ASLRRA Responds to FRA on Disposal of CTRTs

ASLRRA

WASHINGTON, D.C. – The American Short Line and Regional Railroad Association responded to the FRA in a docket over the disposal of creosote-treated railroad ties and its efforts to keep them out of landfills.

The ASLRRA responded to the FRA’s request for information “on the potential uses and options for disposal or repurposing used creosote-treated railroad ties (CTRTs), which are the wooden rail crossties that support the rail track.”

In its attempts to keep the railroad ties out of landfills, the ASLRRA has petitioned “the  Environmental Protection Agency (EPA) legitimacy criteria in 40 C.F.R. Part 241 and the definition of Paper Recycling Residuals to allow for CTRTs to be used for energy production.”

The docket states the ASLRRA’s regulatory changes which include: “changing the legitimacy criterion for comparison of contaminants in the NHSM to the traditional fuel the unit is designed to burn from ‘must’, a mandatory requirement, to ‘should consider’, removing associated design-to-burn and other limitations for CTRTs, and revising the definition of paper recycling residuals (‘PRR’) to remove the limit of non-fiber materials in PRR that can be burned as a non-waste fuel.”

The docket signed off with encouragement with the FRA to “further its efforts into repurposing CTRTs into biochar and suggest the agency partner with a CRISI grant recipient to use a portable pyrolysis machine as part of a tie replacement program or potentially a project out of the Office of Research, Development, and Technology.”