Air Pollution Control
Federal Title V Permit to Operate
Statement of Basis for Permit No. V-UO-002002-2017.01

                         Cobra Oil and Gas Corporation
                            Wolf Flat Tank Battery
                      Uintah and Ouray Indian Reservation
                              Uintah County, Utah

 Facility Information

 Location

Cobra Oil and Gas Corporation's (Cobra) Wolf Flat Tank Battery (Wolf Flat) is located on Indian country lands within the Uintah and Ouray Indian Reservation, in the northeastern part of the state of Utah, in Uintah County. Wolf Flat is located at NE/SW Section 15, Township 9S, Range 22E, Latitude 39.567442N, Longitude -109.751009W. The facility mailing address is:

Cobra Oil and Gas Corporation
2201 Kell Boulevard
Witchita Falls, Texas  76308

 Contact

Facility Contact:
Bobby Hess, Operations Supervisor
Cobra Oil and Gas Corporation
2201 Kell Boulevard
Wichita Falls, Texas  76308
(940) 716-5100
Email<EMAIL_ADDRESS>
Responsible Official:
Edward Winters, Environmental Health and Safety Coordinator
Cobra Oil and Gas Corporation
2201 Kell Boulevard
Wichita Falls, Texas  76308
(940) 716-5100
Email<EMAIL_ADDRESS>
Tribal Contact:
Mike Natchees, Director, Air Quality Program
Ute Indian Tribe
P.O. Box 70
Fort Duchesne, Utah  84026
(435) 725-4950
Email<EMAIL_ADDRESS>

C.	Part 71 Permitting History

Wolf Flat's initial 40 CFR part 71 (Part 71) Title V operating permit was issued on November 28, 2018 (Permit # V-UO-002002-2017.00). The EPA received a request for a permit amendment as specified in 40 CFR 71.7 for Wolf Flat on April 1, 2019, requesting to operate as a small glycol dehydrator under   40 CFR part 63, subpart HH (Subpart HH) at a major source while also retaining the large glycol dehydration unit requirements. Since the requested change was during the public comment period, the permit was administratively amended on May 27, 2020, rather than undergoing a minor permit modification. The EPA has amended the Part 71 permit by adding requirements to the permit to allow the dehydration unit to operate at a major source as both small and large as defined by Subpart HH as it pertains to actual annual natural gas flowrate for limiting emissions in §63.765(b)(1)(iii). The operator has indicated the current operations and throughput vary at this dehydration unit and has asked for operational flexibility in the Part 71 permit. In addition, the EPA revised organizational division names and mail codes in the permit to reflect our recent realignment. The amendments constitute minor revisions in the permit and therefore can be classified as Administrative Permit Amendments under permit condition V.H and 40 CFR 71.7(d).

D.	Description of Operations

The Wolf Flat accepts natural gas fluids produced from two surrounding well sites via a gathering pipeline system. The fluid stream undergoes a separation process at the inlet to the tank battery in two onsite heater-treater separators that separate the stream into natural gas, condensate and produced water. The natural gas is then routed through a 10 million standard cubic foot per day (MMscfd) triethylene glycol (TEG) dehydrator and then routed to a sales line. The produced water is routed to two onsite produced water tanks, and the condensate is routed to two onsite natural gas condensate tanks. The produced water and condensate are then trucked off location for further processing or treatment

E.	Emission Points

Table 1 lists emissions units and emissions generating activities, including any air pollution control devices. The Title V Operating Permit Program at Part 71 allows the Permittee to separately list in the permit application units or activities that qualify as "insignificant" based on potential emissions below 2 tons per year (tpy) for all regulated pollutants that are not listed as hazardous air pollutants (HAPs) under section 112(b) and below 1,000 lbs/year or the de minimis level established under section 112(g), whichever is lower, for HAPs. However, the application may not omit information needed to determine the applicability of, or to impose, any applicable requirement. Units and activities that qualify as "insignificant" for the purposes of the Part 71 application are in no way exempt from applicable requirements or any requirements of the Part 71 permit.

Table 1  -  Emission Units and Emission Generating Activities

                                  Unit I.D.

                                  Description

                               Control Equipment
                                    DEHY-1

                                     HTR-1

Valerus, 36" x 10'0" TEG Dehydrator, 10 MMscfd

Serial No. FG210255                             Installed: 2010

FlameCo, SB 18-12
Heater for Glycol Reboiler on DEHY-1, 0.500 MMBtu/hr*

Serial No. 1010-84                                Installed: 2/1/2011

                                    COMB-1
                          (not federally enforceable)

                                     None

                                    COMB-1
Valerus, FG211206, 48" Combustor

                                                               Installed: 2010
                                     None
                                     HTR-2
NatCo, SB 24-14 (IEU*)
Separator Heater, 1.000 MMBtu/hr

Serial No. 1006-953                              Installed: 2/1/2011
                                     None
                                     HTR-3
NatCo, SB 24-14 (IEU)
Separator Heater, 1.000 MMBtu/hr

Serial No. 1006-270                              Installed: 2/1/2011
                                     None
                                 TK-1 and TK-2
Two 400 bbl* Condensate Storage Tanks
                                     None
                                 PW-1 and PW-2
Two 400 bbl* Produced Water Storage Tanks
                                     None
                                      L-1
Condensate Truck Loadout (IEU)
                                     None
                                     FUG-1
Fugitive Emissions (IEU)
                                     None
IEU = Insignificant Emissions Unit; bbl = barrel; MMscfd = million standard cubic feet per day; MMBtu/hr = million British thermal units per hour.

