How to Avoid Wood Mulch Contamination

Transcription

1 How to Avoid Wood Mulch Contamination New York State Department of Environmental Conservation David Gibb, P.E. November 2013

2 History and Background Long Island began to see select C&D wood used for mulch production in Primarily natural materials (tree branches, stumps, etc) and pallets had been used prior Letter to Industry in December 2009 Definition of unadulterated wood (Part b(175)) 2

3 Unadulterated Wood Definition Unadulterated wood means wood that is not painted or treated with chemicals such as glues, preservatives or adhesives. Any painted wood or chemically treated wood (eg., pressure treated wood, treated railroad ties) or wood containing glues or adhesives (eg., plywood, particle board) is considered adulterated wood. (Part b(175)) 3

4 Mulch Applications & Potential Exposures Compost Bulking Agent & Soil amendment for crop production Exposure: Human ingestion Bedding for children's playgrounds Exposure: skin contact or ingestion for humans or pets Flower beds & Gardens Exposure: skin contact or ingestion for humans or pets 4

5 Adulterated Wood and Their Associated Toxins Three Classes of Pressure Treated Wood (waterborne, creosote, oil-borne) - waterborne preservatives are typically used in residential, commercial and industrial building structures. - eg. Chromated Copper Arsenate (CCA-C), Alkaline Copper Quat (ACQ-C, ACQ-D, ACQ- D Carbonate), Micronized Copper Quat (MCQ), Copper Azole (CA-B & CA-C, µca-c) and Sodium Borates (SBX/DOT). 5

6 Adulterated Wood and Their Associated Toxins CCA Chromated copper arsenate Banned by EPA in 2003 for residential use Wolmanized Natural Select (Copper Azole), Preserve and NatureWood (ACQ), MicroPro, Smart Sense (MCQ), and Advance Guard (Borate). Creosote is primarily used for treating railroad ties, guardrail posts, and timbers used in marine structures 6

7 Adulterated Wood and Their Associated Toxins Oil-borne preservatives are most often used for treating utility poles and cross arms eg. Chlorpyrifos/IBPC, Copper Naphthenate and Pentachlorphenol Plywood & Particle board Various chemicals & adhesives Painted wood Various chemicals & lead 7

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9 How Select C&D is generated C&D facilities with sorting & picking lines C&D facilities without sorting & picking lines 9

10 Typical C&D Picking Line 10

11 Typical Select C&D From Facilities with Picking Lines 11

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16 Typical Select C&D From Facilities without Picking Lines Only slightly coated with C&D dust More recognizable Less Adulterated wood contamination

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18 Mulch Grinder 18

19 Contaminated Course Ground Mulch 19

20 Contaminated Finished Mulch 20

21 Economic Forces Cost of disposal for adulterated wood Mulch profit margins 21

22 Mulch Analytical Test Result Mulch producers using Select C&D have exceedances Small percentage of Treated lumber will cause exceedances

23 Regulatory Overview Recognizable prior to pulverization Select C&D frequently includes treated wood that is difficult or impossible to visually detect. Covered with C&D dust or weathered Clear forms of treatment Uncontaminated Treated, painted, or containing adhesives Covered with C&D dust 23

24 Regulatory Overview Adequate separation and supervision of adulterated wood prior to pulverization C&D must be tipping, processing & storage on a concrete or asphalt Pad with leachate control or inside a building 24

25 Regulatory Overview Tipping, processing & storage of C&D outside on the ground may produce leachate Tipping, processing & storage of C&D outside on the ground may violate special permit conditions. 25

26 Where Do We Go From Here? Other uses for Select C&D : Wood gasification Particle board Close reading of Regulations requires Case- Specific BUD, Predetermined Bud Does not apply. But what about pallets How about chemical testing? 26

27 Complexities of Chemical Testing Cost to owner and Department (if we spit sample) Stock piling required Existing accreditation system for CCA X-Ray Fluorescent Spectrophotometer (XRF) Chemical testing Fine grind to 1/16 th inch EPA Method 3052 &

28 Thank You. Questions? 28

29 Contact Info: David Gibb, P.E. NYS DEC 50 Circle Rd., Stony Brook, NY Phone: (631)