Drawer C Perry GA 31069 (800)866-1414 Plant Manager: Matt Corwart (912)987-5040 F(912)987-7932 14 Pidemont Building Products 441 Dunbar Warner GA 31093 (912)328-6597 Manager: Neal Holbrook Rd Robins F(912)328-6697 15 Savannah Wood Preserving Co., 501 Stiles Ave Savannah GA 31401 - (912) 236 - 4875 Inc. 32141 (800) 847 - 9663 Plant Manager: Herb Gurry 16 Shearouse Lumber Company P.O. Drawer C Pooler GA 31322 (912) 748 - 7244 Plant Manger: Jack Shearouse 17 Tolleson Lumber Co., Inc. P.O. Drawer E Perry GA 31069 (800)768-2105 General Manager: Joe Kusar (912)987-2105 F(912)987-0160 18 Universal Forest Products, Inc. P.O. Box 2487 Moultrie GA 31776 (912)985-8066 Sr. Vice Pres.: Jim Ward F(912)890-1207 19 Varn Wood Products, Co. P.O. Box 128 Hoboken GA 31542-0128 (912)458-2187 General Mngr: Thomas Shave F(912)458-2190 Plant Manager: Mr. Varn

A-5 Table A-4: Wood Treatment Plants Located Within 150 miles of Florida (Mississippi Plants)

COMPANY MAILING CITY ST ZIP TELEPHONE ADDRESS CODE NUMBER 1 American Wood P.O. Box 1532 Richton M 39476 (601)788-6564 General Mgr: Larry Polk Hwy. 15 N S 2 Desoto Treated Material, Inc. P.O. Box 460 Wiggins M 39577 (601) 928 - 5092 Plant Mgr: Steve Owen S 3 International Paper P.O. Box 37 Wiggins M 39577 (601) 928-0176 Plant Mgr: Howard S Hamilton 4 Laurel Lumber Co., Inc. P.O. Box 4178 Laurel M 39441- (601)649-7696 President: Wayne Parker S 4178 Sales Mgr: Billy Ryals 5 Southern Pine Wood P.O. Box 818 Picayune M 39466 (601)798-8152 Preserving S (800)367-0461 Vice Pres/Sales Mgr: Gina F(601)798-8196 Maddalozzo 6 Southern Wood Preserving P.O. Box 630 Hattiesburg M 39403 (601)544-1140 of Hattiesburg, Inc. S (800)844-1140 Plant Mgr: Joe Hartfield F(601)544-1147 7 Treated Materials Co., Inc. P.O. Box 2848 Gulfport M 39503 (601) 896 - 5056 Owner: Bill Randal 13334 Seaway S (800) 748 - 8548 Rd. 8 Tri State Pole & Piling P.O. Box 166 Lucedale M 39452 (601) 947 - 4285 Vice President: Bill Harlod S F(601) 947 - 4286

A-6 SAMPLE COVER LETTER FOR WOOD TREATER QUESTIONNAIRE

DATE

Address XXX

Dear XX,

It was a pleasure speaking with you earlier this afternoon. During our telephone conversation I mentioned that the University of Miami in collaboration with the University of Florida is conducting research to determine the amounts of pressure treated wood sold within the State of Florida. Specifically, our focus is on wood treated with waterborne preservatives such as CCA, ACA, ACZA, ACQ, and ACC. The ultimate objective of this research is to forecast the quantities of pressure-treated wood that will be disposed over time and to evaluate alternatives for the management of this discarded wood. Our intent is to promote the economic viability of the wood treatment industry while assuring that discarded wood is properly handled. We request your assistance in conducting this research by completing the enclosed questionnaire. This questionnaire has been distributed to all wood treaters within the State of Florida as well as those located in southern Georgia, Alabama, and Mississippi. The purpose of the questionnaire is to determine the amount, types, and uses of waterborne preservatives in the State of Florida. Data pertaining to individual companies will be kept confidential. The responses from all the wood treaters will be totaled and only these totals will be reported from this research. This questionnaire is not an industry survey although it has received the support of the American Wood Preserver's Institute (AWPI). If you would like to speak to a representative from AWPI concerning this questionnaire, you may call Dr. George Parris at (703)204-0500. Again we would greatly appreciate your organization's cooperation with this research by completing the enclosed questionnaire and mailing it in the attached self-addressed envelope. The results of our research will be available to your organization if desired. Please mark the appropriate box on the questionnaire if you would like a copy of our final report summarizing the total quantities of waterborne wood preservatives imported into Florida. If you need to contact me, please call (305)284-3489 or write to the address included on the return envelope.