F.	Potential to Emit

Pursuant to 40 CFR 52.21, potential to emit (PTE) is defined as the maximum capacity of a stationary source to emit a pollutant under its physical and operational design. Any physical or operational limitation on the capacity of the source to emit a pollutant, including air pollution control equipment and restrictions on hours of operation or on the type or amount of material combusted, stored, or processed, shall be treated as part of its design if the limitation, or the effect it would have on emissions, is federally enforceable. Independently enforceable applicable requirements are considered enforceable to the extent that the source is in compliance with the standard. In addition, beneficial reductions in non-targeted pollutants resulting from compliance with an independently enforceable applicable requirement may be counted towards PTE provided the emission reduction of the non-targeted pollutant is enforceable as a practical matter and compliance is being met. See the 1995 guidance memo signed by John Seitz, Director of the Office of Air Quality Planning and Standards titled, "Options for Limiting Potential to Emit of a Stationary Source under Section 112 and Title V of the Clean Air Act".
Cobra reported the emissions unit-specific PTE in their Part 71 permit application.
The PTE in Table 2 are based on the applicable legally and practically enforceable requirements outlined in the draft permit.

Table 2  -  Potential-to-Emit with Legally and Practically Enforceable Controls

                                     NOX*
                                      CO*
                                     VOC*
                                      PM*
                                     SO2*
                                    Benzene
                                  Total HAPs*
                                     CO2e*
                                    DEHY-1
                                       -
-
                                    159.69
                                       -
                                       -
                                     53.21
                                    101.60
                                     4277
                                    COMB-1
0.71
0.59
                                     0.01
                                     0.03
                                     0.00
                                     0.00
                                     0.00
                                      198
                                     HTR-1
0.21
0.18
                                     0.01
                                     0.06
                                     0.00
                                     0.00
                                     0.00
                                      232
                                     HTR-2
                                     0.43
                                     0.36
                                     0.02
                                     0.09
                                     0.00
                                     0.00
                                     0.01
                                      465
                                     HTR-3
                                     0.43
                                     0.36
                                     0.02
                                     0.09
                                     0.00
                                     0.00
                                     0.01
                                      465
                                 TK-1 and TK-2
                                       -
                                       -
                                     63.48
                                       -
                                       -
                                     0.03
                                     1.22
                                      173
                                 PW-1 and PW-2
                                       -
                                       -
                                     5.08
                                       -
                                       -
                                     0.03
                                     0.10
                                      277
                                      L-1
                                       -
                                       -
                                     0.38
                                       -
                                       -
                                       -
                                       -
                                       -
                                     FUG-1
                                       -
                                       -
                                     4.05
                                       -
                                       -
                                     0.00
                                     0.01
                                      153
                                     TOTAL
                                     1.78
                                     1.50
                                    232.75
                                     0.30
                                     0.01
                                     53.30
                                    103.16
                                     6242
*NOX = nitrogen oxide; CO = carbon monoxide; VOC = volatile organic compound; PM = particulate matter; SO2 = sulfur dioxide; HAP = hazardous air pollutant; CO2e = equivalent CO2.

 Applicable Requirements Review

The following sections discuss the information provided by Cobra in their Part 71 application, certified to be true and accurate by the Responsible Official of this facility.

        40 CFR 52.21 - Prevention of Significant Deterioration

The Prevention of Significant Deterioration (PSD) Permit Program at 40 CFR part 52 (Part 52) is a preconstruction review requirement of the Clean Air Act (CAA) that applies to proposed projects in areas classified as attainment, attainment/unclassifiable, or unclassifiable for the National Ambient Air Quality Standards (NAAQS) that are sufficiently large (in terms of emissions) to be a "major" stationary source or "major" modification of an existing stationary source. Source size is defined in terms of PTE, which is its capability at maximum design capacity to emit a pollutant, except as constrained by existing legally and practically enforceable conditions applicable to the source. A new stationary source or a modification to an existing minor stationary source is major if the proposed project has the PTE for any pollutant regulated under the Part 52 requirements in amounts equal to or exceeding specified major source thresholds, which are 100 tpy for 28 listed industrial source categories and 250 tpy for all other sources. The PSD Permit Program also applies to modifications at existing major sources that cause a "significant net emissions increase" at that source. Significance levels for each pollutant are defined in the PSD regulations at 40 CFR 52.21.

According to information provided by Cobra in the initial Part 71 permit application, at the time of its construction, the Indian country lands within the Uintah and Ouray Indian Reservation were designated attainment, attainment/unclassifiable, or unclassifiable for all NAAQS and Wolf Flat was a minor source of emissions with respect to the PSD Permit Program, as the PTE did not exceed the major source thresholds of any criteria pollutants regulated under the PSD Permit Program. As such, the source was not subject to preconstruction permitting requirements of the PSD Permit Program.
 40 CFR 49.166  -  Federal Major New Source Review Program for Nonattainment Areas in Indian Country

The Federal Major New Source Review (NSR) Program for Nonattainment (NA) Areas in Indian Country (NNSR Permit Program) at 40 CFR part 49 is a preconstruction review requirement of the CAA that applies to proposed projects that are sufficiently large (in terms of emissions) to be a "major" stationary source or "major modification" of an existing stationary source in an area that the EPA has designated nonattainment for a NAAQS (See 40 CFR 49.167). Similar to the PSD Permit Program, source size is defined in terms of PTE, but a new stationary source or a modification to an existing stationary source is major if the proposed project has the PTE for any pollutant regulated under the      40 CFR part 49 requirements in amounts equal to or exceeding specified major source thresholds defined in 40 CFR part 51, Appendix S.

