Generation, Use, and Disposal and Management Options for ...

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

Transcript of Generation, Use, and Disposal and Management Options for ...

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

May 1998

Helena Solo-Gabriele, Principal InvestigatorJennifer PenhaVandin Catilu

University of Miami

Timothy Townsend, Co-Principal InvestigatorThabet Tolaymat

University of Florida

State University System of FloridaFLORIDA CENTER

FOR SOLID AND HAZARDOUS WASTE MANAGEMENT2207 NW 13 Street, Suite D

Gainesville, FL 32609

Report #98-1

i

TABLE OF CONTENTS

TABLE OF CONTENTSLIST OF FIGURESLIST OF TABLESLIST OF ABBREVIATIONS AND ACRONYMSUNITS OF MEASUREABSTRACT

iiiiiivivv

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 IVIV.1 Changes in Wood Treatment Industry and Implications to Wood Disposal 45

SectorIV.2 Recommendations 46IV.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 ASOURCE OF FUEL AND LIST OF FACILITIES SENTQUESTIONNAIRE

C-1

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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 5Zones

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 17Preservatives, 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 24Concentration

Figure II-7 Stoichiometric Comparison of Copper and Chromium for CCA 28Type A, B, and C and Comparison with Experimental Data

LIST OF TABLESTable 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 7Wood Types: Average Values and Ranges. Number ofexperimental 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: 7Average Values and Ranges. Number of experimental valuesper data point range from 1 to 2 for CCA-treated wood and 4 to6 for other wood types

Table I-5 Elemental Metal Concentrations (mg/kg) for wood mixtures 7which 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 15Extrapolation Methods for 1996.

Table II-3 Disposal of CCA-Treated Wood in Florida and US (Estimated). 18

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Table II-4 21

LIST OF TABLES(Con’d)

Sampling Sites and General Facility Descriptions

Table II-5 F (%) in Wood Waste 29CCA

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 32and Estimated Quantities of CCA-Treated Wood (1996)

Table III-1 Summary of Management Options for CCA-Treated Wood 43Waste

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-2Equipment, V

Table B-2 Production of CCA-Treated Wood and Quantity of Chemical B-3Utilized

Table B-3 Production of Wood Treated With Waterborne Preservatives B-4and Quantity of Chemical Utilized.

Table B-4 Production of Wood Treated With Waterborne Preservatives, B-5by Product Type,U.S. Statistics

Table C-1 List of Facilities Sent a Questionnaire Inquiring About WoodBurning Practices

C-6 to C-7

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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 LeachingProcedure

UNITS OF MEASUREft cubic feet3

lb/ft pounds per cubic foot3

lbs. pounds

mg/kg milligrams per kilogram

mg/L milligrams per liter

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ABSTRACT

High metals concentrations found in CCA-treated wood has prompted Florida regulators tore-examine policy for the recycling and disposal of wood waste. Upon re-examination, it was firstrecognized that limited information was available concerning disposal practices for CCA-treatedwood waste. The objectives of this research are to fill the information gap by developing aninventory for CCA-treated wood in Florida and by identifying current and alternative practices forits disposal. The inventory developed through this research includes a description of the woodtreatment industry in Florida during 1996, the quantities of wood product generated and disposed,and the identification of primary disposal reservoirs for the waste. Management alternativesfocused 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 constructionand demolition (C&D) waste stream. A significant amount of wood within this waste stream isrecycled 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 toaccumulations of the CCA chemical. The increase will likely reach levels which will characterizethe ash as hazardous. A hazardous designation will increase costs for ash disposal and will makeburning 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 mostpromising recycling alternative appears to be cement-based composite materials. Disposal-endmanagement should also focus on improved sorting practices at C&D recycling facilities andproper practices for disposing CCA-treated wood. Our second year research which investigatessorting and ash treatment technologies represents one step in attaining this goal.

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CHAPTER IMOTIVATION, BACKGROUND, AND OBJECTIVES

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I.1 MOTIVATION

Data (Atkins and Fehrs, 1992; McGinnis, 1995; Fehrs, 1995) suggest that elevated metalconcentrations in wood and wood ash are associated with a metal-based preservative referred toas CCA. Laboratory analysis of CCA-treated wood indicates that ash samples are consideredhazardous due to exceeded toxicity levels for chromium and arsenic as specified in the ResourcesConservation and Recovery Act (Gaba and Stever, 1995). Especially notable is that toxicitycriteria are exceeded for the wood ash even when CCA-treated wood represents a small fractionof the total wood fuel.

Given that CCA-treated wood can deem an ash hazardous when present at low levels, statutesthat regulate the disposal of combustor ash and exemptions provided to some wood burningfacilities (FAC, 62-702) are being re-reviewed. The exemptions release facilities from submittingash management plans. It is not clear whether facilities with exemptions burn CCA-treated woodnor is it clear how the wood ash is disposed. Given these uncertainties, research is needed todetermine disposal practices for CCA-treated wood in Florida.

I.2 BACKGROUND

I.2.a Wood Treatment Chemicals and Treatment Process

The wood preservation process involves impregnating the wood with chemicals that protectthe wood from biological deterioration and to delay combustion due to fire. The most commonprocess includes pressure-treatment in which the chemical is carried into the wood by a carrierfluid under pressurized conditions. Treatment chemicals utilized during the wood preservingprocess are separated into four major categories (AWPI, 1994). These categories include: waterborne preservatives including CCA, oilborne preservative including pentachlorophenol,creosote, and fire-retardants. The purpose of the first three chemicals is to prolong the useful lifeof wood products by protecting them against insect and fungal attack. Wood exposed to theoutdoor atmosphere and in direct contact with soil and water are more prone to decay andtherefore usually require treatment. The fourth preservative, fire-retardants, delay the combustionprocess when wood is subjected to fire.

Fire-retardants represent the smallest fraction of the wood treatment market. Formulationsfor 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-richsources, such as coal or wood. The resultant preservative is sometimes mixed with tar oils andpetroleum 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. Bothpentachlorophenol and creosote impart a dark color to the wood, have an odor, and result in anoily surface which is difficult to paint. Wood treated with either chemical is flammable andcontact with skin may cause irritation. Most common uses for creosote treated wood includerailroad 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.

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Waterborne preservatives utilize water as the carrier fluid during the treating process. Thewater is evaporated from the wood shortly after treatment leaving behind the treatment chemicals. The most common waterborne chemicals are metal oxides. These chemicals include chromatedcopper arsenate (CCA), acid copper chromate (ACC), ammoniacal copper arsenate (ACA),chromated zinc chloride (CZC), and ammoniacal copper zinc arsenate (ACZA). The mostcommon 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 ofchromium, copper, and arsenic. The copper in the wood serves as the fungicide whereas thearsenic protects the wood against insects. The chromium fixes the copper and arsenic to thewood. CCA can be separated into Type "A", "B", or "C" depending upon the relative proportionsof metals (table I-1). The relative proportions range from 35-65%, 16-45%, 18-20% forchromium, arsenic, and copper, respectively. The amount of CCA utilized to treat the wood orretention level depends upon the particular application for the wood product (table I-2). Lowretention values (0.25 lb/ft ) are permissible for plywood, lumber, and timbers if the wood is used3

for above ground applications. Higher retention values are required for load bearing woodcomponents such as pilings, structural poles, and columns. The highest retention levels (0.8 and2.5 lb/ft ) are required for wood components which are used for foundations or saltwater3

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 generalappearance of the wood, maintaining the aesthetic quality of natural wood. The wood is suitablefor use indoors and is generally used for interior parts of a wood structure in contact with thefloor. Drawbacks of the wood are a strong green color at high retention values. It should not beused in applications where it is in contact with food or drinking water. CCA is used to treatprimarily lumber, timbers, posts, and plywood. Its use in treating other products, such as polesand pilings, has seen relative increases as well.

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

Chromium as CrO 65.5% 35.3% 47.5%3

Copper as CuO 18.1% 19.6% 18.5%

Arsenic as As O 16.4% 45.1% 34.0%2 5

Table I-1: Composition of CCA-Type A,B, and C (AWPA, 1996)

Application Retention Value(lb/ft )3

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 0.60Structural poles

Foundation/Freshwater: pilings and columns 0.80

Salt water immersion: pilings and columns 2.50Table I-2: Retention Requirements for CCA-Treated Wood (AWPA, 1996)

14.6%

5.7%

79.1%

0.6%Fire Retardants

Waterborne Preservatives,CCA

Creosote

Oilborne Preservatives(Pentachlorophenol)

1996

Volume of Treated Wood Products 591 million cubic feet

50.6%

26.4%

15.8%

7.2%Fire Retardants

WaterbornePreservatives, CCA

Creosote

Oilborne Preservatives(Pentachlorophenol)

1970

Volume of Treated Wood Products 248 million cubic feet

Average service life of 25 years corresponds to lumber and timbers which represent the1

bulk of the CCA market. It is recognized that other products, such as utility poles, have a longerservice life.

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

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 and1970s, respectively. The production of treated wood products with creosote andpentachlorophenol increased at moderate rates between the 1960s and 1980s and has declined inrecent years. The use of CCA, on the other hand, has increased at a very rapid rate since itsinception 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, therelative distribution was 16%, 51%, 26%, and 7%, respectively. The total volume of treatedwood products has significantly increased at well. In 1970, the total volume of treated woodproducts was 248 million cubic feet of which 39 million cubic feet were treated with CCA. By1996, this figure increased to 591 million cubic feet for all products and 467 million cubic feet forCCA-treated products (figure I-2). Assuming that the service life for treated wood products isapproximately 25 years , industry statistics indicate that the total quantity of treated wood1

disposed will increase in the near future and that the characteristics of the waste stream will alsochange. Today in 1998, the disposal sector will observe that a larger quantity of creosote- andpentachlorophenol- treated wood waste is disposed than wood treated with waterbornepreservatives. Given trends in production, increases in the disposal of wood treated withwaterborne preservatives, and especially CCA, are anticipated.

0

100

200

300

400

500

600

Vol

ume,

mill

ion

cubi

c fe

et

1970 1996Year

CCA

CCA

All Products

All Products

W A 13

OR 10

NV 1CA

11

ID 5

UT 2

AZ 2

NM 1

W Y 2

CO 5

SD 3

NE 2

KS 0

TX 28

OK 3

MN 9

IA 2

MO 9

AR 17

LA 15

WI 11

IL 9

IN 7

OH 11

TN 7

MS 21

AL 39

FL 25

ME 1

NY 6

GA 40

SC 17

NC 28

W V 9 VA 20

PA 19

VT 0NH 1

MA 3

RI 1 CT 1

NJ 2

AK 0

MD 6

ND 1

KY 8

MT 2

W A 13

DA

C

B

D

E

A = Low D = HighB = Moderate E = SevereC = Intermediate

HI 5Wood Deterioration Potential

MI 11

5

Figure I-2: Volume of Treated Wood Products

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

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

Wood within the southeastern region has a greater potential for deterioration because theclimate is very conducive for the proliferation of insects and fungi (figure I-3). Florida, becauseof 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 491treatment plants nationally, 25 are located in Florida and an additional 100 are located alongFlorida's northern border, within Georgia, Alabama, and Mississippi. These four states alonehouse 25% of the treatment plants nationwide. Treated wood products will ultimately requiredisposal. A management plan for treated wood waste is needed for Florida due to a significantwood treatment industry within and near its borders.

Please note that an exemption has been provided to arsenically treated wood products. 2

Refer to 40 CFR Section 261.4 (B9).

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I.2.d Background Metals Concentrations in Treated Wood

Background metal concentrations were obtained from several experimental studies (Atkinsand Fehrs, 1992; Fehrs, 1995; McGinnis, 1995) in order to determine the differences betweenCCA- treated wood and other wood types. These data were arranged into several categoriesincluding burned and unburned wood, homogenous wood and wood mixtures, and elementalanalysis versus toxicity characteristics leaching procedure (TCLP). For comparative purposes thetables include federal regulatory criteria for: a) TCLP limits and, b) for land application of sewagesludge.