Sincerely,

Helena Solo-Gabriele, Ph.D.,P.E. Assistant Professor cc: Dr. Timothy Townsend, Univ. of Florida

A-7 Page 1

Pressure Treated Wood Using Waterborne Preservatives, Statistics For Florida

Questionnaire Distributed by the University of Miami in Collaboration with the University of Florida

Completing this questionnaire is a voluntary service. Individual treating companies have no obligations to complete the enclosed form. However, we would appreciate your organizations' participation by completing as much of the survey as possible and mailing it in the self-addressed envelope provided.

A-8 Page 2

Purpose: This questionnaire addresses the treatment of wood products utilizing waterborne wood preservatives such as CCA, ACA, ACC, ACQ, and ACZA. If your organization does not treat wood with waterborne preservatives, check here 9 then fill out the company information and return in the enclosed envelope.

Part A - Company Information

1. Company Headquarters Name: ______

2. Plant Information

Name of Treating Plant:______

Plant Contact, Person's Name:______

Address:______

City:______State:______Zip Code:______

Phone Number with area code: ______

Fax Number with area code: ______

3. Is the company headquarters address the same as this plant address? 9 Yes 9 No

4. During what years has this plant operated? ______

5. Did this plant treat wood in 1996? 9 Yes 9 No If the plant was idle in 1996, do you intend to resume operations? 9 Yes 9 No If yes, when ?______

6. Are any of the waterborne wood products produced by your company sold within Florida? 9 Yes 9 No If yes, what fraction? ______

7. Would you like to receive a copy of the results from this survey? 9 Yes 9 No

A-9 Page 3 Part B - Chemical Information

1. We would prefer chemical information that corresponds to products sold in Florida. However, if the distribution is unknown, please provide values for the total plant production.

Values within this section correspond to: 9 total products generated by the plant 9 only those products sold in Florida

2. List the volume of chemical used in 1996.

Waterborne Preservatives Amount Used (pounds, oxide basis, dry)

CCA (chromated copper arsenate) ______

ACA (ammoniacal copper arsenate) ______

ACC (acid copper chromate) ______

ACQ (ammoniacal copper quat) ______

ACZA (ammoniacal copper zinc arsenate) ______

Other waterborne (specify) ______

3. What type5 of CCA is used to pressure treat wood? Please indicate the percentage of the total CCA used by your company.

9 Type A ______% 9 Type B ______% 9 Type C ______% 9 Other (specify) ______%

5Compositions of CCA CCA-Type A CCA-Type B CCA-Type C Chromium 65.5% 35.3% 47.5% Copper 18.1% 19.6% 18.5% Arsenic 16.4% 45.1% 34.0%

A-10 Page 4 Part B - Chemical Information (con'd)

4. What are the retention values for waterborne preservatives used at your plant. Please check appropriate retention value and indicate amount used if available.

CCA Retention Value Amount Used (pound/ft3) (pounds, oxide basis, dry)

9 0.25 ______9 0.40 ______9 0.60 ______9 0.80 ______9 2.50 ______

Other Waterborne Preservative (specify)______

Retention Value Amount Used (pound/ft3) (pounds, oxide basis, dry)

9 0.25 ______9 0.40 ______9 0.60 ______9 0.80 ______9 2.50 ______

Part C - Treating Plant Information

Equipment Used for waterborne preservatives: Check the appropriate box(es).

Cylinder Number #1 #2 #3 #4 #5 #6 #7

Diameter(inches) ______

Length (feet) ______

A-11 Page 5 Part D - Wood Products

1. Total Cubic Feet of waterborne wood products that your company produced ______. Of this amount, how much was distributed within Florida______.