On April 30, 2018, the EPA designated portions of the Indian country lands within the Uintah and Ouray Indian Reservation as marginal nonattainment for the 2015 ozone NAAQS, effective on August 3, 2018. Wolf Flat is located within that marginal ozone nonattainment area. Appendix S lists the marginal ozone nonattainment major source threshold for VOC or NOX emissions as 100 tpy. As such, although at the time of construction, Wolf Flat was considered a minor source with respect to the PSD Permit Program, it is now considered an existing major source for VOC with respect to the NNSR Permit Program. The preconstruction review requirements of the NNSR Permit Program would apply to any future proposed
modification at Wolf Flat that exceeds 100 tpy of VOC or NOX emissions. Wolf Flat remains a minor source with respect to PSD for all other criteria pollutants.

C. 	Source Determination

At 40 CFR 71.2, a major source is generally defined as any stationary source (or any group of stationary sources that are located on one or more contiguous or adjacent properties, and are under common control of the same person (or persons under common control)), belonging to a single major industrial grouping and that are a major source as described in the definition. On June 3, 2016, the EPA published a final rule clarifying when oil and natural gas sector equipment and activities must be deemed a single source when determining whether major source permitting programs (PSD and New Source Review preconstruction permit programs, and the Part 71 Permit Program) apply (81 FR 35622). By clarifying the term "adjacent," the rule specifies that equipment and activities in the oil and natural gas sector that are under common control will be considered part of the same source if they are located on the same surface site or on individual surface sites that share equipment and are within (1/4) mile of each other.

According to information provided by Cobra in their initial Part 71 application, there are no surface sites with shared emissions equipment within (1/4) mile from the Wolf Flat facility.

 40 CFR Part 60, Subpart A: General Provisions

This subpart applies to the owner or operator of any stationary source which contains an affected facility, the construction or modification of which is commenced after the date of applicability of any standard in 40 CFR part 60 (Part 60). The general provisions under subpart A apply to sources that are subject to the specific subparts of Part 60.

As explained below, no emissions units operating at Wolf Flat are subject to Part 60; therefore, the General Provisions of Part 60 do not apply.
 40 CFR Part 60, Subpart Kb: Standards of Performance for Volatile Organic Liquid Storage Vessels (Including Petroleum Liquid Storage Vessels) for which Construction, Reconstruction, or Modification Commenced After July 23, 1984

This subpart establishes requirements for controlling VOC emissions from storage vessels with a capacity greater than or equal to 75 cubic meters that are used to store volatile organic liquids for which construction, reconstruction, or modification commenced after July 23, 1984.

According to the information provided by Cobra in their Part 71 application, the condensate tanks, TK-1 and TK-2, at this facility are exempt from these requirements, pursuant to §60.110b(d)(4), because they store condensate prior to custody transfer and have a capacity of less than 10,000 bbls.

 40 CFR Part 60, Subpart KKK: Standards of Performance for Equipment Leaks of VOC from Onshore Natural Gas Processing Plants

This subpart establishes requirements for controlling fugitive VOC emissions from onshore natural gas processing plants. It applies to natural gas processing plants that commenced construction, reconstruction, or modification after January 20, 1984.

According to the information provided by Cobra in their Part 71 application, Wolf Flat is not a natural gas processing plant, therefore the facility is not subject to this subpart.

 40 CFR Part 60, Subpart LLL: Standards of Performance for SO2 Emissions From Onshore Natural Gas Processing for Which Construction, Reconstruction, or Modification Commenced After January 20, 1984, and on or Before August 23, 2011

This subpart applies to sweetening units and sulfur recovery units at onshore natural gas processing facilities. As defined in this subpart, sweetening units are process devices that separate hydrogen sulfide (H2S) and CO2 from a sour natural gas stream. Sulfur recovery units are defined as process devices that recover sulfur from the acid gas (consisting of H2S and CO2) removed by a sweetening unit.

According to the information provided by Cobra in their Part 71 application, neither sweetening nor sulfur recovery are performed at the facility. Therefore, this facility is not subject to this subpart.

 40 CFR Part 60, Subpart JJJJ: Standards of Performance for Stationary Spark Ignition Internal Combustion Engines

This subpart establishes emission standards and compliance requirements for the control of emissions from stationary spark ignition internal combustion engines (ICE) that commenced construction, modification, or reconstruction after June 12, 2006, and are manufactured on or after specified manufacture trigger dates. The manufacture trigger dates are based on the engine type, fuel used, and maximum engine horsepower.

According to the information provided by Cobra in their Part 71 application, there are no spark ignition ICE operating at the facility. Therefore, this facility is not subject to this subpart.

