Florida CCA Regulatory Issues

1. Florida CCA Regulatory Issues Bill Hinkley, Chief, Bureau of Solid and Hazardous Waste Satish Kastury, Administrator, Hazardous Waste Regulation Section Richard Tedder, Administrator, Solid Waste Management Section

2. Quantities of CCA-Treated Wood

3. Amount of CCA-Treated Wood To Be Discarded Estimated from a Mass Balance Model Service Life 25 yrs L&T 40 yrs Poles CCA Production Disposal AWPI/AWPA Statistics & SFPA Projections

4. Disposal Forecast

5. Cumulative Quantities Before Ban

6. Cumulative Quantities With Ban

7. 590 Lake Okeechobee’s Equivalent to 4.83 x 1012 L water at 10 ug/L 100 yds x 50 yds x 63 ft of granulated As2O5 Amount of ArsenicTo Be Discarded • Cumulative Amount of As Imported = 31,400 tons • Cumulative Amount of As Disposed to Date = 2,250 tons • As in “In-Service” Wood= 29,150 tons Statistics for the Year 2002 (Florida)

8. 216,000 miles of 2 x 4’s 9 times around 100 yds x 50 yds x 2.7 miles Amount of CCA-Treated Wood To Be Discarded Statistics for the Year 2002 (Florida) • Cumulative Volume Imported = 635 million cubic feet • Cumulative Volume Disposed = 45 million cubic feet (7%) • Volume in Service = 590 million cubic feet

9. Leaching of CCA-Treated Wood

10. Leaching Characteristics of CCA-Treated Wood • TCLP used to characterize solid wastes as hazardous waste • As TC concentration = 5 mg/l • Currently exempt from definition of hazardous waste

11. TCLP Results from New CCA-Treated Wood

12. Typical TCLP Results(New Wood) TC for As and Cr(5 mg/l) Results Based on Two Pieces of 0.25 pcf CCA-C Dimensional Lumber

13. TCLP Results from Old CCA-Treated Wood

14. TCLP Arsenic Concentrations in Old CCA-Treated Wood

15. Will CCA-Treated Wood Leaching Impact Groundwater?

16. Typical TCLP and SPLP Results(New Wood) TC for As(5 mg/l) Results Based on Two Pieces of 0.25 pcf CCA-C Dimensional Lumber

17. Arsenic from Simulated C&D Debris Landfill

18. Mulch Leaching Data Future GWCTL for As?

19. Will CCA-treated Wood Impact Waste-to-Energy?

20. Future TCLP Limit? Ash Leaching Data

21. Regulatory Concerns with CCA-Treated Wood

22. Regulatory Concerns Based on the research of Solo-Gabriele, Townsend, Ma and others, there are regulatory concerns about CCA treated wood in four areas: • In service impacts • Reuse • Combustion • Land Disposal

23. IN SERVICE IMPACTS-SAWDUST • CCA treated wood sawdust routinely fails TCLP • However CCA wood, used for its intended purpose is exempt from RCRA. • Does the exemption cover sawdust? • If sawdust is not exempted, who is regulated, and how? • Furniture and other wood product manufacturers • Building supply stores that cut wood for customers • Contractors building decks at residences

24. IN SERVICE IMPACTS-SOIL CONTAMINATION • CCA treated wood decks and boardwalks are causing arsenic contamination in the underlying soils • The average As soil concentration found under Florida decks was 29 mg/kg • This is well above the RCRA arsenic soil screening value and the state’s clean soil criteria: • RCRA Soil Screening value: 0.4 mg/kg • Florida cleanup/residential: 0.8 mg/kg • Florida cleanup/industrial: 3.7 mg/kg • Florida cleanup/ leaching: 27.5 mg/kg

25. IN SERVICE IMPACTS-SOIL CONTAMINATION • Note that the soil leaching value is based on an MCL of 50 ug/l. EPA has recently announced its intention to lower the MCL to 10 ug/l. This would lower the SCTL Leachable value to 27.5/5 or 5.5 mg/kg • There are an estimated 30,000 acres of CCA treated wood decks and boardwalks in Florida. • What regulatory criteria, if any, apply to this situation?

26. REUSE-MULCH • Construction and demolition debris wood is frequently ground up, dyed and sold as a decorative landscaping mulch. This wood can contain CCA treated wood. • As little as 1% CCA treated wood in mulch will cause it to leach arsenic in excess of the current MCL of 50 ug/l.

27. REUSE-MULCH (con’d) • It is not lawful under current Florida regulations for permitted solid waste management facilities to make mulch from CCA treated wood. • But weathered CCA wood is difficult to distinguish from non-treated wood. Also, some manufacturers of mulch are not regulated as solid waste facilities.

28. COMBUSTION—EMISSIONS • Preliminary mass balance evaluation of CCA treated wood burned in industrial boilers suggests that a significant fraction of the arsenic in the wood cannot be accounted for in the ash and apparently escapes as both particulate and gaseous (arsine) emissions.

29. COMBUSTION—EMISSIONS (con’d) • What kinds of air pollution control equipment are needed to control arsenic emissions? • More research and analysis is needed, especially since burning CCA wood under controlled conditions—i.e. in a waste-to-energy plant or dedicated industrial boiler-- may be best long-term disposal strategy.

30. COMBUSTION—ASH • Ash from the combustion of CCA treated wood contains thousands of parts per million of arsenic, is highly toxic and fails TCLP. • However, ash from combustion of a wood mixture with as little as 6% CCA treated wood will also fail TCLP. • The average amount of CCA treated wood in the Florida wood waste stream is also currently about 6%, but will rise to 25-30% over the coming decades).

31. LAND DISPOSAL • Both laboratory and field data indicate that CCA treated wood disposed of in landfills leaches arsenic well above the proposed new arsenic MCL of 10 ug/l. • Generally, in Florida, construction and demolition debris is disposed of in unlined landfills, since C&D debris is “inert” and “non-polluting”.

32. LAND DISPOSAL (con’d) • Florida is currently evaluating whether CCA treated wood should be banned from unlined landfills, or whether C&D disposal sites should be lined. • Such changes make sense but there are significant repercussions which have to be considered, such as closure of many sites, soaring disposal fees and increased illegal dumping.

33. Questions?