2. What kind of wood is treated using waterborne preservatives at your plant? Please check appropriate box and indicate estimated percentage of total, if available.

9 Southern Yellow Pine ______% 9 ______% 9 Mixed Hardwoods ______% 9 Douglas Fir ______% 9 Other (specify) ______% ______% ______%

Values above correspond to: 9 total products generated by the plant 9 only those products sold in Florida

3. Which waterborne wood products are sold by your company? Please check appropriate box.

9 Lumber6 9 Agricultural Stakes 9 Timbers7 9 Crossarms 9 Crossties 9 Decorative 9 Fence Posts 9 Furniture 9 Poles (utility) 9 Guardrail Posts 9 Poles (building) 9 Highway Posts 9 Piling (marine) 9 Landscape Timbers 9 Piling (other) 9 Mine Ties & Timbers 9 Plywood 9 Other (specify) ______

Please circle the categories for products that are sold within Florida.

Thank you for completing the survey. Please mail survey in the self addressed envelope provided.

6Lumber = sawn products whose least dimension is less than 5 inches (e.g. 2 x 10, 3 x 8)

7Timbers = sawn products whose least dimension is 5 inches or more (e.g. 5 x 7, 6 x 8)

A-12 APPENDIX B: STATISTICS FOR THE WOOD TREATMENT INDUSTRY

B-1 Table B-1: Number of Plants, N, and Void Volumes of Treating Equipment, V.

Number1of Treating Plants Utilizing Void Volume2 For Plants Treating with Year Waterborne Preservatives, N Waterborne Preservatives, V (1000 ft3) Florida SE Region U.S. Florida SE Region U.S. 1964 17 72 128 20 105 233 1965 20 94 162 19 123 258 1966 20 62 151 26 91 255 1967 20 65 159 26 91 268 1968 20 66 161 26 95 275 1969 20 66 162 26 95 275 1970 20 67 165 26 96 279 1971 21 68 171 26 97 284 1972 22 72 182 27 113 310 1973 22 73 190 27 117 323 1974 22 73 194 27 117 335 1975 22 73 195 27 117 336 1976 22 75 202 27 120 351 1977 22 78 211 27 124 363 1978 22 81 214 27 129 365 1979 22 81 216 27 129 366 1980 22 84 226 27 133 380 1981 17 70 195 19 116 337 1982 NR3 NR NR NR NR NR 1983 19 75 213 35 198 487 1984 19 75 213 35 198 487 1985 21 87 237 53 256 561 1986 21 87 242 56 276 662 1987 16 63 180 38 207 598 1988 17 60 177 39 203 590 1989 NR NR 473 NR NR NR 1990 NR 147 458 NR NR NR 1991 NR 140 445 NR NR NR 1992 NR NR 460 NR NR NR 1993 25 136 404 42 229 682 1994 NR 188 583 42 229 682 1995 25 148 486 43 234 696 1996 NR 146 465 NR NR NR 1Number of plants determined directly from statistical reports. 2Some assumptions were necessary for determining void volumes. Specifically, for treating plants that utilized other types of preservatives in addition to waterborne preservatives, the void volume was determined as: "total void volume for the plant divided by the number of different treatment chemicals utilized." 3No Record Available.

B-2 Table B-2: Production of CCA-Treated Wood and Quantity of Chemical Utilized.

