Susquehanna Co-Gen Annual report of Fuel Burned 

### YEAR TONS TREATED WOOD BURNED 1988 1989 89,281 1990 82,038 1991 77,000 EST 1992 116,000 EST 1993 89,000 EST 1994 89,500 EST 1995 103,423 1996 76,000 

### EST 1997 98,720 1998 97,444 1999 76,611 2000 110,013 2001 122,288 2002 113,198 2003 111,699 2004 114,470 2005 116,447 2006 116,052 2007 118,231 

### 2008 93,861 2009 99,741 2010 94,688 2011 72,770 YTD TOTAL 2,278,475 Tons burned

### Statement ofWilliam R SIK\(;kf
I,

### William R. 

### Sheeler, make the following statement in 

### support ofthe petition of the TreatedWood Council for a determination that 

### non-hazardous secondary

### treated wood biomass materials. as described in 

### that petition. are not a solid waste whenusecl as fuel 

### in

### a combustionunit. 

### I. I amthe 

### Business Managerfor Zwicky Processing & 

### Recycling, Inc., a family-owned biofuel processing and recycling 

### facility located in

### Fleetwood, P A Our 

### co:tnpany 

### has operated since 1952. 2. 

### Zwicky's facility 

### wasbuilt for processing non-hazardous secondary treated

### woodbiomass, along with 

### construction and demolition debris. 

### These reclaimed materials
are combined and ground

### to provide a combustion

### material used by cement plants, paper

## mills. and electricity generators.**3~** As 

### an example ofthecurrent scale ofZwicky's

### operations, its fucility 

### processed 140,000 tons ofnon-hazardous secondary biomass during the first ten 

### months of2012.

# ~~~- William R Sheeler

# Wheeler Lumber, LLC
March 26. 2013 

### STATEMENT OF JEFF PARRETT
1. My name is Jeff Parrett. I make the following statement in support ofthe petition ofthe Treated Wood Council for a determination that non-hazardous secondary treated wood biomass materials, 

### as described 

### in that petition, 

### are not a solid waste when used 

### as a fuel 

### in a combustion unit. 

### 2. My title is vice president of Wheeler Lumber, L.L.C. In the course of my work spanning 26 years in the wood treating business, 

### I have gained familiarity with various types of wood products used 

### as railroad ties, utility poles and bridge timbers then beneficially reused as a valuable commodity fuel. 

### 3. While creosote treated wood products are the best known types used for railroad ties and reused for energy proouction, I am also familiar with copper Naphthenate treated wood products. and dual treatments using creosote with borate and copper Naphthenate with borate, that are used the same way. Copper Naphthenate has been used off and on since the early 1900s but usage became a commercial proposition during World War II, when it was applied to railroad ties 

### in conjunction with creosote due to creosote shortage
. Copper Naphthenate has also been used for many years for utility poles, railroad ties and bridge timbers treated and sold by Wheeler Lumber and have more recently found a growing market acceptance 

### as a treatment product on its own or with borate for railroad ties. Wheeler Lumber currently specifies, and treats with Copper Naphthenate for the state of New York. many other state DOTs, USFS, Railroads, along with many other customers nationwide. 4
. Like other forms oftreated wood such as those using creosote, copper Naphthenate treated wood ties are desirable as a fuel to electricity generators and others because ofthese materials' high BTU value, attractive economics, and superior greenhouse gas characteristics compared to fossil fuel that would otherwise be burned for energy generation 

### ifthese valued secondary materials were not available. One example of which 

### I 

### am aware is the DTE plant in Wisconsin, which is permitted to burn copper Naphthenate, borate, and creosote treated wood secondary materials.

Dated: March 26
. 20 13

12127 

### Whitewood Service 

### Road, Whitewood, SD 57793 Web 

### Address: \Y\V\v
.wheeler-con
.com 

### E-Mail: info@wheeler-con.com Phone: 

### (605)269-2215 

### Toll Free:**(8oo)84 3-** **8~304** 

### Fax: (605)2.69-2497