CMRA Seeks Information On Wood Fuel To Fight NHSM Rule

The U.S. Environmental Protection Agency, as part of its suite of rules on the use of industrial materials as fuels in the nation’s boilers (also known as Boiler MACT), released a revised Non Hazardous Secondary Materials rule that includes even more opinion on C&D wood used as biomass. The CMRA needs information on C&D biomass in order to answer the agency’s questions raised in the rule.

The rule is available as a PDF from the CMRA. To receive it contact the association at This e-mail address is being protected from spambots. You need JavaScript enabled to view it . Comments are due by February 23, and the CMRA will be urging its members to send in their thoughts.

For C&D biomass, it is obvious the EPA wants to see the material used as a fuel. In fact, much of the language the CMRA Issued & Education Fund provided to the White House Office of Management & Budget (see next article) is in the new version: “construction and demolition wood that has been processed (e.g., sorted) to remove contaminants (such as lead-painted wood, treated wood containing contaminants such as arsenic and chromium, metals and other non-wood materials), and is size-reduced prior to burning likely meets the processing and legitimacy criteria for contaminants, and thus can be combusted as a non-waste fuel. Such construction and demolition wood may contain de minimis amounts of contaminants and other materials provided it meets the legitimacy criteria for contaminant levels.”

All is what the CMRA I&E told OMB, except for the last sentence, which may mean that C&D biomass will still be subject to the regulatory onerous petition process. The CMRA I&E is working to get a clarification from EPA on what it means for C&D recyclers.

The CMRA needs your data. The CMRA is requesting help from its members. According to CMRA Executive Director, “we are requesting from all our members any laboratory analysis results of your C&D wood derived fuel. We need analysis of the fuel prior to being sent to your fuel buyers. Many of our fuel suppliers must have fuel samples sent to laboratories for TCLP analyses.  We need that data. Typical fuel and ash analyses, such as proximate and ultimate analysis, have information on: moisture, ash, volatile matter, fixed carbon, calorific value, sulfur, carbon, hydrogen, nitrogen, oxygen. Other analyses include metals, volatile organics, semi-volatile organics, or organic halogens.  Many of our members have needed to submit such data either for permitting or for other regulatory requirements and have may such data that is already on the public record.  We just need your help to gather the data.” Contact the CMRA at This e-mail address is being protected from spambots. You need JavaScript enabled to view it , or 630/585-7530, if this data can be shared.

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