Production of CCA-TreatedWood, Quantity of Chemical Utilized, Ave. 3 Year million ft million pounds Retention 3 1 2 2 1 2 2 Value , Florida SE Region U.S. Florida SE Region U.S. Florida (lb/ft3) 1964 0.5 2.5 5.4 Less than 0.1 0.2 0.9 0.09 1965 0.6 3.6 7.6 0.1 0.8 1.2 0.22 1966 1.4 5.0 14.0 0.1 0.5 1.2 0.10 1967 1.2 4.3 12.7 0.3 1.0 1.9 0.23 1968 1.3 4.9 14.0 0.5 1.9 3.2 0.39 1969 1.8 6.7 19.2 0.7 2.7 4.7 0.41 1970 2.0 7.2 22.6 0.9 3.3 6.1 0.46 1971 1.8 6.8 20.1 1.7 6.4 8.6 0.93 1972 2.1 8.9 25.6 1.4 5.8 9.7 0.65 1973 2.3 10.2 29.4 1.5 6.5 11.7 0.64 1974 3.1 13.7 41.1 1.5 6.5 15.3 0.48 1975 2.4 10.4 29.9 1.4 6.0 15.9 0.57 1976 2.4 15.3 44.8 1.6 7.4 17.1 0.69 1977 3.1 14.5 42.7 1.9 8.8 24.8 0.60 1978 4.6 22.0 62.3 2.2 10.5 25.0 0.48 1979 7.0 33.6 95.7 3.7 17.7 33.8 0.53 1980 7.8 38.9 111.0 3.6 17.8 36.2 0.46 1981 7.2 45.4 131.3 4.0 25.0 46.4 0.55 1982 NR5 NR NR NR NR NR 1983 17.7 99.8 245.3 6.1 34.4 63.7 0.34 1984 20.9 117.8 289.6 7.8 44.1 81.6 0.37 1985 30.2 146.7 321.1 8.9 43.0 100.0 0.29 1986 31.0 153.3 367.6 10.1 49.8 115.8 0.32 1987 26.4 143.6 414.6 9.2 50.4 122.9 0.35 1988 29.1 152.7 444.7 9.7 50.9 129.6 0.33 1989 NR NR NR NR NR NR 1990 NR 135.2 341.0 8.9 NR 118.2 1991 NR 131.0 323.1 8.6 NR 114.6 1992 NR NR NR NR NR NR 1993 29.3 159.2 461.1 8.1 44.34 131.6 0.28 1994 41.7 226.8 467.1 8.3 44.94 133.4 0.20 1995 NR 177.2 441.6 NR 49.94 138.5 1996 NR 167.8 458.5 NR 52.04 144.5 1Values have been computed based on void volume 2Values have been taken directly from statistical reports 3Computed from available data 4Values have been calculated by assuming that CCA represents 98% of the total waterborne preservatives. 5Not Recorded.

B-3 Table B-3: Production of Wood Treated With Waterborne Preservatives and Quantity of Chemical Utilized.

Production of Wood Treated with Quantity of Chemical1 Utilized, Ave. Year Waterborne Preservatives, million pounds Retention million ft3 Value4, Florida2 SE Region3 U.S.3 Florida2 SE Region3 U.S.3 Florida (lb/ft3)

1964 1.9 10.3 22.7 1.1 5.9 10.3 0.6 1965 1.9 12.4 25.9 1.1 7.1 12.1 0.6 1966 3.3 11.5 32.5 1.6 5.5 12.6 0.5 1967 2.9 10.2 30.1 1.3 4.4 11.2 0.4 1968 2.5 9.1 26.2 1.3 4.7 10.7 0.5 1969 2.9 10.5 30.1 1.4 5.0 12.0 0.5 1970 2.8 10.2 29.7 1.4 4.9 10.8 0.5 1971 3.3 12.3 36.0 2.0 7.5 13.1 0.6 1972 3.5 12.1 41.2 1.8 7.7 13.3 0.5 1973 3.6 15.9 43.8 1.7 7.5 16.5 0.5 1974 4.3 18.8 53.8 1.7 7.6 20.3 0.4 1975 3.2 13.9 40.0 1.6 6.9 20.4 0.5 1976 4.2 19.1 55.9 1.8 8.0 20.3 0.4 1977 4.2 19.3 56.6 2.0 9.2 27.2 0.5 1978 5.1 24.5 69.5 2.5 12.1 28.5 0.5 1979 7.8 37.8 107.7 3.9 18.9 28.5 0.5 1980 8.9 44.4 126.7 3.8 18.8 37.0 0.4 1981 8.1 51.2 148.3 4.1 25.6 38.5 0.5 1982 NR5 NR NR NR NR NR --- 1983 18.3 103.3 258.2 6.5 36.9 47.9 0.4 1984 24.5 137.8 301.7 8.3 46.8 67.0 0.3 1985 25.4 123.2 328.7 11.6 56.3 85.0 0.5 1986 31.5 155.7 375.5 13.2 65.2 102.4 0.4 1987 31.5 171.8 419.0 9.4 51.0 124.5 0.3 1988 34.1 178.8 450.6 9.8 51.5 131.0 0.3 1989 NR NR NR NR NR NR --- 1990 30.8 157.0 437.7 9.8 47.1 131.3 0.3 1991 29.8 147.1 424.4 9.5 44.1 127.3 0.3 1992 NR NR NR NR NR NR --- 1993 29.9 162.5 470.5 8.3 45.2 134.3 0.3 1994 44.3 241.3 496.9 8.8 47.8 141.9 0.2 1995 32.2 180.8 450.6 9.7 53.0 147.2 1996 NR 171.2 467.9 NR 53.6 148.9 1Includes CCA and other waterborne preservatives. During 1960s and 70s, other significant waterborne preservatives included chromated zinc arsenate, acid copper chromate, chromated zinc chloride, flour chrome arsenate phenol. During the 1990s other waterborne preservatives included acid copper chromate, ammoniacal copper quarternary, and ammoniacal copper zinc arsenate. 2Values have been computed based on void volume. 3Values have been taken directly from statistical reports. 4Computed from available data. 5Not Recorded.

