No Poisonwood Bible

All eyes are on Florida, as the state leads the nation in researching how to manage chromated copper arsenate (CCA)-treated wood waste. Because the wood is just beginning to reach disposal now, and won’t peak for another 15 to 20 years, there is no waste management manual to tell the industry what to do.

“Most of the other states that I’ve spoken with have been somewhat surprised, and sometimes not really aware of this as a waste management issue,” says Timothy Townsend, a lead researcher on the project and associate professor with the University of Florida, Gainesville.

“There’s no arguing that arsenic leaches out,” says Bill Hinkley, chief of the bureau of solid and hazardous waste for the Florida Department of Environmental Protection (FDEP), Tallahassee. “But is there enough leaching out that we should do something about it?” Some people question whether CCA-treated wood poses a serious waste management problem at all, he says.

“You have to look at how much CCA really penetrates the wood. How much is left as a residue when you grind it up or after it’s been sitting above ground in use for decks and things for years?” says Ed Repa, environmental programs director the National Solid Wastes Management Association of the Environmental Industry Associations, Washington, D.C. “If you think about it, I’m not sure.”

Nevertheless, several organizations including the U.S. Environmental Protection Agency (EPA) Office of Solid Waste, Crystal City, Va., continue to evaluate the research coming from Florida.

According to Greg Helms, EPA environmental protection specialist, there isn’t “enough data yet to make any recommendations as an agency.” Consequently, the EPA isn’t requiring states do anything different at this time and isn’t changing the hazwaste exclusion.

“If the data shows that there are risks, then we’ll look at this from a disposal perspective and evaluate the exclusion,” Helms says.

The EIA and Solid Waste Association of North America (SWANA), Silver Spring, Md., also are following the research. “I don’t think you’ll have extensive areas of ground contamination from Subtitle D facilities, but we’re watching the issue and trying to understand the implications of the research for our members,” says John Skinner, SWANA’s executive director and CEO.

Even without substantial data, the potential for problems in the waste industry are real.

“If the wood mulch being produced from C&D recycling facilities can’t be land-applied because of the arsenic concentration in the mulch; if [the CCA-treated wood] shouldn’t be burned because of the arsenic in the ash; and if you can’t recycle wood, which is the biggest volume of C&D debris, it’s going to be a big deal for C&D recyclers,” Townsend says. “And this issue is a potentially big deal to C&D and municipal waste disposers if it goes into an unlined landfill or into the MSW waste stream and increases the metal concentration in the leachate.”

Indeed, CCA-treated wood can become a major problem if the waste is accepted now, and then it later is determined hazardous.

“If construction and demolition (C&D) landfill operators end up having a contaminated site at levels beyond what the states allow, they’ll have to clean it up,” says the EPA’s Helms.

Banning the wood from certain facilities creates its own disposal problems — the materials must go somewhere.

Already, composters and C&D recyclers don’t want to handle CCA-treated wood. “C&D recyclers typically are vigilant about staying away from the material and don’t want it in their plants,” says Bill Turley, executive director of the Construction Materials Recycling Association, Lisle, Ill.

“It’s certainly not a material we want in a composting situation where the material is going for lawn and garden use,” says Sharon Barnes, president of Barnes Nursery and former president of the U.S. Composting Council, Harrisburg, Pa.

So what to do with the wood?

Florida currently is continuing its disposal practices as is, but is seeking feedback from the industry, as well as continuing to research the issue. “We need the industry’s help and advice,” Hinkley says. “I’m obviously interested in whether other people think this is a problem. But I’m also soliciting information on what people think is the best way to approach this issue.”

Among Hinkley’s questions are how to separate the wood, how to dispose of it, where to dispose of it — in a lined or unlined landfill, and how to process the material if it is sent to a lined landfill or waste-to-energy (WTE) facility.

“We’re discarding about 5 million cubic feet per year, but this is expected to grow to 35 million cubic feet,” Hinkley adds. “That’s a lot coming down the pipe, so we need to get organized. We’re not in a crisis; it’s another waste management problem. But it’s our job to do what we do — handle waste management problems.”