If a waste fails the TCLP test it is considered hazardous unless it has been provided aregulatory exemption . The TCLP protocol involves subjecting a waste sample to an acidic2

solution to extract contaminants. The waste fails the TCLP test if the extract exceeds a presetconcentration. 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 toregulate the land application of other wastes. Two sets of limits are established for elementalmetal concentrations. "Ceiling concentrations" represent maximum values for land applicationwhereas land applied wastes which meet the stricter "pollution concentrations" are subject to lessregulatory oversight. Both ceiling and pollution concentrations are included in tables I-3 andtables I-5 for comparative purposes. One should also note that Florida maintains a stricter set ofsoil clean-up goals. These goals have been considered as guidelines for regulating landapplication of wastes in Florida. These guidelines provide elemental concentrations for residentialand industrial land uses. Florida's guidelines are also included in tables I-3 and I-5 forcomparative purposes.

Data indicate that untreated wood and wood treated with resins and other chemicals such ascreosote and pentachlorophenol have significantly lower concentrations of arsenic, chromium, andcopper than CCA-treated wood (table I-3). This is the case if either unburned or ash samples areconsidered. Arsenic standards appear the most critical in limiting potential uses of CCA-treatedwood and other wood types. CCA-treated wood, whether unburned or ashed, exceeds federalcriteria for land application, whereas ash from "other wood" types is near federal limits. Onlyunburned wood in the "other than CCA-treated wood" category meet federal limits. All woodand 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 regulatorylimits (table I-4). Unburned samples of CCA-treated wood contain TCLP levels which are closeto the federal regulatory limits for arsenic, whereas ash samples of CCA-treated woodconsiderably exceed these limits for arsenic.

For mixtures of different wood types, sorting does appear to lower the concentration ofarsenic, chromium, and copper (table I-5). For the data presented in table I-5, samples in thesorted category meet federal regulations, whereas unsorted wood is close to the federal limit forarsenic. Wood in both categories exceed Florida's clean-up goal for arsenic.

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Metal Regulatory Limits Unburned Ash

Federal Florida1 2

Other Wood CCA Treated Other Wood CCA Treated(mg/kg), C (mg/kg), C (mg/kg) (mg/kg)ow CCA

Ceiling Pollution Industrial Residential(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)

Federal Register 40 CFR Part 503.13, Standards for the Use or Disposal of Sewage Sludge, Subpart B, Land Application1

Florida Department of Environmental Protection 2

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 rangefrom 2 to 3 for CCA-treated wood and 5 to 48 for other wood types.

Metal Regulatory Unburned AshLimits1

(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) (BD -3.4)a

Copper Not -- --- 0.29 0.06Applicable (0.04 - 0.76)

Federal Register 40 CFR Part 261.24, Identification and Listing of Hazardous Waste, Toxicity Characteristic1

BD = Below Detection a

Table I-4: TCLP Values for CCA-Treated Wood and Other Wood Types: Average Values andRanges. 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 WoodMixtures (mg/kg)Federal Florida1 2

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)

Federal Register 40 CFR Part 503.13, Standards for the Use or Disposal of Sewage Sludge, Subpart B, Land Application1

Florida Department of Environmental Protection 2

Table I-5: Elemental Metal Concentrations (mg/kg) for wood mixtures which are sorted and notsorted at wood processing facilities.

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I.3 OBJECTIVES

The goals of this project were to estimate the magnitude of CCA-treated wood disposed inFlorida and to determine the ultimate fate of the wood upon disposal. Furthermore, research wasneeded to identify available management options for the discarded wood. These options areintended to assist regulators in developing cost-effective policies that will minimize environmentalimpacts associated with the disposal of CCA-treated wood. These goals were accomplishedthrough 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 industrywithin Florida, the quantities of treated wood products generated over time, and a projection ofdisposal quantities into the future, as well as an evaluation of current disposal reservoirs for thewood 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.

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CHAPTER IIINVENTORY OF CCA-TREATED WOOD IN FLORIDA

QNR 'VNR

VR

× QR

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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-treatedwood, and c) current disposal reservoirs for discarded CCA-treated wood. Each topic isseparated into two parts: a methods and a results section.

II.1 CHARACTERISTICS OF THE FLORIDA WOOD TREATMENTINDUSTRY DURING 1996

II.1.a MethodsCharacteristics 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 itsborders. The 150 miles was chosen to represent a reasonable maximum distance for the transportof treated wood products to end use markets. The task included compiling a list of treaters anddeveloping 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 sourcesincluded the American Wood Preservers' Institute (AWPI) statistical reports of 1995 and 1996, adatabase inquiry through the Southern Forest Products Association (SFPA) (Leslie Moran,personal communication, 1997), a database inquiry through the U.S. Environmental ProtectionAgency's Toxic Release Inventory, and Random Length's "Big Book" which is a buyer's andseller's directory for the forest products industry. Each of the wood treating companies werecalled to verify addresses and to confirm their status of operation. The names and locations ofactive wood treaters is given in figure II-1. Addresses and contact numbers are provided withinappendix A.

The questionnaire inquired about the treatment process utilized by each plant, the quantity ofwood treated, the characteristics of the treating process, and the type of products generated. Adraft of the questionnaire was reviewed by Dr. George Parris of AWPI, who agreed to supportthe research efforts by serving as a contact person for companies who had inquiries about thequestionnaire. The initial mailings were followed by a second mailing and telephone calls. Acopy of the cover letter and questionnaire sent to wood treating plants is included within appendixA.

The amount of CCA-treated wood generated was estimated by adding: 1) the reportedquantities 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 volumeratios. The void volume is the cylindrical volume of pressure treating equipment available atwood 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 ofdifferent chemicals used. Void volumes for non-responding plants were obtained from the AWPIstatistical report of 1995. Our computation for the quantity of wood produced by non-respondingplants, Q , is given by the following expression.NR

equation(II-1)

where: Q = the quantity of CCA-treated wood in ft produced by reporting plants; V = voidR NR3

volume of non-reporting plants; and V = void volume of reporting plants. R

12

II.1.b ResultsA 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 insouthern Alabama, and 9 are located in southeastern Mississippi. The 150 mile boundary forFlorida imports is supported by the results of the questionnaire. For the responding plants, onlythose located within 90 miles of its borders had wood products exported into Florida. None ofthe responding plants outside of 90 miles had products imported into Florida.

FloridaFor 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 haveconsiderable 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 byindividual plants ranged from 27,000 to 1,800,000 pounds. The total waterborne treated productsold within Florida by individual companies ranged from 97,000 to 5,000,000 ft for 1996. 3

Fourteen of the 17 respondents listed the type of preservative utilized. Eleven of these utilizeCCA 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/ft to 2.5 lb/ft . Forty-eight3 3

percent of the wood product is treated with a 0.25 lb/ft retention value, 17% with a 0.6 lb/ft3 3

retention value, and 17% with a 2.5 lb/ft retention value. Retention values of 0.4 and 0.8 lb/ft3 3

were the least common. The most common products produced by the treating plants are lumberand timber. Other products include poles, pilings, fence posts, plywood, agricultural stakes, andguardrail posts. By far the most common type of wood utilized is Southern Yellow Pine.However, treatment of other types of wood including Honduran and Brazilian Pine was alsonoted.

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 theremaining six do not export products to Florida and one company was not able to quantify theamount of its product imported to Florida. The type of treatment chemical utilized by theresponding plants is exclusively CCA Type C. The retention value utilized most frequently bythese plants was 0.4 lb/ft . The total CCA-treated product sold in Florida by individual plants3

ranged from 100,000 ft to 1,800,000 ft for 1996. The product sold by individual plants3 3

corresponded to 55,000 to 825,000 pounds of chemical. The most common wood product soldby the responding plants was lumber and timber. Southern Yellow Pine is used exclusively by theresponding plants.

AlabamaNine 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 rangesbetween 1 to 5.3% of the product produced by an individual company. Six of the 18 companiesdo not export to Florida and in three cases their Florida plant does all the treating. The treatmentchemical utilized was exclusively CCA Type C. The retention value utilized most frequently was0.25 lb/ft . The total waterborne treated product sold in Florida by individual plants ranged from3

22,000 ft to 111,000 ft for 1996. The wood product sold by individual companies within3 3

13

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

MississippiOf the 8 treatment plants located in southeastern Mississippi, five responded. None of these

plants sell their products in Florida.

II.1.c SummaryA 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 amountapproximately 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 areproduced 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 inFlorida. Responding plants in Georgia and Alabama reported a total of 4.2 million cubic feet ofproduct sold within Florida. A value of 6.6 million cubic feet is estimated from equation II-1 fornon-responding plants located outside Florida.

Quantity of CCA-Treated Wood Sold in Florida CCA Chemical Utilized(10 ft ) (10 lbs)6 3 6

Amount Produced Amount Produced Total CrO CuO As O Totalin Florida in Al. & Ga.

3 2 5

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

dBdt

' A&C

UseB

GenerationA

DisposalC

14

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

II.2 GENERATION AND DISPOSAL OF CCA-TREATED WOOD

The purpose of this task was to forecast disposal quantities into the future. Thisprojection 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 andis represented by the following equation:

equation(II-2)

where: B = mass of CCA-treated wood in use at any time t; dB/dt = Rate of change of B withrespect 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 inequation II-2.

Measures of "A" were computed from industry statistical reports. Industry statistics weregathered from the American Wood Preservers' Association (AWPA) for 1964 to 1993 with theexception of 1982, 1989, and 1992 for which no reports were available. The statistics for 1994 to1996 were obtained from the American Wood Preservers Institute (AWPI). Each report, with theexception of 1990 to 1994 and 1996, provided a list of active treatment plants along with theirlocation and size of pressure treating equipment. Furthermore, data were available on either aregional or national basis concerning the amount of chemical utilized and the quantity and types ofwood products treated with the chemical. For any given year, statistics for Florida wereextrapolated from regional or national statistics using the relative number of plants (method 1) orrelative void volume of pressure treating equipment (method 2) corresponding to that year. Forexample, the amount of the CCA chemical utilized in Florida, Q , was computed fromCCA,FL

QCCA,FL ' QCCA,SE ×NFL

NSE

QCCA,FL ' QCCA,SE ×VFL

VSE

15

regional statistics and the relative number of plants as:

equation(II-3)

and from void volumes as:

equation(II-4)

where: Q = the amount of CCA chemical utilized in the southeastern region, lbs; N =CCA,SE FL

number of treatment plants located in Florida; N = number of treatment plants located within theSE

southeastern region; V = void volume of treatment plants located in Florida; V = void volumeFL SE

of treatment plants located in the southeastern region. A yearly tabulation of N and V forFlorida, 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 within5% of the void volumes determined from our questionnaire. The small differences between theresults 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 woodproduct and under-estimate the amount of chemical utilized, when compared to the results of ourquestionnaire. When comparing the void volume estimate (method 2) with the results of thequestionnaire, method 2 over-estimates the quantity of wood product by 10% and the amount ofchemical utilized is under-estimated by 30%. These differences are significant and should beconsidered when interpreting the results of our disposal forecast. Basically, given the assumptionsinvolved accuracies greater than 50% should not be expected through our forecast. The valuesquoted should be considered "order-of-magnitude" estimates.

Computation Method Number of Plants Void Volume Quantity of CCA- CCA Chemical( ft ) treated Wood Utilized3

Produced in FL, (10 lbs.) (10 ft )6 3

6

Method 1: No. of Plants 25 36 9.7Published by AWPI

in 1995

Method 2: Void Volumes 57,300 31 8.3Published 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 generalcharacteristics of CCA-treated wood products is necessary in tracking the waste through thedisposal stream. For example, these results can be used to determine whether sorting at disposal

16

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. Computationsare performed for the amount of wood product disposed (ft ) and the quantity of CCA chemical3

(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 annualproduction is generated as off-cut waste (Cooper, 1993). For purposes of estimating chemicalquantities, 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, andfence posts used in residential applications, for example, generally have short service lives, on theorder of 20 to 30 years (Cooper, 1993). Although the structural integrity of these products doesnot warrant disposal in many instances these products are often discarded for aesthetic reasonsdue to the effects of weathering. Other products such as utility poles and crossties, on the otherhand, generally have longer service lives. Florida Power and Light the largest electric utilitycompany 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 bythe Forest Products Laboratory (Gutzmer and Crawford, 1995) suggest that the service life ofCCA-treated wood products may be even greater than 40 years, especially for products treatedwith high retention levels. Given these differences in average service lives, our assumptions forcomputation purposes were as follows. First it was assumed that the average service life of polesand 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 45years. For lumber, timbers, fence posts, and other products, the assumed average service life is25 years. For computation purposes, it is assumed that 25% of these products last 20 to 22years, 50% last 23 to 27 years, and the remaining 25% last 28 to 30 years. The productionquantities for poles, crossties, lumbers, timbers, and fence posts are based upon industry statisticsas summarized in table B-4 in appendix B. For purposes estimating the chemical quantities it isassumed 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 toaccidental damages and losses. For instance, our assumptions do not include treated woodremoval due to destruction through car collisions, destruction during large storms, or removal dueto 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 toescalate dramatically. Approximately 10 million pounds of waterborne wood preservatives wereutilized in the U.S. during 1964 (table B-3 in appendix B). Most of these waterbornepreservatives consisted of chromated zinc arsenate (Boliden Salts), acid copper chromate(Celcure), chromated zinc chloride, flour chrome arsenate phenol (Osmosalts andTanalith/Wolman Salts). Only 8 percent of the waterborne market at this time consisted of CCA

0

5

10

15

20

25

30

35

40

45

50

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

Year

Mill

ion

cubi

c fe

et .