 40 CFR Part 60, Subpart OOOO: Standards of Performance for Crude Oil and Natural Gas production, Transmission, and Distribution

This subpart establishes emission standards for the control of VOC and SO2 emissions from affected facilities that commence construction, modification, or reconstruction after August 23, 2011. Affected facilities include, but are not limited to well completions, centrifugal compressors, reciprocating compressor, pneumatic controllers, storage vessels, and sweetening units.

According to the information provided by Cobra in their Part 71 application, the current equipment at Wolf Flat predates the applicability date for this subpart. Therefore, Wolf Flat is not subject to this subpart.

 40 CFR Part 60, Subpart OOOOa: Standards of Performance for Crude Oil and Natural Gas Facilities for which Construction, Modification or Reconstruction Commenced After September 18, 2015

This subpart establishes emission standards for the control of VOC and SO2 emissions from affected facilities that commence construction, modification, or reconstruction on or after September 18, 2015. Affected facilities include, but are not limited to well completions, centrifugal compressors, reciprocating compressors, pneumatic controllers, storage vessels and sweetening units.

According to the information provided by Cobra in their Part 71 application, the current equipment at Wolf Flat predates the applicability date for this subpart. Therefore, Wolf Flat is not subject to this subpart.

 40 CFR Part 63, Subpart A: National Emission Standards for Hazardous Air Pollutants for Source Categories, General Provisions

The requirements of 40 CFR part 63, subpart A apply to sources that are subject to the specific subparts of 40 CFR part 63.

As explained below, the dehydrator operating at Cobra is subject to 40 CFR part 63, subpart HH; therefore, the General Provisions of 40 CFR part 63 apply.

 40 CFR Part 63, Subpart HH: National Emission Standards for Hazardous Air Pollutants from Oil and Natural Gas Production Facilities

This subpart establishes emission standards for the control of HAP emissions from affected units located at natural gas production facilities that process, upgrade, or store natural gas prior to the point of custody transfer, or that process, upgrade, or store natural gas prior to the point at which natural gas enters the natural gas transmission and storage source category or is delivered to a final end user. The affected units are glycol dehydration units, storage vessels with the potential for flash emissions and natural gas throughput greater than 79,500 liters per day (660 bbls/day), and the group of ancillary equipment and compressors intended to operate in volatile HAP service which is located at natural gas processing plants.

According to the information provided by Cobra in their Part 71 application, Wolf Flat is a major source of HAP, as defined in the subpart, and operates a glycol dehydration unit, as defined in the subpart. The operator has indicated the current operations and throughput vary at this unit and has asked for operational flexibility in the Part 71 permit. Therefore, this facility is subject to the major source requirements for large and small glycol dehydration units in this subpart.

 40 CFR Part 63, Subpart ZZZZ (MACT ZZZZ): National Emission Standards for Hazardous Air Pollutants for Stationary Reciprocating Internal Combustion Engines

This subpart establishes emission standards and operating limitations for the control of HAP emissions from reciprocating and compression ignition engines (RICE).

According to the information provided by Cobra in their Part 71 application, there are no RICE operating at the facility. Therefore, this facility is not subject to this subpart.

 40 CFR Part 64: Compliance Assurance Monitoring

Pursuant to requirements concerning enhanced monitoring and compliance certification under the CAA, the EPA promulgated regulations to implement compliance assurance monitoring (CAM) for major stationary sources of air pollution, for purposes of Title V permitting that are required to obtain operating permits under Part 71. The rule requires owners or operators of such sources to conduct monitoring that provide a reasonable assurance of compliance with applicable requirements under the CAA. The effective date of this rule is November 21, 1997.
 CAM Applicability

According to 40 CFR 64.2(a), CAM applies to each pollutant specific emission unit (PSEU) located at a major source which is required to obtain a Part 71 permit if the unit satisfies all of the following criteria:

             The unit is subject to an emission limitation or standard for the applicable regulated air pollutant other than an emissions limitation or standard that is exempt under
      40 CFR 64.2(b)(1);

             The unit uses a control device to achieve compliance with any such limit or standard; and

             The unit has pre-control device emissions of the applicable regulated pollutant that are equal to or greater than 100 percent of the amount, in tpy, required for a source to be classified as a major Title V source.

 CAM Plan Submittal Deadlines

       Large PSEUs. A CAM plan submittal for all PSEUs with the PTE (taking into account control devices) of any one regulated air pollutant in an amount equal to or greater than 100% of the amount, in tpy, required for a source to be classified as a major source, is due at the following times:

 On or after April 20, 1998, if by that date, a Part 71 application has either:

                   Not been filed; or
                   Not yet been determined to be complete.

 On or after April 20, 1998, if a Part 71 permit application for a significant modification is submitted with respect to those PSEUs for which the requested permit revision is applicable; or

 Upon application for a renewed Part 71 permit and a CAM plan has not yet been submitted with an initial or a significant modification application, as specified above.

       Other PSEUs. A CAM Plan must be submitted for all PSEUs that are not large PSEUs, but are subject to this rule, upon application for a Part 71 renewal permit.

Based on the information provided by Cobra in their Part 71 application, dehydration unit DEHY-1 is a PSEU with pre-controlled emissions that equal or exceed 100% of the Title V major source HAP thresholds. However, DEHY-1 is subject to the major source requirements of 40 CFR part 63, subpart HH and thus meets the exemption criteria of §64.2(b)(1). Since no other PSEUs at the facility have pre-controlled emissions that exceed or equal 100% of the Title V major source thresholds, Wolf Flat is not subject to CAM requirements.

