[NEWS] EPA Proposes Classifying Treated Railroad Ties as Nonhazardous Waste
– by Anna Simet, November 3, 2016, Biomass Magazine
The U.S. EPA has proposed an amendment that will add additional treated railroad ties to its list of categorical nonwaste fuels under the Non-Hazardous Secondary Materials Rule.
Under the Resource Conservation and Recovery Act, NHSM rulemakings identify which nonhazardous secondary materials are or aren’t solid wastes when burned in combustion units. If material is a solid waste under RCRA, a combustion unit burning it is required to meet the Clean Air Act Section 129 emission standards for solid waste incineration units. If the material is not a solid waste, combustion units are required to meet the CAA Section 112 emission standards for commercial, industrial, and institutional boilers, much less stringent standards.
The NHSM went into effect in March 2011. It has been amended twice since then, the most recent of which added three materials—construction and demolition debris, paper recycling residuals and creosote-treated railroad ties—to the nonwaste fuels list. The latest proposal would add railroad ties processed with creosote-borate, copper naphthenate and copper naphthenate-borate, under certain conditions depending on the chemical treatment.
According to the EPA proposal, creosote-borate railroad ties, as well as mixtures of creosote, copper naphthenate and copper naphthenate-borate railroad ties, would qualify as a nonwaste fuel when processed and combusted in units designed to burn both biomass and fuel oil, but must be part of normal operations and not solely as part of start-up or shut-down operations.
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