NHSM Supplemental Listing

Office of Information and Regulatory Affa

Se

p , tember 20, 20
Overview

Supplemental NHSM listings very important

Rather use renewable, carbon neutral biomass than foTens of millions of dollars at stake; several dozen mills P R li R id l RR ti d C&D W d Paper Recycling Residuals, RR ties, and C&D Wood

Business certainty needed for planning MACT compliance

Major investment decisions being made nowExamples – could use more PRR with improved materhandling OR avoid buying gas boiler to replace PRR if becomes a waste
Paper Recycling Residuals

Meets all legitimacy criteria – contaminant comparison, vhandlingDefine PRR Broadly

Residuals from repulping of cardboard, newsprint, priwriting papers and other pre writing papers, and other pre

- and post and post

-consumer fib

consumer fib

Place no restrictions on BTU value

Boilers designed to economically recover energy Boilers designed to economically recover energy – ov

ov

Comparable to wet biomass – 3700 BTU/lb (ave.); nefuels

Don’t restrict to onsite use - allow offsite use as well

Use in bioenergy facility Use in bioenergy facilityListing could encourage use and reduce landfilling
Creosote Railroad Ties

Meets all legitimacy criteria – contaminant comparison witliquid fuels, high value, and handled as fuelDesigned to Burn – currently, able to burn with appropriatmechanism

Statute and 241 4 regulations do Statute and 241.4 regulations do not require DTB crite

require DTB crite

instead balance all factors and list without restrictionsIF DTB retained, then make engineering assessment oability to burn, such as, use in certain types of boilers Perverse outcomes – MACT limits and clean fuel start-uuse and permitting of fuel oil so historic use of oil shouse and permitting of fuel oil, so historic use of oil sho

List creosote treated railties (and borate)Other stakeholders seeking listing of other treated woods Other stakeholders seeking listing of other treated woods
Processed C&D Wood

Meets all legitimacy criteria – contaminant comvalue and handling value, and handlingSome mills rely very heavily on C&D – up to 40

High BTU fuel – consistent quality

Support reasonable performance-based managepractices suggeste

d b d C ( 20

by BPA an

d

CMRA 

(June 20

Addresses any lingering EPA concerns about outlier sProcessors use varied techniques to reduced unwante
Next Steps

Any alternative fuel is carefully reviewed and permitted by states so environmental impactadd d resse .Environment may be worse off if undue reston use of th th t i l f these three materials

Increase landfilling and fossil fuel use

Ask OMB to complete review in OctoberGive time to stakeholders to examine any isslimitations and develop more information for 

90 day comment period

The earliest possible signal that these renewbiomass materials will remain fuels 
Summary of Issues

Very important that proposal is moving Very important that proposal is moving

- thanks

No or minimal limitations when listing three resPRR – define broadly, no BTU constraints, allow useRail ties – rely on the record not DTB to justify listing, include borate as well as creosoteC&D – reasonable management practices, no teProcess 

– Get 

p p ro

posal out in October, need 90 

comment period