 EPA Authority

Title V of the CAA requires that the EPA promulgate, administer, and enforce a federal operating permit program when a state does not submit an approvable program within the time frame set by Title V or does not adequately administer and enforce its EPA approved program. On July 1, 1996 (61 FR 34202), the EPA adopted regulations codified at 40 CFR part 71 setting forth the procedures and terms under which the Agency would administer a federal operating permit program. These regulations were updated on February 19, 1999 (64 FR 8247) to incorporate the EPA's approach for issuing federal operating permits to stationary sources in Indian country.

As described in 40 CFR 71.4(a), the EPA will implement a Part 71 program in areas where a state, local, or tribal agency has not developed an approved Part 70 program. Unlike states, tribes are not required to develop operating permits programs, though the EPA encourages tribes to do so. See, e.g., Indian Tribes: Air Quality Planning and Management (63 FR 7253, February 12, 1998) (also known as the "Tribal Authority Rule"). Therefore, within Indian country, the EPA will administer and enforce a
Part 71 federal operating permit program for stationary sources until a tribe receives approval to administer their own operating permit program.

 Use of All Credible Evidence

Determinations of deviations, continuous or intermittent compliance status, or violations of the permit are not limited to the testing or monitoring methods required by the underlying regulations or this permit; other credible evidence (including any evidence admissible under the Federal Rules of Evidence) must be considered by the Permittee and the EPA in such determinations.


Materials Characterization Paper

In Support of the

Advanced Notice of Proposed Rulemaking –

Identification of Nonhazardous Materials That Are Solid Waste

Construction and Demolition Materials – Building-Related C&D Materials

December 16, 2008

=====================================================================

1.	Definition of Building-Related Construction and Demolition Materials

Building-related construction debris and demolition (C&D) materials are
commonly grouped as a single type of material, despite the fact that
these two material streams come from different processes. Construction
materials originate from construction, repair or remodeling activities.
This materials stream typically consists of a variety of building
products (such as concrete, roofing, gypsum wallboard, wood products,
plastics, insulation, tile, and metal) as well as the packaging
materials that building materials arrive in (such as cardboard and
plastics). Construction materials are usually generated as a result of
cutting a material down to size for installation or purchasing materials
in excess of what is needed. Wood materials consists of wood scraps from
dimensional lumber, siding, laminates, flooring (potentially stained),
laminated beams, and moldings (potentially painted). Demolition
materials are generated from the dismantling of buildings or the removal
phase of remodeling. Typical constituents include concrete, wood, metal,
insulation, glass, carpet, and other building materials. Debris from
this process is often painted or chemically treated or is fastened to
other materials, making separation difficult (NESCAUM 2006).  For the
purposes of this summary, wooden railroad crossties and wooden utility
poles are also characterized as demolition materials.

This summary of C&D debris focuses largely on the scrap wood generated
from construction and demolition activities, as this is the main C&D
constituent beneficially used as a fuel.  EPA has also expressed
interest in obtaining information on the beneficial use of C&D plastics
and rubber, particularly fuel applications of these materials.  The
major plastic components of C&D materials (vinyl siding and PVC piping),
however, can contain 57 percent chlorine (Commission of the European
Communities, 2000).  Information on the quantities of vinyl siding and
PVC piping combusted in energy recovery facilities is not readily
available. In addition, rubber does not appear to be a major component
of C&D debris.  This C&D summary does not include a detailed examination
of either C&D plastic or rubber.

2.	Annual Quantities of C&D Materials Generated and Used

Sectors that generate C&D Materials:

Construction Materials are produced by NAICS 236: Construction of
Buildings (U.S. Department of Labor 2008). Demolition Materials are
produced by NAICS 238910: Site Preparation Contractors (U.S. Census
Bureau 2007).

(2) Quantities and prices of C&D Materials generated:

EPA estimates that 164 million tons of building-related C&D debris were
produced in 2003.  Approximately 47 percent of this was generated
through construction and renovation activities, and 52 percent was
generated through demolition activities (Franklin 2005).

Of the 164 million tons of building-related C&D materials generated in
2003, EPA estimates that between 33 and 49 million tons2 was C&D wood
(Franklin 2005).

As corroboration for EPA’s 2003 estimate of C&D wood debris
generation, a USDA source estimates that approximately 39.35 million
tons of C&D wood were generated in the U.S. in 2002.  Of this,
approximately 30 percent originated in construction activities and 70
percent in demolition activities (McKeever 2002).

Approximately 50 percent of C&D wood debris (20.28 million short tons)
is of acceptable size, quality, and condition to be considered available
for recovery. Factors limiting “availability” include contamination
and the commingling of wood with other nonwood building products
(McKeever 2002).

The quantity data presented above do not reflect the generation of scrap
railroad ties or utility poles.  A 1995 analysis indicates that 13
million wooden crossties are removed from railroad service each year
(WasteAge 1995). A 2000 analysis reports that 1 to 2 million wooden
utility poles are replaced each year (Choong et. al. 2000, pg 1).