B-4 Table B-4: Production of Wood Treated With Waterborne1 Preservatives, by Product Type. U.S. Statistics Lumber and Poles Crossties Fence Posts Total Year Timber (all products)

106 ft3 % WP 106 ft3 % WP 106 ft3 % WP 106 ft3 % WP 106 ft3 % WP 1964 18.0 38.1 0.2 0.3 0.132 0.2 0.4 2.1 22.7 9.5 1965 20.5 40.9 0.2 0.2 0.166 0.3 0.5 2.8 25.9 10.1 1966 25.6 42.5 0.4 0.5 0.327 0.5 0.7 3.6 32.5 11.5 1967 25.7 41.3 0.6 0.8 0.305 0.4 0.5 2.4 30.1 10.5 1968 21.8 34.8 0.9 1.2 0.113 0.1 0.5 2.7 26.2 9.6 1969 24.3 40.7 2.4 3.2 0.114 0.2 0.5 3.0 30.1 11.8 1970 25.1 44.3 1.8 2.4 0.118 0.2 0.5 3.2 29.7 11.4 1971 26.8 44.9 1.6 2.2 0.140 0.2 0.7 4.0 35.9 13.3 1972 30.3 47.4 1.7 2.3 0.121 0.1 0.9 5.0 41.2 15.1 1973 37.3 54.2 1.9 2.5 0.116 0.2 0.8 5.4 43.8 17.2 1974 45.8 58.9 1.8 2.5 0.029 0.0 2.1 12.3 53.8 19.6 1975 32.6 53.0 1.3 2.6 0.086 0.1 2.0 13.2 40.0 16.4 1976 43.6 64..9 1.4 2.7 0.133 0.1 1.8 13.3 56.0 21.7 1977 42.0 6.8.05 3.7 7.0 0.172 0.2 1.3 12.5 56.6 22.6 1978 54.6 63.6 5.3 8.5 0.375 0.4 2.0 18.0 69.5 24.5 1979 84.7 77.8 6.8 10.0 0.148 0.1 5.8 33.0 107.7 30.6 1980 99.1 84.3 7.9 12.2 0.620 0.7 6.7 39.5 126.7 38.3 1981 112.7 87.3 9.9 15.5 0.706 0.7 7.5 45.5 148.3 42.4 1982 NR2 NR NR NR NR NR NR NR NR NR 1983 221.8 92.5 10.3 15.5 0 0.0 7.7 68.8 258.2 55.0 1984 251.4 93.8 12.0 15.4 0 0.0 7.7 68.8 301.7 57.8 1985 273.8 94.5 13.3 17.3 0 0.0 7.3 74.1 328.7 63.1 1986 314.1 95.1 15.1 20.6 0 0.0 12.5 80.5 375.5 67.0 1987 312.4 96.1 15.5 20.6 0 0.0 8.7 77.7 419.0 72.9 1988 391.1 96.6 14.7 20.7 0 0.0 9.8 79.0 450.6 75.2 1989 NR NR NR NR NR NR NR NR NR NR 1990 366.3 97.5 17.4 23.7 0 0.0 12.5 84.0 437.7 74.7 1991 353.2 97.5 16.6 28.9 0 0.0 81.1 73.6 424.4 75.1 1992 NR NR NR NR NR NR NR NR NR NR 1993 386.1 98.1 20.0 27.9 0 0.0 10.3 75.2 470.5 77.7 1994 250.0 98.7 24.4 39.0 0 0.0 13.4 92.7 496.8 78.3 1995 319.5 98.3 29.2 42.5 0 0.0 18.2 96.9 450.6 77.8 1996 346.0 98.8 24.1 38.0 0 0.0 21.1 90.2 467.8 79.1 1Includes CCA and other waterborne preservatives. During 1960s and 70s, other significant waterborne preservatives included chromated zinc arsenate, acid copper chromate, chromated zinc chloride, flour chrome arsenate phenol. During the 1990s other waterborne preservatives included acid copper chromate, ammoniacal copper quarternary, and ammoniacal copper zinc arsenate. 2Not Recorded

