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Hide details for Drip PadsDrip Pads
09/24/2003OPTIONS FOR CCA WOOD TREATMENT PLANTS CONVERTING TO PRESERVATIVES THAT DO NOT GENERATE HAZARDOUS WASTEMemo
 Description: The prohibition against chromated copper arsenate (CCA) treatment of wood for residential use will require many wood treatment plants to convert to alternative preservatives and perform generator closure of hazardous waste drip pads (SEE ALSO: RPC# 12/1/1998-02, 11/1/1997-01). Three options for complying with the closure requirements are complete closure, continued operation, or phased closure. Complete closure requires owners and operators to clean close drip pads to cleanup levels determined by the implementing agency (SEE ALSO: RPC# 3/16/1998-01) or to close pads as landfills if clean closure cannot be performed. Continued operation requires no cleaning or replacement of drip pads, but owners and operators must continue to comply with the drip pad requirements and manage all wastewaters, process residuals, preservative drippage, spent formulations, and related materials as hazardous wastes via the mixture rule. Phased closure requires owners and operators to sufficiently clean drip pads, system components, and equipment and requires continued compliance with certain drip pad requirements until complete closure is performed. Methods for cleaning drip pads depend on whether pads are covered or sealed, and the methods include gritblasting, hydroblasting/water blasting, solvent washing, and steam cleaning.
 
01/01/2003FREQUENTLY ASKED QUESTIONS ON GENERATOR TREATMENTQuestion & Answer
 Description: Small quantity generators (SQGs) and large quantity generators (LQGs) may treat hazardous waste on site without a permit provided they comply with 262.34 and conduct no thermal treatment. Conditionally exempt small quantity generators (CESQGs) may treat hazardous waste on site without a permit provided they meet one of the conditions in 261.5(g)(3)(iii) through (vii). No generator may conduct thermal treatment without a permit. SQGs cannot treat in containment buildings or on drip pads and continue to operate under the reduced 262.34(d) standards. Only SQGs that operate under LQG standards may use these units. State implementing agencies may have more stringent rules regarding generator treatment.
 
07/17/2002SCOPE AND APPLICABILITY OF RCRA REGULATIONS AT WOOD PRESERVING FACILITIESMemo
 Description: Whether stormwater runoff from pentachlorophenol treated wood is a hazardous waste (e.g., F032) depends on site-specific factors. Stormwater that contacts preservative solutions or listed waste is hazardous via the contained-in policy. Precipitation runoff in storage yards is not F032 and drippage does not constitute illegal disposal, provided the facility complies with Subpart W. Steam from wood preserving equipment that condenses and settles away from the equipment is not F032, F034, or F035. A facility operating a tank-based zero discharge system is considered subject to the CWA for the purposes of the wastewater treatment unit (WWTU) definition. Drip pads are not required in storage yards, provided that any infrequent and incidental drippage is immediately responded to as outlined in the facility contingency plan. Infrequent and incidental drippage determinations are site-specific. Whether the presence of hazardous contaminants in soil indicates illegal disposal is determined on a case-by-case basis. State regulations can be more stringent.
 
07/01/1998DRIP PAD LEAKAGE COLLECTION SYSTEM REQUIREMENTSQuestion & Answer
 Description: Owners and operators of new or existing drip pads must apply surface coating or provide liner and leak detection system. If the owner and operator chooses to install a liner and leak detection system, a leakage collection system may be required. Only existing drip pads, new drip pads constructed before 12/24/92, new drip pads for which owner and operator had a design and had entered into a binding financial or other agreement for construction prior to 12/24/92, do not require a leakage collection system.
 
11/01/1997DRIP PAD CLOSURE NOTIFICATION AND CERTIFICATION REQUIREMENTSQuestion & Answer
 Description: Owners and operators of drip pads are generators in most cases, and therefore, are not required to comply with notification and certification of closure requirements in Sections 264/265.112(d) and 264/265.115. Generators must comply with closure performance standards in Section 265.111, and disposal and decontamination of equipment, soils, and structures in Section 265.114. In addition, owners and operators of drip pads must comply with the drip pad closure requirements of Subpart W. If decontamination or removal cannot be fully accomplished during closure, the drip pad must close as a landfill.
 
08/30/1996PROPOSED EXCLUSION FOR WOOD PRESERVING PROCESS WASTEWATERSMemo
 Description: EPA expects to propose an exclusion from solid waste regulations for process wastewaters recycled at wood preserving facilities. Discusses the intended proposed language. Process wastewaters must be used for their original intended purpose, must be managed in units visually or otherwise determined to prevent releases, and if managed in drip pads, the units must be in compliance with the drip pad standards (SEE ALSO: 63 FR 28556; 5/26/98).
 
05/01/1996RESOLUTION OF RCRA ISSUES RELATING TO THE WOOD PRESERVING INDUSTRYMemo
 Description: Drip pad sumps can satisfy the wastewater treatment unit (WWTU) exemption if they are part of the facility’s wastewater treatment system, even though the wood preserving regulations require sumps to meet Subpart J tank standards. If a wood preserving facility qualifies as a conditionally exempt small quantity generator (CESQG), it is conditionally exempt from Parts 264/265, Subparts W and J requirements.
 
02/18/1994REGULATORY STATUS OF RAINWATER IN WOOD PRESERVING PROCESS AREASMemo
 Description: Rainwater that contacts drip pad at a wood preserving facility becomes a hazardous waste and remains a hazardous waste until recycled (SEE ALSO: Section 261.3(c)(2)). Quantity of contaminated rainwater generated should be included in the monthly generator reporting requirements.
 
11/01/1993CONTAINMENT BUILDINGS AS INDEPENDENT HAZARDOUS WASTE MANAGEMENT UNITSQuestion & Answer
 Description: A containment building is intended to be an independent hazardous waste management units. Existing tanks, containers, and drip pads do not need to be within a containment buildings. Containment buildings can serve as secondary containment for tanks.
 
05/31/1991DRIPPAGE IN WOOD PRESERVING STORAGE YARDSMemo
 Description: Incidental drippage after the removal of treated wood from drip pad is not illegal hazardous waste disposal, provided the owner and/or operator responds immediately. An immediate response determination is site-specific. A facility must have a contingency plan and must keep records of the response.
 
12/15/1990New Rule for Wood Preserving WastesPublication
 Description: Covers three categories of wastes generated by the wood preserving industry and added to the list of hazardous wastes under RCRA. Finalizes the December 1988 proposed rule. Includes management standards for existing and new drip pads used to collect treated wood drippage.
 
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