NHSM Supplemental ListingOffice of Information and Regulatory AffairsSeptember 20,2013,OverviewSupplemental NHSM listings very importantRather use renewable, carbon neutral biomass than fossil fuelsTens of millions of dollars at stake; several dozen mills useP R li R id l RR ti d C&D W dPaperRecyclingResiduals,RRties, andC&DWoodBusiness certainty needed for planning MACTcomplianceMajor investment decisions being made nowExamples – could use more PRR with improved materialhandling OR avoid buying gas boiler to replace PRR if itbecomes a waste2Paper Recycling ResidualsMeets all legitimacy criteria – contaminant comparison, value, andhandlingDefine PRR BroadlyResiduals from repulping of cardboard, newsprint, printing andwriting papers and other pre-and post-consumer fiberswritingpapers,andotherpreandpostconsumerfibersPlace no restrictions on BTU valueBoilers designed to economically recover energyover/under airBoilersdesignedtoeconomicallyrecoverenergy–over/underairComparable to wet biomass – 3700 BTU/lb (ave.); need some wetfuelsDon’t restrict to onsite use - allow offsite use as wellUse in bioenergy facilityUseinbioenergyfacilityListing could encourage use and reduce landfilling3Creosote Railroad TiesMeets all legitimacy criteria – contaminant comparison with solid andliquid fuels, high value, and handled as fuelDesigned to Burn – currently, able to burn with appropriate feedmechanismStatute and 241 4 regulations donotrequire DTB criteria–Statuteand241.4regulationsdorequireDTBcriteriainstead balance all factors and list without restrictionsIFDTB retained, then make engineering assessment of boilersability to burn, such as, use in certain types of boilersPerverse outcomes – MACT limits and clean fuel start-up changinguse and permitting of fuel oil so historic use of oil should sufficeuseandpermittingoffueloil,sohistoricuseofoilshouldsufficeList creosote treated railties (and borate)Other stakeholders seeking listing of other treated woodsOtherstakeholdersseekinglistingofothertreatedwoods4Processed C&D WoodMeets all legitimacy criteria – contaminant comparison,value and handlingvalue,andhandlingSome mills rely very heavily on C&D – up to 40%High BTU fuel – consistent qualitySupport reasonable performance-based managementib d C ( 2013)practces suggestedby BPA andCMRA(June2013)Addresses any lingering EPA concerns about outlier samplesProcessors use varied techniques to reduced unwanted materials5Next StepsAny alternative fuel is carefully reviewed andpermitted by states so environmental impacts aredd daresse.Environment may be worse off if undue restrictionsf th th t i lon use ofthesethree materialsIncrease landfilling and fossil fuel useAsk OMB to complete review in OctoberGive time to stakeholders to examine any issues andlimitations and develop more information for EPA90 day comment periodThe earliest possible signal that these renewablebiomass materials will remain fuels6Summary of IssuesVery important that proposal is moving-thanksVeryimportantthatproposalismovingNo or minimal limitations when listing three residualsPRR – define broadly, no BTU constraints, allow offsiteuseRail ties – rely on the record not DTB to justify broadlisting, include borate as well as creosoteC&D – reasonable management practices, no testingProcess–Getproposal out in October,need 90 daypcomment period7