B-5 APPENDIX C: QUESTIONNAIRE FOR FACILITIES THAT USE WOOD AS A SOURCE OF FUEL AND LIST OF FACILITIES SENT QUESTIONNAIRE.

C-1 PAGE 1

Facilities that Utilize Wood as a Source of Fuel in Boiler Operations, Statistics for Florida

Questionnaire distributed by the University of Miami in collaboration with the University of Florida and the Florida Institute of Technology.

Completing this questionnaire is a voluntary service. Individual companies have no obligations to complete the enclosed form. However, we would appreciate your organizations participation by completing as much of the survey as possible and mailing it in the self- addressed envelope provided.

C-2 PAGE 2

Purpose: This questionnaire addresses the fuel-source utilized by wood burning facilities in the state of Florida. If your organization does not utilize wood as a fuel source, please indicate below the type of fuel utilized, fill out the company information and return this information in the enclosed envelope.

Part A - Company Information

Company Name: ______

Address: ______

City: ______State: ______Zip Code: ______

Contact Person: ______

Telephone Number, include area code: ______

Fax Number, include area code: ______

Dates of operation during 1996: ______

Would you like to receive a copy of the results from this survey? Yes No

Part B – Fuel Description lease check the appropriate box.

1. Fuel Source: Wood only Wood & other fuel source (describe fuel characteristics and proportion of mix: ______) Other fuel source,no wood (describe fuel characteristics and proportion of mix: ______)

2. Total amount of wood burned per year (tons):______

C-3 PAGE 3

3. Wood Characteristics and Quantities Quantity (tons/year)

Wood type utilized: ______(e.g. urban tree waste, ______construction waste, etc.) ______

Other types of fuel utilized: ______(e.g. coal, tires, municipal ______solid waste, etc.) ______

4. If wood is accepted from other companies indicate name. (e.g. John Doe Recycling Company.) ______

Part C – Burning Process

Feed rate: ______

Residence time of wood in the boiler: ______

Briefly describe the burner system used (include temperature range): ______

Number of boilers utilized: ______

Capacity or size of each boiler: ______

C-4 PAGE 4

Part E - Handling of Ash

Describe ash collection system: ______

Ash generated per year (tons or cubic yards): ______

Please indicate where the ash is disposed:

Landfill Forest Spreading Agricultural Spreading Landfill cover Spread on site Other ______

If landfill is used for disposal, indicate type of landfill.

Lined Landfill Un-lined Landfill such as Construction & Demolition Landfills Other ______

Is the wood fuel or ash routinely analyzed? ______

If yes, what type of analysis procedure is used? ______

If availabe, please enclose a copy of your ash anlysis.

