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How to Avoid Wood Mulch Contamination
How to Avoid Wood Mulch Contamination New York State Department of Environmental Conservation David Gibb, P.E. November 2013 NYS Department of Environmental Conservation History and Background • Long Island began to see “select C&D” wood used for mulch production in 2008-09 – Primarily natural materials (tree branches, stumps, etc) and pallets had been used prior • Letter to Industry in December 2009 – Definition of unadulterated wood (Part 360-1.2b(175)) 2 NYS Department of Environmental Conservation 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 360-1.2b(175)) 3 NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation 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, ACQD Carbonate), Micronized Copper Quat (MCQ), Copper Azole (CA-B & CA-C, µCA-C) and Sodium Borates (SBX/DOT). 5 NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation 8 NYS Department of Environmental Conservation How “Select C&D” is generated • C&D facilities with sorting & picking lines • C&D facilities without sorting & picking lines 9 NYS Department of Environmental Conservation Typical C&D Picking Line 10 NYS Department of Environmental Conservation Typical “Select C&D” From Facilities with Picking Lines 11 NYS Department of Environmental Conservation 12 NYS Department of Environmental Conservation NYS Department of Environmental Conservation NYS Department of Environmental Conservation 15 NYS Department of Environmental Conservation Typical “Select C&D” From Facilities without Picking Lines • Only slightly coated with C&D dust • More recognizable • Less Adulterated wood contamination NYS Department of Environmental Conservation 17 NYS Department of Environmental Conservation Mulch Grinder 18 NYS Department of Environmental Conservation Contaminated Course Ground Mulch 19 NYS Department of Environmental Conservation Contaminated Finished Mulch 20 NYS Department of Environmental Conservation Economic Forces • Cost of disposal for adulterated wood • Mulch profit margins 21 NYS Department of Environmental Conservation Mulch Analytical Test Result • Mulch producers using “Select C&D” have exceedances • Small percentage of Treated lumber will cause exceedances NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation 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 NYS Department of Environmental Conservation Where Do We Go From Here? • Other uses for “Select C&D”: – Wood gasification – Particle board • Close reading of Regulations requires CaseSpecific BUD, Predetermined Bud Does not apply. – But what about pallets • How about chemical testing? 26 NYS Department of Environmental Conservation 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 1/16th inch • EPA Method 3052 & 6020 27 NYS Department of Environmental Conservation Thank You. Questions? 28 Contact Info: • David Gibb, P.E. NYS DEC 50 Circle Rd., Stony Brook, NY 11790 Phone: (631) 444-0375 Email: [email protected] 29 NYS Department of Environmental Conservation