AWPI, 94

17

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

(Green Salt). Nevertheless, once CCA was introduced into the wood preserving industry, its usebegan to escalate dramatically. By 1995, 147 million pounds of waterborne preservatives wereutilized for wood treating purposes and over 90% of the waterborne preservatives utilized wasCCA. 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 industrycaused a shift in the chemicals used for treating wood products (table B-4, appendix B). Forexample, in 1964, approximately 38% of all lumber and timbers produced were treated withwaterborne preservatives. This percentage increased to 99% by 1996. A similar trend wasobserved for poles where 0.3% of the total product was treated with waterborne preservatives in1964; 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 asimilar trend as observed for the U.S. In 1964 it is estimated that approximately 2 million cubicfeet of wood product treated with waterborne preservatives were produced within Florida. Bythe early 1970s this figure reached a value of 3 to 4 million cubic feet. From the 1970s to the1990s the amount produced increased by a factor of 10 with a production of roughly 30 millioncubic feet in 1995. The amount of wood product generated in Florida corresponds to roughly 1million pounds of the treatment chemical in 1964. By 1980 this value increased to 4 millionpounds and by 1995 the amount reached a value of 10 million pounds.

18

DisposalProjected 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 increasedramatically in the near future. Our analysis indicates that roughly 3.7 million cubic feet oftreated wood product were disposed in Florida in 1996. By 2006 we expect to find 14 millioncubic feet within the disposal stream and by 2016, 31 million cubic feet are expected. Thesedisposal 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 millionpounds.

Year CCA-Treated Wood Disposed10 ft6 3

USFlorida

3.7 31.01995

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 31.0 397.3Table II-3: Disposal of CCA-Treated Wood in Florida and US (Estimated).

0

5

10

15

20

25

30

35

1995

1997

1999

2001

2003

2005

2007

2009

2011

2013

2015

Year

Mill

ion

cu

bic

fee

t

19

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

20

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

Efforts during this phase focused on estimating the quantities of CCA-treated wood disposedthrough construction and demolition (C&D) recycling facilities and through wood-burningoperations. It is recognized that other disposal reservoirs, such as municipal solid waste landfillsand incinerators or composting operations, may accept CCA-treated wood. However, thesereservoirs are considered small relative to the volume disposed through C&D and wood wastecogeneration 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 iscomposed of a variety of materials, including concrete, asphalt, metal, drywall, paper, plastic, andwood. 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, aswell as demolished structures. As part of residential construction, CCA-treated wood is used inareas of the structure where contact with the external environment is likely. This includes anywood 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-treatedwood entering Florida's C&D facilities yearly (M [tons/year]).CCA

M = [M ]*[F ]*[F ] equation (II-5)CCA C&D wood CCA

M refers to the total amount of C&D waste entering Florida C&D facilities [tons/year], FC&D wood

represents the fraction of wood in Florida's C&D waste stream [ton/ton], and F is the fractionCCA

of CCA-treated wood in total wood stream [ton/ton]. The amount of C&D waste entering Florida’s landfills and recycling facilities (M ) wasC&D

estimated using existing generation estimates, as well as specific data from recycling facilities inFlorida. The fraction of Florida’s C&D waste stream which is composed of wood (F ) waswood

estimated using existing C&D waste composition estimates, ongoing C&D waste compositionwork, and data from C&D recycling facilities. The methodology used to estimate F included aCCA

number of steps: collection of wood samples, sample preparation, analysis for concentrations ofcopper and chromium in the prepared samples, mass balance computations, and methodvalidation. The steps necessary for the computation of F are provided below.CCA

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 woodwas not used because of the large volume of material which would have to be sorted to collect arepresentative sample, and because of the difficulty in visually identifying CCA-treated wood.

Samples were collected in 35-gallon plastic containers. Composite grab samples werecollected, with a minimum of 20 grabs from each pile; and at some sites duplicate samples werecollected. The facilities that were visited are termed for this paper as A through M and adescription of these facilities and the types of samples collected are presented in table II-4.

21

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 frontand 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 frontand in manual recovery system.

F 1 Mixed C&D waste recycling facility. Wood separated upfront.

G 1 Mixed C&D waste recycling facility. Wood separated up frontand in manual recovery system.

H 2 Mixed C&D waste recycling facility. Wood separated up frontand in manual recovery system.

I 2 Mixed C&D waste recycling facility. Wood separated up frontand in manual recovery system.

J 1 Mixed C&D waste recycling facility. Wood separated up frontand in manual recovery system.

K 1 Mixed C&D waste recycling facility. Wood separated upfront.

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 PreparationAlthough 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 stepswere 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 shreddertwice. In addition to bringing the sample size of most pieces to less than 1 inch, this processprovided mixing. Sample mass was measured before and after chipping to determine any loss inthe shredding process. Remaining large pieces in the samples were further size reduced usingstainless steel sheers. During these two steps impurities such as nails and wires were removedfrom the samples and characterized. The samples were then placed on a plastic tarp, mixedfor 10 minutes, and six 1200 g subsamples were randomly collected and placed in plasticcontainers. Each of the six grab samples was composed of at least 20 grabs from throughout thepile.

Three of the six samples were then dried in an oven at 105 EC. Moisture content wasdetermined. The dried samples were then ashed in a muffle furnace at 550 EC, and the volatilesolids content was calculated. All of the ash was then transferred to teflon lined glass jars andstored in a refrigerator at 4EC.

Chipped WoodSample in 35-gallon

Container

Size-Reduce SampleUsing Chipper-

Shredder

M ix Sample for 10minutes

Collect six 1200g Sub-samples from randomgrabs throughout the

pile

Dry (105C) and thenash (550C)

approximately 700 g ofeach subsample.

Analysis ash forCopper, andChromium.

RepeatOnce

22

Figure II-5: Sample Preparation Process

Sample AnalysisThe 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 PerkinElmer 5100 Atomic Absorption Spectrophotometer using Flame Atomization.

FCCA,m 'MCCA

MT

'CT,m & Cow,m

CCCA,m & Cow,m

23

Mass Balance ComputationsIt 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 metalswere assumed negligible. A literature review on background metals concentrations in woodindicated that CCA-treated wood and its ash contain higher chromium, copper, and arsenicconcentrations than other wood types including clean wood, wood treated with creosote,pentachlorophenol, resins, and adhesives. The difference in metals concentrations was severalorders-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 metalsconcentration data can be utilized to estimate F . This mass balance is given quantitatively by:CCA

M C = M C + M C equation (II-6)T T,m ow ow,m CCA CCA,m

Total Metal Mass Metal Mass from Other Wood Metal Mass from CCA-treated Wood

where: M = mass of wood. Subscript j corresponds to wood type where: T = recycled woodj

waste, ow=other wood, and CCA=CCA-treated wood. C corresponds to metals concentrationsj,m

(mass metal per mass wood), where C is the concentration of the recycled wood waste, C isT,m ow,m

the metal concentration corresponding to other wood types, and C is the metal concentrationCCA,m

corresponding to CCA-treated wood. One mass balance is developed for each metal as providedby subscript m, where m = Cu corresponds to copper and m = Cr corresponds to chromium.

Values of C and C were measured experimentally in the laboratory. C wereCCA,m ow,m CCA,m

obtained by processing CCA Type C with a 0.25 lb/ft retention level. C were obtained by3ow,m

processing clean wood.Re-arranging equation II-6, the fraction of the recycled wood waste stream composed of

CCA-treated wood, F , is computed as,m

equation (II-7)

ValidationTo validate the methodology, wood samples with known treated wood concentrations were

analyzed. Type ?C” 0.25 lb/ft CCA-treated wood was purchased from a local hardware store. 3

The treated wood was then passed twice through the chipper shredder, in a similar manner as theother wood samples. Treated wood was mixed with untreated wood to achieve concentrations of1%, 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 samplewas 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 tothe theoretical values. The predicted or measured CCA wood concentration (F ) is plotted inCCA

figure II-6 versus the actual concentration. The bold line indicates a 1:1 relationship. As can beseen, the method provided accurate prediction of F using both copper and chromium.CCA

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

25

II.3.b Methods: Wood BurningThe 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 burningfacilities within the State of Florida, b) determining the quantities and characteristics of the woodfuel at these facilities, and c) estimating the quantities of CCA-treated wood burned from massbalance considerations.

List of Wood Burning FacilitiesA 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 thathave received air emission permits and which burn specific types of waste. Specifically thefollowing waste categories were searched: wood/bark waste, bagasse, solid waste, woodcommercial/industrial space heaters, solid waste disposal - government/commercial/institutional,wood refuse, trench burner wood, trench burner refuse, fire fighting structure wood pallets. Thissearch was facilitated by Kathy Anderson and Yi Zhu of the DEP. The initial list containedapproximately 200 facilities. This list was further narrowed by removing facilities that did notburn wood. This narrowed list is based upon more detailed descriptions of the fuel stream asavailable through the database and through follow-up phone calls. The shortened list of facilitieswhich were considered to potentially include wood boilers and wood cogeneration plants isprovided in appendix C.

Quantities and Characteristics of Wood FuelQuantities 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 thefacilities. A review of DEP permit applications in June 1997 provided information concerning fueland ash quality for major wood burning operations within the State. These data were compiledfor purposes of estimating the quantity of CCA-treated wood at each site. Field visits were alsoconducted in June 1997 to three facilities: the Okeelanta cogeneration plant, the Ridgecogeneration 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 aquestionnaire was sent to each of the facilities considered to potentially burn wood (table C-1 in3

appendix C). The questionnaire inquired about the quantity of wood burned as well ascharacteristics of the wood fuel stream. Chemical composition data of the wood fuel and ashwere requested if available. Following each mailing, telephone calls were made to the plantmanager to assure receipt of the questionnaire. For facilities that did not respond, a second copyof 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 (C and C ) were based upon literature valuesow CCA

(Please refer to table I-3, Chapter 1). Values of C were provided by the wood burning facilitiesT

or through review Florida DEP permit applications. Since data were available for copper,

FCCA,Average 'FCr % FCu %FAs

3

QW 'N

100R ( H ( D

QCCA ' QW(FCCA,Average

PCCA 'QCCA ( 2000 lbs./ton

30 lbs per cubic foot

26

chromium, and arsenic, three mass balance equations were developed from equation II-6 andtherefore three values were computed for the fraction of the wood fuel stream composed ofCCA-treated wood (F ). An overall average value of F is given by:CCA CCA, Average

equation (II-8)

where: F ,F ,F are the average fractions computed from chromium, copper, and arsenic results, Cr Cu As

respectively. The quantity of wood burned at each facility, Q , was computed as follows:W

equation (II-9)

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, Q , in units of tons per year wasCCA

then computed from values of F as: CCA,Average

equation (II-10)

The value of Q can be converted to units of ft /yr (P ) utilizing an average density for woodCCA CCA3

of 30 lb/ft (Lide, 1992; AWPA, 1996). This conversion is given as:3

equation (II-11)

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

The amount of C&D waste generated (M ) in Florida in 1995 was estimated by the FloridaC&D

DEP as 5,200,000 tons. While much of the information used to calculate this number isdebatable, the amount generated as compared to MSW falls in line with other C&D wasteestimates.