The available data on the market price of ground wood includes a range
of values.  Data for 2000 show a range of $11.16 to $12.50 per ton,
while 2006 data suggest a range of $15 to $20 per ton (Krause 2000,
Goldstein 2006).  These prices vary by region, with prices in the
Northeast lower than in the West (Krause 2000).

Trends in generation of C&D Materials:

Information on the trend in C&D wood debris generation is not readily
available; however, between 1998 and 2003 the generation of all
building-related C&D rose by approximately 17 percent, from 136 million
tons in 1998 to 164 million tons in 2003 (EPA 1998, Franklin 2005).
Assuming that this growth rate applies to building-related C&D wood
debris, the generation of this debris grew from 28 to 42 million tons in
1998 to 33 to 49 million tons in 2003.

Trends in the generation of C&D debris tend to mirror the trend in
economic activity (McKeever 2002).  That is, a strong economy generally
results in more construction and demolition activity.  For example, the
annual percentage change in U.S. Gross Domestic Product (GDP) in 2006
decreased from 2.8 to 2.0 in 2007. During the same time period, total
U.S. new housing starts decreased from 1,800 to 1,355 (thousands) (U.S.
Census Bureau 2008, U.S. Department of Commerce 2008).

On a more local scale, the rate of C&D debris generation is heavily
influenced by a number of area-specific factors including the age of the
building stock (SWANA 2002b).

3.	Uses of C&D Materials

Fuel uses of C&D Materials:

C&D wood residues are commonly used for boiler fuel. The biomass can
either be combusted directly to heat a conventional type of boiler and
produce steam for power production, or it can be converted into gaseous
components (carbon monoxide, hydrogen, methane, and other inert gases)
through gasification. In contrast to incineration, which fully converts
the input debris into energy and ash, gasification deliberately limits
the conversion so the biomass is converted into the intermediate
products of gas and charcoal, which can be used for further energy
recovery (NRI).

Oven-dry wood produces approximately 9,000 Btu/lb when burned (SWANA
2002a).

Information on the quantity of C&D materials combusted for energy
recovery is unavailable.

Railroad ties are in demand for combustion due to their low moisture
content. In addition, because most crossties are creosote-treated, the
chips reportedly allow boilers to burn at a higher temperature than they
would with untreated wood chips. Furthermore, treated wood chips from
railroad ties reportedly leave less combustion residue behind than
untreated chips (WasteAge 1995).

Asphalt shingles can be used as fuel in cement kilns, and the mineral
components remaining after combustion can serve as raw material for the
cement (EPA 2008, p. 23).  However, while the use of asphalt shingles as
fuel is an established market in Europe, this use is limited in the
United States because of air pollution concerns and concerns about the
previous use of asbestos in older shingles (Shingle Recycling.org 2007).

Non-combustion uses of C&D Materials:

EPA estimates that 48 percent (65.6 million tons) of C&D materials were
recovered for beneficial use (including recycling and use as a fuel) in
2003 (Franklin 2005).  A corresponding estimate specific to wood C&D is
not readily available.

Approximately 3,500 C&D recycling facilities are operating in the U.S.
(Franklin 2005).

Additional markets for C&D wood include flooring, feedstock for
engineered woods, landscape mulch, soil conditioner, animal bedding,
compost additive, and sewage sludge bulking medium. Reusing wood as
lumber can potentially yield revenues 20 to 32 times higher than those
from selling wood for fuel or mulch. Similarly, recycling wood to the
manufacturing of engineered wood products can potentially generate
revenues four times greater than the revenues generated from selling the
same amount of wood for fuel or mulch. However, processing and handling
costs associated with the reuse of lumber and engineered wood product
feedstock options are also much greater than those associated with using
debris wood for fuel or mulch. Therefore, some of the revenues
associated with more “high-end” applications are offset by greater
processing and handling costs (SWANA 2002a).

More than half of scrap railroad ties are reused in landscaping,
fencing, construction, retaining walls and as fuel for utilities and
other plants (WasteAge 1995).

Quantities of C&D Materials landfilled:

Most C&D materials are non-hazardous and are frequently accepted at C&D
and municipal solid waste (MSW) landfills, depending on the state and
local laws governing disposal (EPA 2004).

As indicated in Exhibit 1, EPA estimates that 98.4 million tons of
building-related C&D debris were disposed in 2003 (Franklin 2005).  A
corresponding estimate specific to wood C&D is not readily available.

A 1994 EPA survey identified approximately 1,900 active C&D landfills in
the United States. (EPA 1998).

In 1998, EPA estimated that 45-60 million tons of C&D debris were
disposed of in permitted C&D landfills. This amount is equal to about
35-45 percent of the estimated 136 million tons of building related C&D
debris produced that year (EPA 1998).

Less than half of scrap railroad ties are landfilled (WasteAge 1995).

Quantities of C&D Materials stockpiled/stored:

Construction and demolition debris is not believed to be stockpiled in
significant quantities.  The data sources consulted for the development
of this document provided no indication that large quantities of C&D
materials are stockpiled.

 Exhibit 1:  C&D Material Quantities Generated and Managed in 2003

Material	Quantity Generated (million short tons)	Quantity Recycled or
used as Fuel (million short tons)	Percent Recycled or used as Fuel
Quantity Disposed

(million short tons)	Percent Disposed

	Building Related C&D Materials 	164 million	65.6	40%	98.4	60%

Sources:

Franklin 2005

4.	Management and Combustion processes using C&D Materials

Types of units using C&D Materials:

C&D wood is used by wood-fired industrial boilers and burners.