Thank you for completing the survey. Please mail survey in the self addressed envelope provided.

C-5 Table C-1: List of Facilities Sent a Questionnaire Inquiring About Wood Burning Practices.

Owner/Company Contact Person Address City St Zip Phone Fax First/ Middle Last Name

1 KOPPERS INDUSTRIES, INC. DONALD SURRENCY 200 NW 23RD AVENUE GAINESVILLE FL 32609 9043765144 2 UNIVERSITY OF FLORIDA - TACACHALE ALEX E.S GREEN SPACE SCIENCE RESEARCH GAINESVILLE FL 32611 9043422001 3 U.S. FOREST INDUSTRIES, INC. JACK B. PRESCOTT POST OFFICE BOX 2560 PANAMA CITY FL 32402 9047854311 9047636290 4 LOUISIANA PACIFIC CORP DENNIS MCCORMICK P.O. BOX 3107 CONROE TX1 77305 4097605921 4097560570 5 C & D PAVING, INC. CHARLES MONTES 15150 GOLDEN POINT LANE WEST PALM BEACH FL 33414 4075230004 6 JEFFERSON SMURFIT CORP (U.S.) HOLLIS H. ELDER P.O. BOX 150 JACKSONVILLE FL 32201 9047985600 9047985700 7 CHAMPION INTERNATIONAL CORPORATION F. DOUG OWENBY POST OFFICE BOX 87 CANTONMENT FL 32533 9049682121 8 HIGDON FURNITURE CO J.W. HIGDON P O BOX 978 QUINCY FL 32351 9046277564 9 COASTAL LUMBER CO JOHN G. KYNOCH HIGHWAY 27 NORTH P.O. BOX 1128 HAVANA FL 70333 9045396432 9045396799 10 MACTAVISH FURNITURE INDUSTRIES HERSHEL SHEPARD P.O. BOX 430 QUINCY FL 32351 9046277561 9046277519 11 MANATEE INTER. WOOD PRODUCTS ROY T. BOYD 2035 N.W. 8TH AVENUE OCALA FL 34475 9043518000 9043515969 12 TIMBER ENERGY RESOURCES HARRY L. GEORGE P.O. BOX 199 TELOGIA FL 32360 8503798341 8503798766 13 FLORIDA PLYWOODS JOHN MAULTSBY P. O. BOX 458 GREENVILLE FL 32331 9049482211 14 LFC NO. 47 CORP. MADISON BIOMASS PLT DAVID J. BROWN 4000 KRUSE WAY PL, BLDG 1 LAKE OSWEGO OR1 97035 5036369620 5036970288 15 FLEMING LUMBER CO H. FLEMING P O BOX 68 CRESTVIEW FL 32536 16 ATLANTIC SUGAR ASSOCIATION JOHN FANJUL P. O. BOX 1570 BELLE GLADE FL 33430 5619966541 8029968021 17 OSCEOLA FARMS CARLOS RIONDA P O BOX 679 PAHOKEE FL 33476 4079247156 4079243246 18 OSCEOLA POWER L.P. JAMES M. MERIWETHER P. O. BOX 86 SOUTH BAY FL 33493 4079969072 19 BARTOW ETHANOL, INC. DAVID HALL 12900 34TH STREET NORTH CLEARWATER FL 34622 8135733040 20 RIDGE GENERATING STATION, L.P. GEORGE WOODWARD 3131 K-VILLE AVENUE AUBURNDALE FL 33823 9416652255 9416650400 21 FLORIDA FURNITURE INDUSTRIES, INC. KENNETH LOYLESS P. O. BOX 610 PALATKA FL 32178 9043283444 9043286011 22 GEORGIA-PACIFIC CORP. PLYWOOD PLANT TOBIN FINELY 223 GORDON CHAPEL ROAD HAWTHORNE FL 32640 3524814311 3524814915 23 ROBERTS LUMBER CO, INC. ALAN ROBERTS ROBERTS LUMBER COMPANY INC PERRY FL 32347 9045844573 9045844348 24 PERRY LUMBER COMPANY, INC. PAUL DICKERT 1509 S. BYRON BUTLER PKWY PERRY FL 32347 9045843401

C-6 Table C-1(con'd): List of Facilities Sent a Questionnaire Inquiring About Wood Burning Practices.