The amount of wood in C&D waste, (F ), varies from the type of construction orwood

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

27

CCA Fraction in C&D Waste Wood, FCCA

A total of 61 samples were ashed, digested and analyzed for copper and chromiumconcentrations. 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 chromiumconcentrations in the ashed samples were compared to determine if a relationship consistent withCCA-treated wood was observed (figure II-7). Included in figure II-7 is the best fit line (for theentire data set) and the theoretical chromium to copper ratio for CCA Types A, B, and C. Theseresults confirm that it is very likely that the copper and chromium measured were the result ofType C CCA-treated wood.

The copper and chromium concentrations in the ashed samples were then used in theequations developed previously to calculate the fraction of CCA-treated wood in the collectedsamples (F ). The mass balance was based on the assumption that the Cu and Cr were from theCCA

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 VScontent would have the lesser F , because those metals would have been a result of more woodCCA

(more VS). The VS content ranged from 58% to 98% for the collected samples. Samples thatwere predominately wood had the greatest VS content, and samples mixed with some soil had thelowest.

The results of the F calculations are presented in table II-5 for each sample by both copperCCA

and chromium. The F predicted using copper ranges from "below detection" to 26%. The FCCA

predicted by chromium ranges from "below detection" to 29%. It is important to again note,CCA

that F is the percentage of 0.25 lb/ft Type C CCA-treated wood needed to account for all ofCCA3

the copper and chromium measured. If the Cu and Cr were the result of a 0.6 lb/ft retention3

level, the F number would be only 43% of the number in table II-5. CCA

The average F for all samples was 6.1% based on copper and 5.6% based on chromium. CCA

The values utilized for the samples that were below detection was 0.4%. It is observed thatsamples collected at given sites tended to follow similar patterns. Sample 2 from site C had thehighest calculated CCA fraction. CCA-treated wood was readily observed in the unprocessedfraction at this facility, including a number of pole cut-offs which were likely greater than 0.25lb/ft standard retention. Site D had two samples that were below 1%. These samples3

corresponded to material at a site that processed both yard waste and C&D wood waste. Thesamples with F values less than 1% were collected primarily from the vegetation fraction. CCA

29

Site Sample Number of F , (%) AverageNumber Replicates (%)

CCA

Copper Chromium0.25 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: F (%) in Wood WasteCCA

A list of the facilities that were sent questionnaires is provided within table C-1 within4

appendix C.

30

SummaryThe fraction of C&D wood waste (F ) that is composed of CCA is estimated from experimentalCCA

data as 5.9%. During 1995, Florida generated an estimated 5,200,000 tons of C&D waste androughly 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 equalto 4.6 x 10 ft assuming an average wood density of 33 lb/ft . The mass balance from section II.26 3 3

indicates that the total quantity of CCA-treated wood disposed within the State is approximately 3.7x 10 ft . Given the uncertainties in our estimates it is interesting to note that both the amount6 3

disposed within the C&D waste stream is of the "same-order-of-magnitude" as the total disposalquantity predicted through methods described in section II.2. Our interpretation of these results isthat most of the CCA-treated wood waste is likely disposed through the C&D waste stream.

II.3.d Results: Wood BurningResponses were received from 27 of the 45 facilities sent questionnaires (table II-6). Additional4

information concerning 3 of the 27 responding facilities was obtained from field visits and review ofpermit applications. Six of the 20 facilities that did not respond could not be reached by telephoneor mail. Of the 27 responding facilities, 13 utilized wood as a fuel source, 7 did not utilize wood asfuel, 2 utilized a small amount of wood for start-up purposes, 3 were not burning facilities, and 2chose 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, plastics, pecan hulls,bagasse, black liquor, and fossil fuels.

The amount of ash generated by each of the responding facilities ranged from 1,000 to 11,000tons per year. Most of the ash was landfilled or stock-piled. Small quantities of ash were utilized aslandfill 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 % 47Table II-6: Response to Questionnaire.

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

31

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 100Table 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 C C C F F F FNo. (mg/kg) (mg/kg) (mg/kg) (%) (%) (%) (%)

T,Cr T,Cu T,As Cr Cu As CCA,Average

1 27.2 19.1 21.4 0.97 1.40 1.62 1.3a

6 12.6 40 NM 0.27 3.31 ---- 1.8b c

Data obtained from DEP permit applicationsa

Provided through Wood Boiler Questionnaireb

Not Measuredc

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 thestandard deviation of the results (0.33%) is significantly lower than the standard deviation for plant6 (2.2%). Given the lack of data on fuel quality, the values of F for the remaining plantsCCA,Average

were assumed equal to 1.3%. Testing of the wood fuel is highly recommended to obtain a moreaccurate estimate of F for other facilities. CCA,Average

Given our assumptions and equation II-11, the total amount of CCA disposed via wood burningfacilities is estimated at 2.5 x 10 ft /year. The total amount disposed, as estimated from section II.2,6 3

is 3.7 x 10 ft /year. These values suggest that wood burning/cogeneration facilities can account for6 3

up to 67% of the CCA disposed during 1996. The 67% estimate should not be considered anabsolute value in light of the uncertainties in our assumptions. What is noted from these numbersis that both estimates are within the "same-order-of-magnitude" and that they support the hypothesisthat a significant fraction of CCA-treated wood waste generated within the State is used for energyrecovery purposes.

32

Plant Total Wood CCA-treated (estimated)Number Burned, QW

tons/year tons/year ft /yrQ PCCA

3

CCA

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).

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CHAPTER IIIMANAGEMENT OPTIONS

34

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 ofprocessing needed to find new uses for the wood. Reuse requires minimal processing (i.e. theoriginal piece of discarded wood remains intact with minimal cutting) whereas recycling requires asignificant 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). Treatmenttechnologies for extracting metals from CCA-treated wood are included within recyclingalternatives since metal extraction increases the potential for recycling the wood fiber. Thepreferred management options are presented first with the least preferred options following. Asummary 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 alternativechemical preservatives. A description of these alternatives are provided below. Prolonging theservice life of CCA-treated wood products through retreatment is also considered a means forwaste minimization. Consider for example that a company requires 100 CCA-treated utility polesfor 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 increasedto 50 years then only 200 poles (100 * (100/50)) must be purchased during the same 100 yearperiod. Therefore, by increasing the service life of a CCA-treated pole from 25 to 50 years, theamount of wood product utilized (and therefore the amount ultimately disposed) decreases by50%. The net effect of retreatment technologies is to reduce the quantity of CCA-treated woodwaste within the disposal stream.

III.1.a Alternative Structural MaterialsWood 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 iscontrasted with other building materials, such as steel, concrete, aluminum, and brick, which areobtained from Earth's finite reserves. Furthermore, less energy is required to process wood whencompared to other materials (Milton, 1995). Treating wood has its advantages by prolonging theservice life of wood products. At some point however, the disadvantages of using CCA from adisposal perspective outweigh the positive aspects. If the objective is to reduce the quantity ofCCA 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 polyvinylchloride. 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 forplastic lumber is 35 to 50 years. Its utilization allows for the recycling of plastic and the reduction

35

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

Utilization of wood with natural resistanceAs 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 protectthis layer, extractives are deposited within dead cells located within the heartwood center. Theseextractives are often toxic to insects and fungi, thereby providing the heartwood portion of thetree natural protection against decay (Milton, 1995). The type and quantity of extractivesproduced by a tree differs from species to species, and therefore some tree species have naturallymore resistance than others. Tree species characterized by natural resistance include Americanchesnut, western red cedar, mahogany, and teak. It is also important to note that extractives arefound only within the heartwood layer. Even for species considered durable, wood surroundingthe heartwood (i.e. sapwood) must be removed or treated for durability. Durable species aremore expensive, scarce, and slower to grow, than non-durable species. The scarcity of durablespecies is due in part to extensive harvesting and re-planting with fast growing non-durablespecies (Milton, 1995).

Other alternative materialsOther 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 thatuntreated wood requires the least amount of energy to process (Milton, 1995). Life-cycleanalysis for treated wood products is currently underway through an independent research project(Reaven, personal communication).

III.1.b Alternative Chemical Preservatives

Creosote and pentachlorophenolCreosote 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 odorsemitted by the preservatives. These preservatives nevertheless can be used as alternatives to CCAfor outdoor applications that have limited human contact. Examples include utility poles whichtoday are treated to a considerable extent with CCA. Advantages associated with creosote andpentachlorophenol are the lower metals concentration associated with these preservatives. Although some concerns have been raised concerning emissions, burning creosote andpentachlorophenol has advantages over CCA. When burned, the ash from creosote andpentachlorophenol has lower metals concentrations, and the oils associated with thesepreservatives, facilitate the combustion process reducing the need for fuel oils when these woodtypes are incinerated.

PhytoalexinsTrees 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 componentof the bark layer of trees. Tree bark is usually the last component to degrade after a tree has diedand this resistance to decomposition has been attributed to suberin, a complex polyester. It has

36

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

Copper naphthenateCopper 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, woodtreated with the chemical has a characteristic odor. This disadvantage can be avoided through theuse of water soluble forms of copper naphthenate, which are less commonly used. Otherdisadvantages 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 thepreservative in an attempt to make the treated product more appealing (Summers, 1995). As forcreosote and pentachlorophenol, copper naphthenate may be substituted for CCA in outdoorapplications. Copper naphthenate contains elevated copper concentrations which must beaddressed 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 ratioof copper oxide to quat. Quat is an abbreviation for quaternary which is a chemical term used todescribe a molecule with four functional groups. The "quat" molecule used in ACQ isdidecyldimethyl 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 AmmoniacalCopper Quaternary Ammonium.

A major advantage of this chemical preservative is that it does not contain arsenic orchromium, therefore reducing some of the environmental concerns associated with the disposal ofthese compounds. Furthermore, quat is considered to have low human toxicity. Another majoradvantage is that ACQ has been standardized by the American Wood Preservers' Association andformulations have been developed for use outdoors in above ground, ground contact, forfreshwater, and for marine splash zone contact. The service life of ACQ treated wood is similarto that of CCA and ACZA (Archer, personal communication, 1998).

Disadvantages of the chemical include elevated copper concentrations which must beaddressed during disposal and the alkaline nature of the chemical. Treatment with this chemicalmay require the need for a scrubbing system for neutralization of alkaline vapors produced duringthe 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 ACZArequires an additional step for wastewater neutralization since the chemical is dissolved in analkaline solution during treatment. Disposal of ACZA treated wood is subject to the samedrawbacks as CCA due to elevated metals concentrations. Although levels of chromium are notas high within ACZA, zinc represents a significant concern upon disposal.

37

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.

BoratesBorates 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 thatused for other waterborne preservatives (Staats, personal communication, 1998). Borates areadded to water in the form of disodium octoborate tetrahydrate. This chemical is then injectedinto the wood under pressure using similar equipment that is used for treating wood with otherwaterborne preservatives. In New Zealand, however, borates are applied in a much differentfashion (Burton, et. al., 1990). The application of the chemical in New Zealand typically requiresvaporization of trimethyl borate. Trimethyl borate reacts with the wood to form boric acid andmethyl alcohol (Turner, et. al., 1990).

Primary advantages in the used of borates are that they provide resistance to wood at very lowretention levels thereby requiring less chemical on a per unit wood volume basis. It does notdiscolor 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 useof the wood is limited to indoor applications. Other disadvantages include that the wood must bevery dry (4 to 6% moisture content) during chemical application and, for vapor-phase applicationof borates, the wastewater produced during treatment is contaminated with methanol (Cogan,personal communication, 1997).

Plastic Coated WoodPlastic 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 havebeen raised concerning cracking and resistance of the plastic coating (Fahy, et. al., 1993).

Other chemicalsOther chemicals that have shown some preservative capacity include propiconazole,

isothiazolone, cholorthalanil, and copper citrate. Experiments have shown that bothpropiconazole and isothiazolone are effective against insects and fungi. Isothiazolone is noteffective against marine borers and therefore not recommended for marine applications. Thesechemicals have not been included within the AWPA book of standards (Fahy, et. al., 1993) sincelimited information exists on their long-term performance.

