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EPARulemakingEPA-HQ-RCRA-2008-0329

Notice of Proposed Rulemaking - Identification of Non-Hazardous Secondary Materials That Are Solid Waste

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American Forest & Paper Association filings
4

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American Forest & Paper Association filed 4 comments on this docket between Feb 6, 2009 and Apr 10, 2012. 190 other organizations filed here. The comment window closed 5271d ago.

What American Forest & Paper Association filed (4)

Apr 10, 2012· Comment Submitted by Timothy G. Hunt, Senior Director, Air Quality Programs, American Forest & Paper Association (AF&PA)· EPA-HQ-RCRA-2008-0329-1977

Dear Jim: Thank you for meeting with AF&PA, AWC and other coalition partners on March 22nd to discuss our comments on the Non-Hazardous Secondary Materials (NHSM) proposed rule ((EPA-HQ-RCRA-2008-0329). We understand the Agency is on an accelerated schedule to complete the NHSM and other Boiler MACT rulemakings, so I wanted to get back to you with some follow-up information. During our discussion on non-waste fuels and wastewater treatment residuals (WWTR) in particular, the question came up about how reliant our mills are on WWTR as a fuel source. In our comments, we reported that about 25% of WWTR is burned for energy recovery and that EPA only needs to concern itself with the practices and quality of the WWTR that are used in boilers to produce energy and steam. We provided data that showed that contaminant levels in WWTR are comparable to those in traditional fuels that would be burned in the boilers (see Table 1 on page 51 of 2/21/12 AF&PA et. al. comments, EPA-HQ-RCRA-2008-0329-1843). We would expect that this data is convincing to the Agency that WWTR meet the legitimacy criteria and that mills could rely on the comparisons in the future, if necessary. Finally, we emphasized that the NHSM Rule does not in fact address the WWTR that are not combusted. Let me provide you further perspective and data on those mills that do burn WWTR. Based on 2010 data collected as part of AF&PA's biennial Environment Health and Safety survey (this is provided by mills confidentially and then aggregated by AF&PA since information on fuel use is very sensitive), forty-seven member company mills reported burning 786,000 dry tons of WWTR (this is slightly more than reported in our comments using the most up-to-date information). Those mills generated roughly 1,130,000 dry tons of WWTR so 70% of the WWTR that are generated by those mills are burned for energy recovery. If the five mills that burn less than 20% of their WWTR are excluded, the remaining forty-two mills burn about 80% of the WWTR produced onsite. Thus, for those mills that burn WWTR, regularly they truly rely on it as a steady source of BTUs day in and day out, so it is integral to the operations of the mill and the boiler. In fact, sixteen of those mills (a third) burn 100% of the WWTR generated. If you would like data from the forty-seven mills we could provide that information in a blinded format. For the small amount that is not burned on site (at mills that regularly burn WWTR), several circumstances explain why it might be beneficially reused elsewhere or even land-filled. First, as we described in our comments, WWTR are generally dewatered to increase the value as a fuel. If the screw presses or other equipment used to remove water are not operating properly or adequately then the WWTR may not have properties conducive for combustion. Second, it is more challenging to remove water from some types of WWTR especially those that are high in non-fiber biological materials such as generated in aerated stabilization basins (ASBs). Primary clarifier residuals and secondary residuals from aerated sludge treatment (ASTs) are routinely and easily dewatered. Third, dewatered WWTR are stored outside like other biomass residuals (hog fuel) for short periods of time (a few weeks or months) and during rainy weather may reabsorb moisture. This is generally not a concern, but if combustion conditions for the mill dictate the need for a drier balance of fuels, then the wetter materials, including hog fuel and WWTR, may be passed over to maintain overall boiler and steam system needs. Some of the temporarily "passed over" materials soon dry and as weather and mill conditions change are again consumed as a valuable fuel. Process needs and economic incentives ensure against burning other than suitable fuels. Finally, if there are malfunctions of the fuel feeder systems to the boiler then WWTR may not get burned for a short period of time (couple of weeks or month). When repairs are made to the…

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Feb 23, 2012· Comment submitted by Paul Noe, Vice President for Public Policy, American Forest & Paper Association, et al.· EPA-HQ-RCRA-2008-0329-1946

Filed on regulations.gov — full text not in the inline record.

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Aug 5, 2010· Comment submitted by Paul Noe, Vice President, Public Policy, American Forest & Paper Association (AF&PA)· EPA-HQ-RCRA-2008-0329-0871

Dear Sir or Madam, Attached please find the American Forest & Paper Association (AF&PA)?s comments on the proposed ?Identification of Non-Hazardous Secondary Materials? rule (Docket ID No. EPA-HQ-RCRA-2008-0329) published in the Federal Register on June 4, 2010. Please feel free to contact me with any questions or concerns. Best regards, Paul Noe Vice President, Public Policy

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Feb 6, 2009· Comment submitted by Timothy G. Hunt, Senior Director, Air Quality Programs, American Forest & Paper Association (AF&PA)· EPA-HQ-RCRA-2008-0329-0374

"Hunt, Tim" <Tim_Hunt@afandpa.org> 02/02/2009 04:49 PMTo Group Rcra-Docket@EPA cc Matt Hale/DC/USEPA/US@EPA, Michael Galbraith/DC/USEPA/US@EPA, Brian Shrager/RTP/USEPA/US@EPA bcc Subject AF&PA comments on ANPR for non-hazardous solid waste: Docket # EPA-HQ-RCRA-2008-0329 TO:RCRA Docket Attached are the American Forest & Paper Association (AF&PA) comments on OSWER�s January 2nd Advance Notice of Proposed Rulemaking for Identification of Non-Hazardous Materials that are Solid Wastes (74 FR 41) plus a separate file with the eight referenced attachments. Both documents have electronic bookmarks that correspond to the table of contents for easy reference. If you have any questions concerning these comments, please feel free to contact me. Timothy Hunt Senior Director, Air Quality Programs American Forest & Paper Association 1111 19th St., NW Washington, DC 20036 phone: 202-463-2588 tim_hunt@afandpa.org

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Abstract

OSWER must determine which non-hazardous materials are "solid wastes" so that the Office of Air and Radiation can promulgate the Commerical and Industrial Solid Waste Incineration (CISWI) MACT standards of the Clean Air Act (CAA) sections 112 and 129.

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Co-filers (190)

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