Sourcing of C&D Materials:

Wood from C&D activities becomes available as combustion fuel through a
variety of methods, but it is typically sent to a processing facility by
municipal haulers, private haulers, construction companies, or
individual households. After the wood is processed according to
combustor specifications, it is delivered to combustion facilities
(NESCAUM 2006).

Processing of C&D Materials:

Prior to use as fuel, scrap wood typically requires removal of non-wood
materials and processing into chips. Fuel specifications for combustors
usually include minimum and maximum chip sizes, amount of C&D fines,
maximum moisture content, and maximum contaminant levels (NESCAUM 2006).

A “hog” (also called a shredder or tub grinder) is used to process
construction and demolition wood materials. The hog uses rotating
hammers and stationary anvils to smash, crush and tear large wood into
smaller fragments. The maximum output particle dimension of hogged fuel
is typically less than 3 inches. Hogged fuel often has a high moisture
content and a significant ash content (from 2 to 20 percent) (Natural
Resources Canada 2000).

State status of C&D Materials use as fuel:

According to state responses to a 2006 survey by the Association of
State and Territorial Solid Waste Management Officials (ASTSWMO), two
states—Maine and Michigan—have approved the use of wood C&D
(excluding railroad ties) as fuel on at least one occasion.  In
addition, the following states have approved the use of railroad ties as
fuel on at least one occasion: Maryland, Pennsylvania, Iowa, Michigan,
and North Dakota.

5.	C&D Materials Composition and Impacts

Composition of C&D Materials:

As indicated in Exhibit 2, EPA estimates that concrete rubble makes up
40 to 50 percent of building-related C&D materials and that wood makes
up 20 to 30 percent of this material.

Exhibit 2:  Average Composition of Building-related C&D Materials

Building-Related C&D Material	Quantity Generated

(million tons)	Percent of C&D Debris Stream

Concrete Rubble	66 to 83	40-50%

Wood	33 to 49	20-30%

Gypsum Drywall	8 to 25	5-15%

Asphalt Roofing	2 to 16	1-10%

Metals	2 to 8	1-5%

Bricks	2 to 8	1-5%

Plastics	2 to 8	1-5%

Total	164	100%

Source:

Sandler 2003

A 2004 analysis of the composition of C&D wood chips used as fuel
conducted by the Maine Department of Environmental Protection found that
approximately 60 percent were untreated wood, 20 to 26 percent were C&D
fines, and less than 10 percent were painted wood, pressure-treated
wood, non-burnables, and plastic (NESCAUM 2006).

The rapid growth in the use of CCA-treated wood into the 1990s may
translate into future growth of this material as a component of C&D.
While information on national generation rates is not readily available,
some states do have data. For example, approximately 450 tons of
CCA-treated wood was disposed of in Florida in 1996, and this figure was
expected to quadruple by 2006. Recovered wood from C&D processing
facilities in Florida was found to contain, on average, six percent
CCA-treated wood in 1996. It should be noted that Florida’s
utilization of treated wood may be greater than utilization in many
states due to the extensive use of treated wood for marine applications
(Iida 2004).

Impacts of C&D Materials use:

Cost Impacts: The net cost impacts associated with beneficial use
applications for construction and demolition materials depend on the
avoided input or fuel costs for facilities that use these materials and
the cost of beneficial use itself.  Both of these vary by C&D material
and application, as fees charged at the processing site for delivered
loads of recovered wood are based in part on local competitive disposal
market rates. Construction wood and chemically treated wood often incur
higher tipping fees, whereas a number of operations will pay for sawmill
residue. The unit fuel savings for C&D used as a fuel (e.g., C&D wood
burned in a boiler) would equal the savings from the fuel replaced net
of the cost of the C&D wood and processing costs. Estimates of the
average price of processed wood used as fuel in 2000 ranged from $11.16
to $12.50 per ton net of transportation (Krause 2000). The going rates
of fossil fuels that could be readily replaced by C&D wood are as
follows:

Natural Gas (Industrial): $7.35 / million Btu (MMBtu) (EIA 2008a, Table
20)

No. 2 Distillate (Industrial): $16.80 / MMBtu (EIA 2008b, Table 36)

Residual Fuel Oil Average:  $9.19 / MMBtu (EIA 2008b, Table 38)

Coal – Average Delivered Price in 2006: $2.23 / MMBtu (EIA 2007, Table
ES1)

Emissions Impacts of Using C&D Wood Debris as a Fuel: To evaluate the
environmental impacts of burning C&D wood debris, we examined the
emissions associated with burning wood debris in a boiler and compared
these values to the emissions associated with the combustion of
conventional fossil fuels, as summarized in Exhibit 3.  The estimates in
the exhibit suggest that the combustion of wood results in higher PM
emissions than natural gas or distillate oil, but lower PM emissions
than coal or residual oil systems. The data in Exhibit 3 also suggest
that wood results in lower SO2 emissions than most conventional fuels.
The estimated NOx emissions associated with wood combustion are similar
to those associated with distillate and lower than the NOx emissions for
other conventional fuels.