III.1.c Methods to Increase Product Service Life

Supplemental treatmentsSupplemental treatments include water sealants and plastic coverings for CCA-treated wood

products. These treatments help to maintain the CCA chemical within the wood product therebyproviding greater protection against decay. For example, formulations for water proofed pressuretreated 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).

38

Chemical re-treatmentChemical 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 areawhere chemicals are lost the quickest. Care should be taken during the chemical retreatmentprocess 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. Regulatoryrestrictions are placed upon its handling.

C Dursban: Dursban contains 0.5% chlorpyrifos, which acts as a pesticide. Chlorpyrifos haslow volatility and bonds easily with organic matter. The chemical has a tendency todecompose when subject to light and water.

C Timberfume: Timberfume contains 99% chloropicrin, which is used within the agriculturalindustry as a crop and soil fumigant. Drawbacks with the chemical include its volatilityand its tendency to decompose when exposed to water and light.

C Woodfume (Vapam): Woodfume consists of 32.7 sodium methyldithiocarbamate. Priorto contact with water, the chemical is non-volatile and bonds to organic matter. When incontact with water, the chemical is transformed to a volatile organic compound,methylisothiocyanate.

C Misc Fume: Misc Fume consists of 97% methylisothiocyanate. The chemical does notbond 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% potassiumdichromate. Hollow heart consists of 11% sodium flouride, 5% sodium dichromate, and 5%sodium arsenate.

Wood treatment process enhancementSeveral 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 thefixation of the wood. These process enhancements improve the retention of CCA within thewood during its service life thereby providing more effective protection against decay. Thedistribution of CCA within the wood matrix is enhanced through the incisor method, whichinvolves placing small incisions in the wood's surface. This process permits the preservative tomore effectively penetrate the interior of the wood. This process is especially useful forhardwood such as white spruce, lodgepole pine, and alpine fir. This process, however, does notprovide a significant added benefit for treating Southern Yellow Pine, which is by far the primarywood species treated in the State of Florida. Southern Yellow Pine is extremely porous andgenerally 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 enhancedthrough rapid fixation processes (Fahy, et. al., 1993). Rapid fixation processes include hot airheating, hot water fixation, steam fixation, and hot oil heating.

39

II.2 REUSE

III.2.a Reuse for New ApplicationsThe 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 lowerservice lines and as guardrail posts. Construction off-cuts of lumbers and timbers can be used forsmaller applications including composting bins, planter boxes, shipping crates, picnic tables, andwalkway edging. Potential problems with these re-use options, however, is the generation ofcontaminated sawdust and human exposures to the sawdust.

The demand for CCA-treated wood reuse purposes is apparently high within the State ofFlorida. The pole recycling facility operated at Florida Power and Light, for example, hasobserved 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 originalgenerator of the waste (Doyle, et. al., 1992).

III.2.b Reuse for the Same ApplicationThe 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 DeGroot, 1996).

III.3 RECYCLING

III.3.a Recovery of Untreated Portions of Treated Wood ProductsThe 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 notusually penetrated by preservatives during treatment (Felton and De Groot, 1996) and butttreated utility poles. For example, a wood recycling facility in British Columbia scrapes the outertwo to three inches of the pole and converts the remaining clean portion into lumber ("WoodyMaterials Recycling", 1997). The main drawbacks with this form of recycling includes thedisposal 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 containhigh decay potential due to the presence of the preservative chemical. Wood based compositesrely 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-treatedwood fibers and the CCA chemical deposits themselves which prevent the adhesive contact withthe wood. However, hydroxymethylated resorcinol (HMR) can be potentially used as a couplingagent 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 manufacturersare not in favor of using recycled CCA. Concerns cited were safety of workers and environmentalproblems that may arise when composite products are contaminated with treatment chemicals.

III.3.c Wood cement composites

40

Wood cement composites are highly pest and fire-resistant. They are generally lighter andpossess better insulating properties than products made entirely of cement. Wood cementcomposites 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). Applicationsinclude 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 areusually used in board products for providing some tensile strength. Wood can also be added tocement in "chunks," where it simply functions as a low-density low-cost aggregate. Applicationsof these products include situations where the tensile strength is not critical.

Research indicates that cement wood composites with CCA-treated wood are stronger thancomposites with untreated wood. This increase in strength has been attributed to the chromium inthe 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 speciesare Douglas-fir, hemlock, and most hardwoods (Felton and De Groot, 1996).

III.3.d Wood gypsum compositesAs 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 gypsumcomposites is limited to indoor applications (Moslemi, 1988). Gypsum composites appear to beless sensitive to wood species than wood cement composites (Felton and De Groot, 1996). Applications of these composites include fireproof walls and ceilings, laminated paneling, andfireproof furniture (Moslami, 1988).

III.3.e Wood plastic compositesSome 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 MetalsOnce 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 extractiontechnologies for CCA- treated wood waste.

Smith and Shiau, 1997, tested the effects of several acids on sawdust and steam explodedCCA-treated wood. Their results showed that most of the metals were removed within the first24 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 chromiumand 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. Onceconverted arsenic, chromium, and copper can be removed from the wood through a washingprocess and the wood can be used for other purposes. Bacteria convert the CCA chemical towater soluble forms for detoxification purposes only (Felton and De Groot, 1996). Bacteria cantolerate only low levels of the preservative and therefore, pre-treatment of the wood to removethe bulk of the preservative may be necessary prior to bio-conversion processes. Otherdrawbacks of the process include a wastewater contaminated with metals. Processes must be

41

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 formetals leaching. Land application regulations (see section I.2.d) may apply if CCA-treated woodis reused for such purposes. If these recycling options are considered, technologies for removingthe CCA from the wood (Smith and Shiau, 1997; Felton and De Groot, 1996) should beconsidered prior to recycling as mulch. These technologies include biodegradation and solventextraction. 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 operationssuch as cement kilns. Wood utilized for energy recovery purposes has the advantage in that itlessens the dependence on fossil fuels and eases the landfill burden through volume reduction.

III.4.a Cement kilnsWood 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 inorganicswithin the wood including metals may be stabilized within the cement matrix. Emissions representa 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 andpublic perception. Although no ash is produced in cement kilns the metals in CCA-treated woodmay increase the concentration of metals in cement kiln dust.

III.4.b CogenerationSeveral 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 volumereduction 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 includepotential air emission problems and the high metals concentrations that can be found in the woodash. When incinerated, most of the chromium and copper are retained in the ash while attemperatures greater than 300 C some arsenic is volatilized (Smith and Shiau, 1996). Amountso

of arsenic volatilized ranges from 20 to 90% (Doyle, et. al., 1992). The metals that remain withinthe ash greatly restrict recycling opportunities for the ash residual. If CCA-treated woodrepresents a significant fraction of the fuel stream (>2% to 3%) TCLP limits will likely beexceeded 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

42

The least desirable disposal options include incineration without energy recovery andlandfilling.

III.5.a Incineration without Energy RecoveryIncineration 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 disposedand emissions must be controlled. Excessive amounts of CCA-treated wood within this wastestream may increase metals concentrations in the ash or in air emissions to unacceptable levels.

III.5.b LandfillsLandfills include both Construction and Demolition (C&D) Landfills and Municipal Solid

Waste (MSW) landfills. C&D landfills are generally unlined and contain limited leachatemonitoring systems. Wood is a significant component of the waste stream at these facilitiesnevertheless. The US EPA, 1995 reports that approximately 30% of the C&D waste stream inFlorida is composed of wood. MSW landfill designs are usually more elaborate and includebottom liners and leachate collection systems. Groundwater monitoring is usually more extensiveat MSW landfills.

Landfill disposal can be in the form of chips. Large bulky objects such as telephone poles canbe buried. Landfill disposal of treated wood is regulated on the basis of leaching characteristics ofthe wood, as determined by a standard leaching protocols (i.e. TCLP). The literature indicatesthat CCA-treated wood will pass the TCLP test on most occasions. In the few occasions whereit may not pass TCLP tests, an exemption is provided at the federal level if the waste is generatedby 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 solidwaste. Current regulations however, do not exclude the ash from CCA-treated wood, from beingclassified as a hazardous waste.

Gifford, et. al., 1997 conducted a study to determine the quality of leachate and factorsaffecting leachate quality when CCA-treated wood was exposed to natural weathering conditionsin a simulated land disposal situation. The results of their lysimeter tests indicate that soilattenuates the leachate concentrations of Cu, Cr, and As. They conclude that in well constructedlandfills where clay capping layers are placed between waste layers, there is a substantial capacityfor 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 otheroptions have been exhausted. Landfill capacity within Florida is diminishing and large bulkymaterials such as CCA-treated wood waste should be discouraged from disposal within thesefacilities.

III.5.c Ash DisposalWood 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 toneutralize 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 microbialactivity which enhances nitrogen availability, mineralization, cellulose decomposition, andnitrogen fixation (Campbell, 1990). Wood ash can also be used to control the odor and moisturecontent of wastewater sludge (Campbell, et. al., 1997). This material can then be used as a soilamendment (Pepin and Coleman, 1984). Wood ash can also be used as an amendment for

43

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 ofcompost to enhance plant growth (Campbell, et. al. 1997).

Recycling opportunities for ash however are limited if the ash contains elevated metalconcentrations. Excessive amounts of CCA-treated wood ash would significantly degrade ashquality 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, theresultant ash will be classified as hazardous and the costs for disposal would escalate.

44

Waste MinimizationC 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.

ReuseC Reuse for New Applications: Fence posts, landscape timber, parking lot bumpers,

guardrail posts, composting bins, planter boxes, shipping crates, picnic tables, walkwayedging, etc...

C Reuse for Same Application: Splicing intact portions of spent utility poles.

RecyclingC Recovery of Untreated Portions of Treated Wood Products: Clean wood portions used

for many different applicationsC 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 arecurrently under development.

C Extraction of Metals: Chemical and biological methods under development forunburned wood.

C Mulching and Composting (unburned wood): Viewed with caution due to potential formetals leaching.

Energy Recovery and Wood As FuelC 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.

DisposalC 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 recyclingopportunities.

Table III-1: Summary of Management Options for CCA-Treated Wood Waste.

45

CHAPTER IVCONCLUSIONS AND RECOMMENDATIONS

46

IV.1 CHANGES IN WOOD TREATMENT INDUSTRY ANDIMPLICATIONS TO THE WOOD DISPOSAL SECTOR

The chemicals utilized by the wood preservation industry have changed significantly since the1970s. During the 1970s preservatives made of organic chemicals, such as creosote andpentachlorophenol, were the most widely used preservatives. During the 1970s and 1980s the useof waterborne preservatives, composed primarily of metal salts or oxides, began to increasedramatically. Given the trends in chemical usage by the wood treatment sector, changes in thecomposition of the wood waste stream are anticipated in the near future. These changes in thewaste stream will have a significant impact upon disposal. Metals from discarded CCA-treatedwood must be addressed. These metals are concentrated in the wood ash upon combustion andsome metals may be lost through air emissions. Since creosote and pentachlorophenol arecomposed of organic compounds, both chemicals can be converted to carbon dioxide and othercarbon-based chemicals by the action of micro-organisms or through combustion. There are someconcerns associated with air emissions since some toxins can be produced if combustiontemperatures are not properly maintained and if air pollution control devices are not used. However, the disposal issues associated with creosote and pentachlorophenol with respect tometal by-products are small relative to that for CCA. Management options chosen for discardedwood should consider the anticipated increases in metal by-products due to increased quantities ofCCA-treated wood waste.

Furthermore, the increase in CCA-treated wood waste will make discarded wood moredifficult to manage. Products treated with creosote and pentachlorophenol are more easilyregulated than wood treated with waterborne preservatives. Creosote- and pentachlorophenol-treated products, such as railroad ties, utility poles, and cross-arms, are generally used exclusivelyby industry which have more controls placed on their waste stream than wastes produced by thecommercial and residential sectors. Even if these products are found within commercial andresidential waste, they can be readily recognized because of their dimensions. Rarely is wood ofthese dimensions untreated. Therefore, if the disposal sector requires separate handling forcreosote- and pentachlorophenol- treated wood waste, implementation can be accomplishedthrough 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 usedto treat products that have a considerable "clean" market. In other words, CCA is used to treatsignificant quantities of lumber, timbers, and plywood. Lumber, timbers, and plywood have useswithin industrial, commercial, and residential sectors. Furthermore, these products also have aconsiderable market if untreated. Therefore, once CCA-treated wood is disposed, it is likelymixed 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 treatedwood 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 asignificantly larger quantity of CCA-treated wood. Methods are needed which enable the disposalsector to effectively handle this anticipated change in the wood waste stream.

