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Document Record Detail



Full Document:
Title:OPTIONS FOR CCA WOOD TREATMENT PLANTS CONVERTING TO PRESERVATIVES THAT DO NOT GENERATE HAZARDOUS WASTE
RCRA Online Number:14681
Date:09/24/2003
To:RCRA Directors, Regions 1 -10
From:Springer
Organization of Recipient:NA
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.
Regulatory Citation(s) : 261.3(a(2)(iv), 261.31, 262.34(a)(1)(iii), 265.110(d), 265.111, 265.114, 265.310, 265.440(c)(1), 265.445 EXIT disclaimer
Statutory Citation(s):NA Read US Code 42, Chapter 82 EXIT disclaimer
Topic(s):Closure (Hazardous Waste); Drip Pads; Generators; Hazardous Waste
Approximate Number of Hardcopy Pages:7
EPA Publication Number:NA
RPPC Number (if applicable): NA
Official OSW Policy:No

 

 
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