We are proud to be a service partner to ReEnergy Ashland Inc., a biomass to energy plant located in Ashland, Maine. We are so committed to the success of the program that we worked directly with them to address a specific regulatory challenge they were facing.
ReEnergy Ashland holds a permit in the State of Maine allowing it to recycle the wood ash generated by the plant. Casella Organics recycles the wood ash as a service provider to ReEnergy, and uses it as an agronomic substitute for lime, saving both ReEnergy and local farmers money. This program is a great example of turning a waste material into a valuable resource, and aligns well with Casella's commitment to beneficial use of residuals.
In 2009, ReEnergy (at that time Boralex) Ashland submitted a request to the Maine Department of Environmental Management (MeDEP) for a Minor Revision to their ash recycling permit. The MeDEP granted the revision, but added a license condition for manganese soil testing which was unrelated to the changes requested under the Minor Revision. Specifically, the license condition required base-line soil testing for manganese at all sites receiving wood ash. Perplexed by the necessity and appearance of this condition, Boralex Ashland contacted Casella Organics' project manager John Leslie to express concerns. John shared that all wood ash contains manganese, but that the Chapter 419, Rules for the Agronomic Utilization of Residuals, does not contain a standard. The MeDEP had chosen to use the standard in Chapter 418, Rules for the Beneficial Utilization of Residuals. The important distinction is that the Chapter 418 standard is based on a residential risk assessment standard and does not take into account the decreased exposure presented by commercial agronomy and other critical considerations.
Based on these facts, Boralex decided to appeal the license and on November 19, 2009 their case was presented to the Maine Board of Environmental Protection. Casella Organics’ regulatory professionals, John Leslie, Mary Waring, and Jeff McBurnie testified at the hearing. They explained that the MeDEP had acted improperly in applying the Chapter 418 standard because the rules clearly state that only Chapter 419 metals standards are to be used for screening residuals for land application. In turn, Boralex asked that the soil testing requirement be removed and that the Department develop an appropriate manganese standard for agronomic utilization. The Board agreed, and ordered the soil sampling condition in the permit be removed. It further required that the MeDEP undertake a rule-making process to develop an appropriate risk-based standard for manganese and other metals that are not currently addressed by Chapter 419.
As a service to ReEnergy Ashland and our numerous other clients, Casella Organics will be following the rule-making process closely. This will include attending public hearings and submitting scientific testimony, to assist the Department in developing an agronomic risk-based standard for manganese. We encourage generators of wood ash, multi-fuel ash, and other residuals to stay abreast of the proceedings and participate by attending the hearings and submitting public comment. Casella Organics will communicate with our customers and other interested parties throughout the process to ensure residuals generators and agricultural interests are considered. If you are interested in participating or you would like additional information, please contact us.