47

IV.2 RECOMMENDATIONS

Waste MinimizationReduction of CCA-treated wood within the waste stream can be assured through waste

minimization practices. Waste minimization can be accomplished through the use of alternativestructural materials, alternative chemical preservatives, and by increasing the service life of CCA-treated wood products. The use of alternative structural materials and chemicals may bepromoted 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 copperquat, borates, and phytoalexins. ACQ is already produced commercially and its use should beencouraged. Research to improve the economics of other promising chemical alternatives shouldbe also encouraged.

Although waste minimization is the most efficient means by which to control the amount ofCCA-treated wood found in the waste stream, it is important to consider that a strong demandexists for CCA-treated wood products, especially in Florida. Until economical alternatives areidentified for CCA-treated wood products, "disposal-end" management will be the primary meansby which to control the ultimate fate of the wood.

Disposal-End ManagementThe 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 valuesgreater than roughly 2 to 3% CCA-treated wood by weight, the ash from combusted wood willlikely be hazardous according to TCLP criteria. A wood mixture study should be implemented todetermine a precise value for mixtures of CCA-treated wood with other wood types such thatTCLP 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 managedin Florida via two primary means. The traditional method of disposal is by landfilling. Newregulations increasing requirements of such facilities, and existing stringent regulations in anumber of counties, has resulted in the growth of C&D recycling. C&D recycling facilitiestypically accept mixed loads of C&D waste, and separate the materials by a combination ofmanual and mechanical means. C&D recycling facilities are typically required to remove themajority of CCA-treated wood from the "clean" wood sold to recycling markets. The primarymarket for wood recovered from C&D recycling operations in Florida is as fuel in industrialcombustion units. The amount of CCA-treated wood in the fuel stream these industries accept isoften required to be less than a specified level (e.g. 1%). Results have shown however, that thefraction of CCA-treated wood collected from C&D processing facilities around Florida issignificantly higher than 1% on average. No given type or standard retention is defined, and it isextremely difficult to police this policy.

Other than separation of large readily recognizable wood products, sorting of CCA-treatedwood from other wood types is almost non-existent at C&D recycling facilities. Technologies doexist 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 betested on wood waste. If results are positive, these sorting technologies should be promotedamong the disposal sector. Our second year study investigates two potential sorting technologies.

48

Once CCA-treated wood is sorted from the remaining wood waste stream, it must be eitherreused, recycled, or ultimately disposed. There is currently a demand for CCA-treated woodwaste for residential landscaping and for agricultural fencing. It is recommended that large usersof CCA-treated wood (such as electric and telephone utilities) advertise the availability of thematerial 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 thatcentralized facilities be established for accepting CCA-treated wood waste from C&D recyclingoperations. At these centralized facilities, the wood can be re-distributed to potential users or canbe disposed in a controlled manner. To facilitate the collection of CCA-treated wood fromresidential users it is recommended that a pamphlet be developed that informs users about properdisposal practices for the wood and about locations where the discarded CCA-treated wood willbe accepted. These pamphlets should be distributed along with EPA's Consumer InformationSheets to individuals purchasing CCA-treated wood in Florida.

One of the most promising recycling alternatives for CCA-treated wood waste are woodcement composites. The advantages of this alternative are: a) the stabilization of metals withinthe cement matrix, and b) the production of this composite material may economical for specialapplications requiring both a fire-resistant and light-weight material. Markets for wood cementcomposite materials should be investigated further.

Disposal of CCA-treated wood via incineration should also be considered as a means forvolume 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 to15% 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 anextraction, if successful, may open new opportunities for treating wood ash and recycling theCCA chemical.

49

IV.3 CONCLUSION

As a structural material, wood has many positive and unique characteristics. One majordisadvantage of wood however is that it is subject to decay by insects and fungi. Thisdisadvantage is especially detrimental when the wood is utilized outdoors, especially in areas ofwarm and humid climate such as Florida. To overcome this disadvantage, chemical preservativesare added to wood. These preservatives act as pesticides and fungicides, thereby protectingwood. Disposal of treated wood, however, also includes the disposal of the preservativechemicals found in them. The point at which the disadvantages of treated wood outweigh itsadvantages is not exactly known. However, what is known is that there is currently a highdemand for treated wood products, and especially CCA-treated wood, in Florida. The demandfor this product will continue until economical alternatives are found. This wood will continue tobe found within the wood waste stream for years to come with quantities increasing significantlyin the future. Current management practices for CCA-treated wood will not be acceptable in thenear future. Combustion of the treated wood waste with other clean wood results in high metalsconcentrations 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 thatwould be classified as hazardous according to toxicity criteria as defined through RCRA. Theresearch team recommends several alternatives for improving the management of CCA-treatedwood waste. These alternatives are outlined in section IV.2 and include improved sorting atC&D recycling facilities and improved methods for handling the waste upon disposal. Our secondyear research which investigates sorting and ash treatment technologies represents a next step inattaining this goal.

50

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 fortheir suggestions and for their assistance with information dissemination. The authors also thankthe following members of the Technical Advisory Committee for their feedback throughout thecourse 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 ofSolid Waste Management, Kenneth Cogan of Hickson Corporation, Keith Drescher of FloridaPower and Light, Jeffrey Fehrs of C.T. Donovan and Associates, Bill Gay of Langdale ForestProducts, George Parris of the American Wood Preservers' Institute, Mike Provenza of RobbinsManufacturing, Chih-Shin Shieh of the Florida Institute of Technology, Donald Surrency ofKoppers Industries, David Stephenson of the Southeastern Regional Biomass Energy Program,August Staats of Osmose Wood Preserving, and George Varn Jr. of Varn Wood Products.

51

REFERENCESAPWI, 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 EnergyResearch 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 PreservativeTreatment 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 municipalsludge 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 inthe Southeast. Southeastern Regional Biomass Energy Program, Muscle Shoals, Alabama.

Donovan, C.T. and Fehrs, J.E., 1993. Environmental Issues: New techniques for Managing andUsing 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. DonovanAssociates, 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, Agriculture, 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.

52

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.

53

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-cementcompatibility 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 reductionof 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 withVolatile Borates. Paper prepared for the 21st Annual Meeting of the International ResearchGroup on Wood Preservation, Rotorua, New Zealand.

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

U.S. EPA. Toxic Release Inventory Database. Available throughthe internet: http://www.epa.gov/enviro/html/tris/tris_query.html SIC Code 2491. Databaseaccessed 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.

54

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

Webb, D.A., and Davis, D.E., 1993. Spent Treated Wood Products: Alternatives and TheirReuse 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.

A-1

APPENDIX A: WOOD TREATERS AND WOOD TREATER

QUESTIONNAIRE

A-2

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) 556-8003Plant Manager: Juan Moran

2 Anchor Wood Treating 3670 NW 79th St. Miami F L 33147 (305) 691-7711Plant Manager: Jorge DeFema

3 Apalachee Pole Company P.O. Box 610 Bristol FL 32440 (904) 643-2121Plant Manager : David Powell

4 Arnold Lumber Company Rt 1 Box 260 Bonifay FL 32425 (304) 547 - 5733Plant Manger: Chris Jernigan

5 Coastal Lumber Company P.O. Box 1128 Havanna FL 32333 (904) 539-6432Vice President: Bill Harlod P.O. Box 829 Weldon NC 27890

6 Cook Lumber & Treating, Inc. 4956 Lantana Road Lake Worth FL 33463 (561) 965 - 1633Plant Manager: Fred Poston

7 Cook Lumber Company 1905 N. 66th St Tampa FL 33619 (813) 626 - 1411Plant Manger: Joel Miller

8 Dantzler Lumber & Export Co. P.O. Box 6340 Jacksonville FL 32236 (904) 786 - 0424Plant Manager: Chuck Galloway

9 E.D. Cook Lumber Company, Inc 5901 Beggs Rd Orlando FL 32810- (407) 293 -1811Plant Manager: Harry Arolan -2609

10 Florida Fence Post Company P.O. Box 645 Ona FL 33865 (941) 735 - 1361Office Manager: Linda Kiella

11 Florida Perma-Wood Treaters 4500 E. 11TH Ave. Hialeah FL 33013 (305) 685 - 7833President: Stephen Rose

12 Great Southern Wood Preservers P.O. Box 759 Bushnell FL 33513 (352) 793 - 9410General Manager: Jimmy Harris

13 Koppers Industries P.O. Box 1067 Gainesville FL 32602 (352) 376 - 5144Manager: Don Surrency 200 N.W. 23rd Ave. 32609

14 Longleaf Forest Products, Inc. 1325 Yorktown St. Deland FL 32724 (904) 734 - 5161President: Robert Wheeler

15 Ocala Lumber SaLes Co P.O. Box 1389 Ocala FL 34478- (352) 732 - 0167Owner: Henry Moxon -1389

16 Pensacola Wood Treating 1813 East Gadster Pensacola FL 32501 (904) 433 - 1300Plant Manager: Neil McMillan

17 Pride of Florida/Union Forestry P.O. Box 308 Raiford FL 32083 (904) 431 - 1912Production Manager: StanLehman

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.Neb raska Tampa FL 33612 (813) 971 - 3030Plant Manager: Mike Provenza Ave. 1-800-282-9336

20 Robbins Manufacturing Company 3250 Metro Parkway Ft Myers FL 33916 (813) 334 - 221921 Robbins Manufacturing Company 7205 Rose Avenue Orlando FL 32810 (407) 293 - 0321

A-3

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 - 1003Plant Manger: Jerry Lindsey

23 Southern Lumber & Treating Co P.O. Box 7450 Jacksonville FL 32238 (904) 695 - 0784Plant Manager: Robert Stovall

24 Sunbelt Forest Products P.O. Box 1218 Bartow FL 33830 (941) 534 - 1702Plant Manager: Ken Delle Donne

25 Suwannee Lumber Mfg. Company P.O. Drawer 5090 Cross City FL 32628- (352) 498-3364Plant Manager: Lee Childers -5090

26 Universal Forest Products, Inc P.O. Box 217 Auburndale FL 33823- (941) 965 - 2566Plant Manager: Jon Scharfenberg -0217

27 Wood Treaters, Inc. P.O. Box 41604 Jacksonville FL 32203- (904) 358 - 2507President: Stan Hill -1604

A-4

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)864-9303President: 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 - 2141Plant Manager: Tom Mcmillian Drawer 758 0758

3 Centreville Lumber Co. P.O. Box 94 Vance AL 35042 (205) 926 - 4606Plant Manager : Russ Griffin

4 Everwood Treating Co., Inc. P.O Box 7500 Spanish Fort AL 36577 (334) 626 - 2080Plant Manager: Jar Hudson

5 Great Southern Wood Preserving, P.O. Box 610 Abbeville AL 36310 (334) 585 - 2291Inc.Plant Manager: Mitchell WeaverAst. Plant Manager:Bryan Newman

6 Great Southern Wood Preserving, P.O. Box 987 Theodore AL 36590 (334) 438 - 6842Inc.

7 Gulf Treating Co., Inc. P.O. Box 1663 Mobile AL 36633 (334) 457 - 6872Plant Manager: Romean Upshaw

8 Kopper Industries P.O. Box 510 Montgomery AL 36101 (334) 834 - 5290Plant Manager: Bill HasleyAst. Plant Manager: Ed Davidson

9 Lee Lumber Co. P.O. Box 416 Centreville AL 35042 (205) 926 -9717Owner: Don Lee

10 Louisiana - Pacific Corporation P.O. Box 388 Lockhart AL 36455Plant Manager: Roy Ezell

11 Louisiana - Pacific Corporation P.O. Box 726 Evergreen AL 3640112 Olon Belcher Lumber Co., Inc. P.O. Box 160 Brent AL 35034 (205)926-4666

General Manager: Brent Belcher(near Centreville)

F(205)926-4666

13 Stallworth Timber Co., Inc. P.O. Box 38 Beatrice AL 36425 (334) 789 - 2151Plant Manager: Bill Black(near Greensboro)

[email protected]