The emissions profile of treated woods or wood with lead paint may
differ from the values presented in Exhibit 3.  For example, concerning
the combustion of railroad ties, the creosote in the ties increases the
combustion temperature, resulting in a more complete combustion of some
organics such as benzene, formaldehyde, and dioxins.  However, the
creosote itself contains 200 to 300 chemicals (Reid 2002).  In addition,
wood treated with chromium copper arsenate (CCA-treated wood) contains
arsenic, copper, and chromium that may be emitted when this wood is
combusted (Iida et al. 2004).  Similarly, lead may be emitted during the
combustion of lead-painted wood. Information on the magnitudes of these
emissions is not readily available.

Lifecycle Emissions Impacts: Use of C&D wood debris as a replacement for
traditional primary fuels may eliminate the environmental impacts
associated with extraction and processing of traditional fuels.  In
addition to the emissions impacts of combustion described above, Exhibit
3 lists the quantities of the total cradle-to-gate emissions
(“Combustion plus Upstream”) for these fuels based on typical
processes in the United States in the late 1990s, with wood scrap
combustion presented as an indicator of the emissions likely from the
combustion of C&D wood debris.  Note that there may be impacts
associated with the processing of C&D wood debris into useable fuel that
are not accounted for in the values presented in the exhibit.  In
addition, there may be alternative uses (e.g., composting) that are
environmentally preferable to combustion.

Exhibit 3:  Comparative Impacts of Wood Combustion versus Alternative
Primary Fuels

Pollutant	Wood1	Coal	Distillate Fuel Oil	Residual Fuel Oil	Natural Gas

	Combustion	Combustion	Combustion plus Upstream	Combustion	Combustion
plus Upstream	Combustion	Combustion plus Upstream	Combustion	Combustion
plus Upstream

	-------------------------------------- lb./MMBtu
-----------------------------------

Criteria Pollutants

PM2.5	-	-	-	-	-	-	-	-	-

PM10	0.019	0.054	0.054	0.011	0.011	0.093	0.093	0.009	0.009

PM, unspecified	-	-	0.246	-	0.012	-	0.012	-	0.004

NOx	0.167	0.482	0.504	0.173	0.234	0.367	0.428	0.301	0.417

VOCs	-	0.006	0.014	0.001	0.363	0.002	0.367	0.009	0.524

SOx	0.008	1.446	1.469	0.209	0.394	1.593	1.781	0.073	1.985

CO	1.511	0.068	0.085	0.036	0.082	0.033	0.079	0.058	0.282

Pb	1.33x10-4	8.93x10-6	9.19x10-6	4.60x10-6	5.61x10-6	5.80x10-5	5.90x10-5
-	2.72x10-7

Hg	-	2.05x10-6	2.14x10-6	1.58x10-6	1.77x10-6	8.67x10-6	8.85x10-6	-
7.18x10-8

Source:

Franklin Associates 1998.

Note:

“-” signifies data not available; may equal zero.

1. Estimates of the metals emissions associated with the combustion of
CCA-treated wood are not readily available.

The emission information presented in this table is derived from Life
Cycle Inventory (LCI) data, as compiled by Franklin Associates.   LCI
data identifies and quantifies resource inputs, energy requirements, and
releases to the air, water, and land for each step in the manufacture of
a product or process, from the extraction of the raw materials to
ultimate disposal. The LCI can be used to identify those system
components or life cycle steps that are the main contributors to
environmental burdens such as energy use, solid waste, and atmospheric
and waterborne emissions.  Uncertainty in an LCI is due to the
cumulative effects of input uncertainties and data variability.

There are several life cycle inventory databases available in the U.S.
and Europe.  For this paper, we applied the most readily available LCI
database that was most consistent with the materials and uses examined.
These LCI data rely on system boundaries as defined by Franklin
Associates, as described in the documentation for this database,
available at:   HYPERLINK
"http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf"
http://www.pre.nl/download/manuals/DatabaseManualFranklinUS98.pdf .

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 Building-related C&D debris does not include debris generated from the
construction and demolition of roads.  The available data suggest that
most road-related debris is not useable as a fuel; therefore, we exclude
these materials from this document.

 Data currently under revision.

 Although disaster debris is not considered C&D material, the
construction of new structures following a natural disaster increases
the generation of construction debris.

 The primary exception to this is wood treated with chromated copper
arsenate (CCA).

 The ASTSWMO survey also indicates that New York and North Carolina have
approved the use of recovered wood materials as a fuel on at least one
occasion but does not specify whether these approvals apply to the
beneficial use of finished wood products or vegetative debris generated
through land-clearing or natural disasters (ASTSWMO 2007, p.B-42).

 To express these values as dollars per Million Btu (MMBtu), the
following thermal conversion factors were used: 1,031 Btu per 1,000
cubic foot of natural gas, 138,690 Btu per gallon of Number 2
distillate, 149,690 Btu per gallon of residual fuel oil, and 22,473,000
Btu per short ton of coal (EIA 2005, Tables A1, A4, and A5).

 We note that the emission factors for wood presented in Exhibit 3
represent averages for wood-burning boilers.  In addition, the wood
reflected in the emissions data may include wood other than C&D wood
debris. Emission factors for conventional fuels are based on typical
boilers in use in North America in the late 1990s.

Construction and Demolition Materials – Building-related C&D Materials

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