1. USWAG Treated Wood Activities Jim Roewer, USWAG APPA Supply Management Conference May 2, 2007

2. USWAG Overview USWAG engages in regulatory advocacy pertaining to RCRA, TSCA, and HMTA USWAG’s Mission is to address the regulation of utility wastes, byproducts and materials in a manner that protects human health and the environment and is consistent with the business needs of its members Comprised of over 80 utilities, power producers, energy companies and utility trade associations

3. Treated Wood Activities & Goals Working to preserve the continued availability of treated wood for industrial uses Maintain the option of secondary use of poles & crossarms Maintain the non-hazardous waste status of discarded treated wood

4. USWAG Treated Wood Guidelines Developed in response to regulatory/policy pressures Demonstrates industry commitment to treated wood product stewardship Consistent with utility practices Supports continued use of treated wood products

5. USWAG Treated Wood Guidelines Purchasing Policies to Reflect Treatment Standards Evaluate Alternatives to Treated Wood Re-Use Treated Wood Within Utility System Provide Notification to Secondary Use Properly Dispose of Treated Wood Explore Alternative Management Options Ensure Program Awareness Coordinate With Other Industry Groups

6. Establish purchasing policies that reflect appropriate treatment standards Companies should endeavor to have purchasing documents, specifications, or procedures requiring that new treated wood products meet AWPA standards or specific utility company requirements Addresses bleeding, leaching concerns

7. Evaluate, where applicable, treated wood alternatives Treated wood preferred product Reliability & cost concerns paramount Alternatives may be used depending on specific concerns Company-specific factors, customer needs, structural support requirements, and economic impacts affect decision

8. Assessment of Treated Wood and Alternate Materials for Utility Poles 1010964 Final Report, June 2004 Prepared for Electric Power Research Institute 3412 Hillview Avenue Palo Alto, California 94304 EPRI Project Manager M.E. McLearn Transmission and Distribution Soil and Water Issues Utility Solid Waste Activities Group 701 Pennsylvania Avenue, Fifth Floor Washington, D.C. 20004-2696 USWAG Project Manager J.R. Roewer USWAG Executive Director

10. Reuse treated wood products within the utility system Life extension (e.g., groundline treatment of in-service poles) Reuse of poles to reduce the amount of treated wood removed from service and purchase of new treated wood products

11. Ensure that secondary users are informed with regard to the proper handling, use, and disposal of treated wood products Secondary use applications conserve natural resources and landfill space Provide information to secondary users re appropriate handling, use, and ultimate disposal Ensure stewardship through treated wood life

12. Secondary Use Information May Include: Caution: This wood has been treated with an EPA registered wood preservative and may contain chromated copper arsenate, pentachlorophenol, creosote, or other registered wood preservatives Wear a dust mask and goggles when cutting or sanding treated wood Wear gloves when working with treated wood Ask for the consumer safety information sheet or other safety information that may be available

13. Secondary Use Information May Include: Do not use treated wood in circumstances where there may be direct contact with domestic animals or livestock which may crib (bite) or lick the wood Do not use treated wood in circumstances where the wood may become a component of food or animal feed, such as structures or containers for storing silage or food Ensure that the treated wood is properly disposed of after its intended use. Removal and disposal by ordinary trash collection is generally acceptable, though it may advisable to check with local officials regarding proper disposal options

14. Arrange for proper disposal of treated wood that is not reused Treated wood destined for disposal rather than reuse is managed in accordance with Federal and State laws governing solid waste disposal

15. Continue to explore and utilize alternative management options Secondary use (sale or donation to the public) critical option Secondary use consistent with EPA’s preferred policy of resource conservation and reuse USWAG will explore and expand alternative reuse/recycling and disposal options

17. Options for Disposal/Reuse Sale/Donation for Reuse Dimensional Lumber Paper Manufacture Energy Recovery Incinceration Chipping/Composting Landfilling

18. Options for Disposal/Reuse Sale/Donation for Reuse Most Popular Option CIS/CSIS Information Transfer End Use concerns

19. Options for Disposal/Reuse Dimensional Lumber Remanufacturing Issues End Use Concerns Paper Manufacture Preservative Extraction Issues Non-commercial Scale

20. Options for Disposal/Reuse Energy Recovery Air Permitting Issues Regulation & Management of Ash Issues Incineration Air Permitting Issues Regulation of Ash Costs >> Energy Recovery

21. Options for Disposal/Reuse Chipping/Composting Not Common Practice Use as Daily Cover Leachability Issues Landfilling Second Most Frequently Used Option Costs = f (Landfill Capacity)

22. Ensure program awareness Establish system to ensure personnel are aware of and understand the guidelines Ensure guidelines are understood and supported at all levels of the company.

23. Continue to coordinate with other industry groups Telecommunications & railroad industries Encourage adoption of treated wood management guidelines Ensure the proper management of treated wood products by all groups

24. Treated Wood Guidelines Submitted to EPA Under review by EPA OCG, OSW, OPPT Draft MOU between EPA & USWAG Referenced in GLBTS status report Finalization?

25. USWAG Goals Preserve Use Options Continued Disposal as Non-hazardous Waste Maintain Secondary Use Options

27. Questions? jim.roewer@uswag.org 202/508-5645 www.uswag.org