14 Southeast Wood Treating, Inc. P.O. Box 25 Louisville AL 36048

15 Swift Lumber, Inc. P.O. Box Atmore AL 36504 (334) 368 - 8800Plant Manager: Dwight Grant Drawer 1298

16 T.R. Miller Mill Co., Inc. P.O. Box 708 Brewton AL 36427 (334) 867 - 4331Plant Manager: James McGougin (800) 633 - 6740cdc.net/sprimus/trim/

17 Walker - Williams Lumber Co., Inc. P.O. Box 170 Hatchechubbee AL 36858 (334) 667 - 7736Plant Manager: Bobby Walker(near Hurtsboro)

(800) 727 - 9007

18 Willamina Lumber Hwy 219 Centreville AL 35042 (205) 926 - 4605Plant Manager: Russ Griffin

A-5

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 - 4011Plant Manager: C.M. EuniceAst. Plant Manager: HaroldFlyod

Timberlane

2 Atlantic Wood Industries, Inc. P.O. Box 1608 Savannah GA 31402 - (912) 964 - 1234Plant Manger: J. Frank Cliett 1608

3 Atlantic Wood Industries, Inc. P.O. Box 384 Vidalia GA 30474-0384 (912) 537-4188Plant Manager: Guy Haltom

4 B & M Wood Products Inc. P.O Box 176 Manor GA 31550 (912) 283 - 0353Plant Manager: Jim Stovall Rt. 1 (800) 451 - 0385

5 Baxley Creosoting Company P.O. Box 459 Baxley GA 31513 (912) 367 - 4646Plant Manager: Lowton Morris

6 Cook County Wood Preserving P.O Box 637 Adel GA 31620 (912) 896 -4357Plant Manager: David Sorrell

7 D & D Wood Preserving, Inc. P.O. Box 1802 Albany GA 31702 (912) 436 - 2638Plant Manager: Russel Davis

8 Georgia - Pacific Corp. P.O. Box 668 Brunswick GA 31521 (912) 261-2974Plant Manager: Carter Ramsey

9 Georgia - Pacific Corp. P.O. Box 799 Pearson GA 31642 (912)422-3247Plant Supt: Stanley Wall F(912)422-7749

10 Langdale Forest Products Co. P.O. Box 1088 Valdosta GA 31603 (912) 333 - 2513Plant Manager: Jim Langdale

11 Louisana - Pacific Corp. P.O. Box 130 Statesboro GA 30459 (912) 681 - 2048Plant Manager: BobbyWhittington

12 Manor Timber Co., Inc. RTE #1 Box Manor GA 31550 - (912) 487 - 2621Plant Manager: William F.Peagler

60 9601

13 Mellco, Inc. P.O. Drawer C Perry GA 31069 (800)866-1414Plant Manager: Matt Corwart (912)987-5040

F(912)987-793214 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 - 4875Inc. 32141 (800) 847 - 9663Plant Manager: Herb Gurry

16 Shearouse Lumber Company P.O. Drawer C Pooler GA 31322 (912) 748 - 7244Plant Manger: Jack Shearouse

17 Tolleson Lumber Co., Inc. P.O. Drawer E Perry GA 31069 (800)768-2105General Manager: Joe Kusar (912)987-2105

F(912)987-016018 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)458-2187General Mngr: Thomas ShavePlant Manager: Mr. Varn

F(912)458-2190

A-6

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)788-6564General Mgr: Larry Polk Hwy. 15 N S

2 Desoto Treated Material, Inc. P.O. Box 460 Wiggins M 39577 (601) 928 - 5092Plant Mgr: Steve Owen S

3 International Paper P.O. Box 37 Wiggins M 39577 (601) 928-0176Plant Mgr: HowardHamilton

S

4 Laurel Lumber Co., Inc. P.O. Box 4178 Laurel M 39441- (601)649-7696President: Wayne ParkerSales Mgr: Billy Ryals

S 4178

5 Southern Pine Wood P.O. Box 818 Picayune M 39466 (601)798-8152Preserving S (800)367-0461Vice Pres/Sales Mgr: GinaMaddalozzo

F(601)798-8196

6 Southern Wood Preserving P.O. Box 630 Hattiesburg M 39403 (601)544-1140of Hattiesburg, Inc. S (800)844-1140Plant Mgr: Joe Hartfield F(601)544-1147

7 Treated Materials Co., Inc. P.O. Box 2848 Gulfport M 39503 (601) 896 - 5056Owner: 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-7

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 conversationI mentioned that the University of Miami in collaboration with the University of Florida isconducting research to determine the amounts of pressure treated wood sold within the State ofFlorida. 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 thequantities of pressure-treated wood that will be disposed over time and to evaluate alternatives forthe management of this discarded wood. Our intent is to promote the economic viability of thewood treatment industry while assuring that discarded wood is properly handled.

We request your assistance in conducting this research by completing the enclosedquestionnaire. This questionnaire has been distributed to all wood treaters within the State ofFlorida as well as those located in southern Georgia, Alabama, and Mississippi. The purpose ofthe questionnaire is to determine the amount, types, and uses of waterborne preservatives in theState of Florida. Data pertaining to individual companies will be kept confidential. The responsesfrom 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 theAmerican Wood Preserver's Institute (AWPI). If you would like to speak to a representativefrom 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 bycompleting the enclosed questionnaire and mailing it in the attached self-addressed envelope. Theresults of our research will be available to your organization if desired. Please mark theappropriate box on the questionnaire if you would like a copy of our final report summarizing thetotal 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 thereturn envelope.

Sincerely,

Helena Solo-Gabriele, Ph.D.,P.E.Assistant Professor

cc: Dr. Timothy Townsend, Univ. of Florida

A-8

Page 1

Pressure Treated Wood Using Waterborne Preservatives,Statistics For Florida

Questionnaire Distributed by the University of Miami inCollaboration with the University of Florida

Completing this questionnaire is a voluntary service. Individual treating companies have noobligations 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-addressedenvelope provided.

A-9

Page 2

Purpose: This questionnaire addresses the treatment of wood products utilizing waterborne woodpreservatives such as CCA, ACA, ACC, ACQ, and ACZA. If your organization does not treat woodwith waterborne preservatives, check here 9 then fill out the company information and return in theenclosed 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 NoIf the plant was idle in 1996, do you intend to resume operations? 9 Yes 9 NoIf 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

Compositions of CCA 5

CCA-Type A CCA-Type B CCA-Type CChromium 65.5% 35.3% 47.5%

Copper 18.1% 19.6% 18.5%Arsenic 16.4% 45.1% 34.0%

A-10

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 plant9 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 type of CCA is used to pressure treat wood? Please indicate the percentage of the total5

CCA used by your company.

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

_______ _______%

A-11

Page 4

Part B - Chemical Information (con'd)

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

CCA Retention Value Amount Used(pound/ft ) (pounds, oxide basis, dry)3

9 0.25 ____________________9 0.40 ____________________9 0.60 ____________________9 0.80 _____________________9 2.50 _____________________

Other Waterborne Preservative (specify)____________

Retention Value Amount Used(pound/ft ) (pounds, oxide basis, dry)3

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) __ __ __ __ __ __ __

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

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

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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 checkappropriate box and indicate estimated percentage of total, if available.

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

___________ ______%___________ ______%___________ ______%

Values above correspond to: 9 total products generated by the plant9 only those products sold in Florida

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

9 Lumber 9 Agricultural Stakes6

9 Timbers 9 Crossarms7

9 Crossties 9 Decorative9 Fence Posts 9 Furniture9 Poles (utility) 9 Guardrail Posts9 Poles (building) 9 Highway Posts9 Piling (marine) 9 Landscape Timbers9 Piling (other) 9 Mine Ties & Timbers9 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.

B-1

APPENDIX B:STATISTICS FOR THE WOOD TREATMENT

INDUSTRY

B-2

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

Year

Number of Treating Plants Utilizing Void Volume For Plants Treating with1

Waterborne Preservatives, N Waterborne Preservatives, V (1000 ft )

2

3

Florida SE Region U.S. Florida SE Region U.S.

1964 128 20 105 23317 72

1965 162 19 123 25820 94

1966 151 26 91 25520 62

1967 159 26 91 26820 65

1968 161 26 95 27520 66

1969 162 26 95 27520 66

1970 165 26 96 27920 67

1971 171 26 97 28421 68

1972 182 27 113 31022 72

1973 190 27 117 32322 73

1974 194 27 117 33522 73

1975 195 27 117 33622 73

1976 27 120 35122 75 202

1977 211 27 124 36322 78

1978 214 27 129 36522 81

1979 216 27 129 36622 81

1980 226 27 133 38022 84

1981 195 19 116 33717 70

1982 NR NR NR NRNR3 NR

1983 213 35 198 48719 75

1984 213 35 198 48719 75

1985 237 53 256 56121 87

1986 242 56 276 66221 87

1987 180 38 207 59816 63

1988 177 39 203 59017 60

1989 473 NR NR NRNR NR

1990 458 NR NR NRNR 147

1991 445 NR NR NRNR 140

1992 460 NR NR NRNR NR

1993 42 229 68225 136 404

1994 583 42 229 682NR 188

1995 486 43 234 69625 148

1996 NR 146 465 NR NR NRNumber of plants determined directly from statistical reports. 1

Some assumptions were necessary for determining void volumes. Specifically, for treating plants that utilized2

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."No Record Available.3

B-3

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

Year

Production of CCA-TreatedWood, Quantity of Chemical Utilized, Ave. million ft million pounds Retention3

Value ,3

Florida(lb/ft )3

Florida SE Region U.S. Florida SE Region U.S.1 2 2 1 2 2

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 NR NR NR NR NR NR5

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 44.3 131.6 0.284

1994 41.7 226.8 467.1 8.3 44.9 133.4 0.204

1995 NR 177.2 441.6 NR 49.9 138.54

1996 NR 167.8 458.5 NR 52.0 144.54

Values have been computed based on void volume1

Values have been taken directly from statistical reports2

Computed from available data3

Values have been calculated by assuming that CCA represents 98% of the total waterborne4

preservatives. Not Recorded.5

B-4

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

Year million pounds RetentionProduction of Wood Treated with Quantity of Chemical Utilized, Ave.

Waterborne Preservatives,million ft Value ,3

1

4

Florida(lb/ft )3

Florida SE Region U.S. Florida SE Region U.S.2 3 3 2 3 3

1964 1.9 10.3 22.7 1.1 5.9 10.3 0.61965 1.9 12.4 25.9 1.1 7.1 12.1 0.61966 3.3 11.5 32.5 1.6 5.5 12.6 0.51967 2.9 10.2 30.1 1.3 4.4 11.2 0.41968 2.5 9.1 26.2 1.3 4.7 10.7 0.51969 2.9 10.5 30.1 1.4 5.0 12.0 0.51970 2.8 10.2 29.7 1.4 4.9 10.8 0.51971 3.3 12.3 36.0 2.0 7.5 13.1 0.61972 3.5 12.1 41.2 1.8 7.7 13.3 0.51973 3.6 15.9 43.8 1.7 7.5 16.5 0.51974 4.3 18.8 53.8 1.7 7.6 20.3 0.41975 3.2 13.9 40.0 1.6 6.9 20.4 0.51976 4.2 19.1 55.9 1.8 8.0 20.3 0.41977 4.2 19.3 56.6 2.0 9.2 27.2 0.51978 5.1 24.5 69.5 2.5 12.1 28.5 0.51979 7.8 37.8 107.7 3.9 18.9 28.5 0.51980 8.9 44.4 126.7 3.8 18.8 37.0 0.41981 8.1 51.2 148.3 4.1 25.6 38.5 0.51982 NR NR NR NR NR NR ---5

1983 18.3 103.3 258.2 6.5 36.9 47.9 0.41984 24.5 137.8 301.7 8.3 46.8 67.0 0.31985 25.4 123.2 328.7 11.6 56.3 85.0 0.51986 31.5 155.7 375.5 13.2 65.2 102.4 0.41987 31.5 171.8 419.0 9.4 51.0 124.5 0.31988 34.1 178.8 450.6 9.8 51.5 131.0 0.31989 NR NR NR NR NR NR ---1990 30.8 157.0 437.7 9.8 47.1 131.3 0.31991 29.8 147.1 424.4 9.5 44.1 127.3 0.31992 NR NR NR NR NR NR ---1993 29.9 162.5 470.5 8.3 45.2 134.3 0.31994 44.3 241.3 496.9 8.8 47.8 141.9 0.21995 32.2 180.8 450.6 9.7 53.0 147.21996 NR 171.2 467.9 NR 53.6 148.9