Owner/Company Contact Person Address City St Zip Phone Fax First/ Middle Last Name

25 FL DEPT OF CORRECTIONS - UNION CORR INST RON KRONENBERGE P.O. BOX 2211 RAIFORD FL 32083 9044883800 R 26 GEORGIA-PACIFIC CORP. PULP/PAPER MILL MYRA CARPENTER GEORGIA-PACIFIC CORPORATION PALATKA FL 32178 9043252001 9043280014 27 BUCKEYE FLORIDA, LIMITED PARTNERSHIP CHARLES AIKEN BUCKEYE FLORIDA PERRY FL 32347 9045841121 9045841220 28 RECOVERY CORPORATION OF AMERICA R.L. TORRENS 102 STAR LANE BUTLER MO1 57901 29 GULFSTREAM PARK JACK BLAIR 901 S. FEDERAL HIGHWAY HALLANDALE FL 33009 3054547000 30 QUADREX ALTERNATE ENERGY DIVISION ROGER GARRA,PRE 7108 FAIRWAY DRIVE PALM BEACH FL 33418 5616277700 GARDENS 31 COMBUSTOR INC.SO FLA DETENTION FACILITY R, HOOVER 6663 HOLLANDALE DRIVE BOCA RATON FL 33433 3053687100 32 FLORIDA COAST PAPER COMPANY FERREL O. ALLEN FLORIDA PORT ST.LUCIE FL 32457 9042271171 9042272399 33 USEPPA INN & DOCK CO. / USEPPA ISLAND VINCENT FORMOSA P.O. BOX 640 BOKEELIA FL 33922 9412831061 9412830290 CLUB 34 SAFETY HARBOR CLUB JACK A. HUNT P.O. BOX 2276 PINELAND FL 33945 9414721019 9414721321 35 RUDOLF KRAUSE & SONS OF FLORIDA, INC. RUDY KRAUSE ROUTE 4, BOX 331 SUMMERLAND KEY FL 33042 3058724000 36 TONLEY FOUNDER & MACHINE, CO., INC J.O. TOWNLEY P.O. BOX 221 CANDLER FL 32624 9043559930 37 JEFFERSON SMURFIT CORPORATION (US) WARREN S. FLENNIKEN NORTH 8TH STREET FERNANDINA FL 32034 9042615551 9042775888 BEACH 38 RAYONIER INC. STEPHEN D. OLSEN P.O. BOX 2002 FERNANDINA FL 32035 9042613611 9042771413 BEACH 39 BOCA RATON RESORT & CLUB, LTD JESSE PERERA 501 EAST CAMINO REAL BOCA RATON FL 33432 4073953000 40 ST LUCIE INCINERATION - ON COLD STANDBY WAYNE HOLLAND 2300 VIRGINIA AVE FORT PIERCE FL 34982 4074681707 41 ROBBINS MANUFACTURING CO. BRAD ALSTON PO BOX 17939 TAMPA FL 33682 8139713030 42 LAKELAND DRUM SERVICE RANDY GUY P.O. BOX AUBURN FL 33823 9419673388 9419679516 43 ENVIRON-LECTRIC, INC WAYNE BODIR P.O. BOX 507 DE FUNIA SPAS FL 32435 8508922711 8503926428 44 NORTH FLORIDA LUMBER C. FINLEY MCRAE P O BOX 7 GRACEVILLE FL 32440 9042634457 45 OKEELANTA CORP RICARDO LIMA P O BOX 86 SOUTH BAY FL 33493 4079969072 4079927326 46 FORESTRY RESOURCES JOHN CAAUTHEN 4353 MICHIGAN LINK FORT MYERS FL 33916 9413324206 9413342953 47 ROYAL OAK ENTERPRISES, INC. JIM STROUP 1921 N.W. 17 PLACE OCALA FL 34475 3527320005 3527323874 1Questionnaire sent to company headquarters. Plant is located in Florida.

C-7