Includes CCA and other waterborne preservatives. During 1960s and 70s, other significant waterborne1

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. Values have been computed based on void volume.2

Values have been taken directly from statistical reports.3

Computed from available data.4

Not Recorded.5

B-5

Table B-4: Production of Wood Treated With Waterborne Preservatives, by Product Type. 1

U.S. Statistics

Year (all products)Lumber and Poles Crossties Fence Posts Total

Timber

10 ft % WP 10 ft % WP 10 ft % WP 10 ft % WP 10 ft % WP6 3 6 3 6 3 6 3 6 3

1964 18.0 38.1 0.2 0.3 0.2 0.4 2.10.132 22.7 9.5

1965 20.5 40.9 0.2 0.2 0.3 0.5 2.80.166 25.9 10.1

1966 25.6 42.5 0.4 0.5 0.5 0.7 3.60.327 32.5 11.5

1967 25.7 41.3 0.6 0.8 0.4 0.5 2.40.305 30.1 10.5

1968 21.8 34.8 0.9 1.2 0.1 0.5 2.70.113 26.2 9.6

1969 24.3 40.7 2.4 3.2 0.2 0.5 3.00.114 30.1 11.8

1970 25.1 44.3 1.8 2.4 0.2 0.5 3.20.118 29.7 11.4

1971 26.8 44.9 1.6 2.2 0.2 0.7 4.00.140 35.9 13.3

1972 30.3 47.4 1.7 2.3 0.1 0.9 5.00.121 41.2 15.1

1973 37.3 54.2 1.9 2.5 0.2 0.8 5.40.116 43.8 17.2

1974 45.8 58.9 1.8 2.5 0.0 2.1 12.30.029 53.8 19.6

1975 32.6 53.0 1.3 2.6 0.1 2.0 13.20.086 40.0 16.4

1976 43.6 64..9 1.4 2.7 0.1 1.8 13.30.133 56.0 21.7

1977 42.0 6.8.05 3.7 7.0 0.2 1.3 12.50.172 56.6 22.6

1978 54.6 63.6 5.3 8.5 0.4 2.0 18.00.375 69.5 24.5

1979 84.7 77.8 6.8 10.0 0.1 5.8 33.00.148 107.7 30.6

1980 99.1 84.3 7.9 12.2 0.7 6.7 39.50.620 126.7 38.3

1981 112.7 87.3 9.9 15.5 0.7 7.5 45.50.706 148.3 42.4

1982 NR NR NR NR NR NR NR2NR NR NR

1983 221.8 92.5 10.3 15.5 0.0 7.7 68.80 258.2 55.0

1984 251.4 93.8 12.0 15.4 0.0 7.7 68.80 301.7 57.8

1985 273.8 94.5 13.3 17.3 0.0 7.3 74.10 328.7 63.1

1986 314.1 95.1 15.1 20.6 0.0 12.5 80.50 375.5 67.0

1987 312.4 96.1 15.5 20.6 0.0 8.7 77.70 419.0 72.9

1988 391.1 96.6 14.7 20.7 0.0 9.8 79.00 450.6 75.2

1989 NR NR NR NR NR NR NRNR NR NR

1990 366.3 97.5 17.4 23.7 0.0 12.5 84.00 437.7 74.7

1991 353.2 97.5 16.6 28.9 0.0 81.1 73.60 424.4 75.1

1992 NR NR NR NR NR NR NRNR NR NR

1993 386.1 98.1 20.0 27.9 0.0 10.3 75.20 470.5 77.7

1994 250.0 98.7 24.4 39.0 0.0 13.4 92.70 496.8 78.3

1995 319.5 98.3 29.2 42.5 0.0 18.2 96.9 450.60 77.8

1996 346.0 98.8 24.1 38.0 0 0.0 21.1 90.2 467.8 79.1Includes CCA and other waterborne preservatives. During 1960s and 70s, other significant waterborne1

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. Not Recorded2

C-1

APPENDIX C:QUESTIONNAIRE FOR FACILITIES THAT USE

WOOD AS A SOURCE OF FUEL ANDLIST OF FACILITIES SENT QUESTIONNAIRE.

C-2

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 noobligations 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-3

PAGE 2

Purpose: This questionnaire addresses the fuel-source utilized by wood burning facilities inthe state of Florida. If your organization does not utilize wood as a fuel source, pleaseindicate below the type of fuel utilized, fill out the company information and return thisinformation 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):_______________________________

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PAGE 3

3. Wood Characteristics and QuantitiesQuantity

(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 RecyclingCompany.)

________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________________

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-5

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-6

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

Owner/Company Contact PersonAddress City St Zip Phone Fax

First/ Middle Last Name

1 KOPPERS INDUSTRIES, INC. DONALD SURRENCY 200 NW 23RD AVENUE GAINESVILLE FL 32609 90437651442 UNIVERSITY OF FLORIDA - TACACHALE ALEX E.S GREEN SPACE SCIENCE RESEARCH GAINESVILLE FL 32611 90434220013 U.S. FOREST INDUSTRIES, INC. JACK B. PRESCOTT POST OFFICE BOX 2560 PANAMA CITY FL 32402 9047854311 90476362904 LOUISIANA PACIFIC CORP DENNIS MCCORMICK P.O. BOX 3107 CONROE TX 77305 4097605921 40975605701

5 C & D PAVING, INC. CHARLES MONTES 15150 GOLDEN POINT LANE WEST PALM BEACH FL 33414 40752300046 JEFFERSON SMURFIT CORP (U.S.) HOLLIS H. ELDER P.O. BOX 150 JACKSONVILLE FL 32201 9047985600 90479857007 CHAMPION INTERNATIONAL CORPORATION F. DOUG OWENBY POST OFFICE BOX 87 CANTONMENT FL 32533 90496821218 HIGDON FURNITURE CO J.W. HIGDON P O BOX 978 QUINCY FL 32351 90462775649 COASTAL LUMBER CO JOHN G. KYNOCH HIGHWAY 27 NORTH P.O. BOX 1128 HAVANA FL 70333 9045396432 904539679910 MACTAVISH FURNITURE INDUSTRIES HERSHEL SHEPARD P.O. BOX 430 QUINCY FL 32351 9046277561 904627751911 MANATEE INTER. WOOD PRODUCTS ROY T. BOYD 2035 N.W. 8TH AVENUE OCALA FL 34475 9043518000 904351596912 TIMBER ENERGY RESOURCES HARRY L. GEORGE P.O. BOX 199 TELOGIA FL 32360 8503798341 850379876613 FLORIDA PLYWOODS JOHN MAULTSBY P. O. BOX 458 GREENVILLE FL 32331 904948221114 LFC NO. 47 CORP. MADISON BIOMASS PLT DAVID J. BROWN 4000 KRUSE WAY PL, BLDG 1 LAKE OSWEGO OR 97035 5036369620 50369702881

15 FLEMING LUMBER CO H. FLEMING P O BOX 68 CRESTVIEW FL 3253616 ATLANTIC SUGAR ASSOCIATION JOHN FANJUL P. O. BOX 1570 BELLE GLADE FL 33430 5619966541 802996802117 OSCEOLA FARMS CARLOS RIONDA P O BOX 679 PAHOKEE FL 33476 4079247156 407924324618 OSCEOLA POWER L.P. JAMES M. MERIWETHER P. O. BOX 86 SOUTH BAY FL 33493 407996907219 BARTOW ETHANOL, INC. DAVID HALL 12900 34TH STREET NORTH CLEARWATER FL 34622 813573304020 RIDGE GENERATING STATION, L.P. GEORGE WOODWARD 3131 K-VILLE AVENUE AUBURNDALE FL 33823 9416652255 941665040021 FLORIDA FURNITURE INDUSTRIES, INC. KENNETH LOYLESS P. O. BOX 610 PALATKA FL 32178 9043283444 904328601122 GEORGIA-PACIFIC CORP. PLYWOOD PLANT TOBIN FINELY 223 GORDON CHAPEL ROAD HAWTHORNE FL 32640 3524814311 352481491523 ROBERTS LUMBER CO, INC. ALAN ROBERTS ROBERTS LUMBER COMPANY INC PERRY FL 32347 9045844573 904584434824 PERRY LUMBER COMPANY, INC. PAUL DICKERT 1509 S. BYRON BUTLER PKWY PERRY FL 32347 9045843401

C-7

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

Owner/Company Contact PersonAddress 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 9044883800R

26 GEORGIA-PACIFIC CORP. PULP/PAPER MILL MYRA CARPENTER GEORGIA-PACIFIC CORPORATION PALATKA FL 32178 9043252001 904328001427 BUCKEYE FLORIDA, LIMITED PARTNERSHIP CHARLES AIKEN BUCKEYE FLORIDA PERRY FL 32347 9045841121 904584122028 RECOVERY CORPORATION OF AMERICA R.L. TORRENS 102 STAR LANE BUTLER MO 579011

29 GULFSTREAM PARK JACK BLAIR 901 S. FEDERAL HIGHWAY HALLANDALE FL 33009 305454700030 QUADREX ALTERNATE ENERGY DIVISION ROGER GARRA,PRE 7108 FAIRWAY DRIVE PALM BEACH FL 33418 5616277700

GARDENS31 COMBUSTOR INC.SO FLA DETENTION FACILITY R, HOOVER 6663 HOLLANDALE DRIVE BOCA RATON FL 33433 305368710032 FLORIDA COAST PAPER COMPANY FERREL O. ALLEN FLORIDA PORT ST.LUCIE FL 32457 9042271171 904227239933 USEPPA INN & DOCK CO. / USEPPA ISLAND VINCENT FORMOSA P.O. BOX 640 BOKEELIA FL 33922 9412831061 9412830290

CLUB34 SAFETY HARBOR CLUB JACK A. HUNT P.O. BOX 2276 PINELAND FL 33945 9414721019 941472132135 RUDOLF KRAUSE & SONS OF FLORIDA, INC. RUDY KRAUSE ROUTE 4, BOX 331 SUMMERLAND KEY FL 33042 305872400036 TONLEY FOUNDER & MACHINE, CO., INC J.O. TOWNLEY P.O. BOX 221 CANDLER FL 32624 904355993037 JEFFERSON SMURFIT CORPORATION (US) WARREN S. FLENNIKEN NORTH 8TH STREET F E R N A N D I N A FL 32034 9042615551 9042775888

BEACH38 RAYONIER INC. STEPHEN D. OLSEN P.O. BOX 2002 F E R N A N D I N A FL 32035 9042613611 9042771413

BEACH39 BOCA RATON RESORT & CLUB, LTD JESSE PERERA 501 EAST CAMINO REAL BOCA RATON FL 33432 407395300040 ST LUCIE INCINERATION - ON COLD STANDBY WAYNE HOLLAND 2300 VIRGINIA AVE FORT PIERCE FL 34982 407468170741 ROBBINS MANUFACTURING CO. BRAD ALSTON PO BOX 17939 TAMPA FL 33682 813971303042 LAKELAND DRUM SERVICE RANDY GUY P.O. BOX AUBURN FL 33823 9419673388 941967951643 ENVIRON-LECTRIC, INC WAYNE BODIR P.O. BOX 507 DE FUNIA SPAS FL 32435 8508922711 850392642844 NORTH FLORIDA LUMBER C. FINLEY MCRAE P O BOX 7 GRACEVILLE FL 32440 904263445745 OKEELANTA CORP RICARDO LIMA P O BOX 86 SOUTH BAY FL 33493 4079969072 407992732646 FORESTRY RESOURCES JOHN CAAUTHEN 4353 MICHIGAN LINK FORT MYERS FL 33916 9413324206 941334295347 ROYAL OAK ENTERPRISES, INC. JIM STROUP 1921 N.W. 17 PLACE OCALA FL 34475 3527320005 3527323874Questionnaire sent to company headquarters. Plant is located in Florida.1