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Hide details for Wood Preserving WastesWood Preserving Wastes
04/12/2004RECOMMENDATION ON THE DISPOSAL OF WASTE LUMBER PRESERVED WITH CHROMATED COPPER ARSENATE (CCA)Memo
 Description: Discarded arsenical-treated wood is generally not subject to regulation as hazardous waste. Some Chromated Copper Arsenate (CCA) treated wood is exempt from regulation as household hazardous waste. States may have guidelines for disposal of CCA-treated wood in municipal solid waste landfills. EPA recommends discarded CCA-treated wood be disposed in a landfill designed to satisfy the design and performance criteria in 258.40 for protection of groundwater.
 
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.
 
03/29/1999CLARIFICATION OF WOOD SURFACE PROTECTION AND WOOD PRESERVING DEFINITIONSMemo
 Description: Distinction between wood surface protection and wood preserving is based upon intent of process. Wood preserving is intended to protect physical integrity of wood. Surface protection is intended to prevent surface discoloration (SEE ALSO: 58 FR 25706; 4/27/93). Media actively managed which contain F032 waste would carry F032 listing.
 
03/19/1999APPLICATION OF AREA OF CONTAMINATION POLICY TO REMEDIATION OF WOOD TREATING SITESMemo
 Description: Area of contamination (AOC) policy provides that certain discrete areas of generally dispersed contamination can be considered as RCRA units (usually a landfill) and that consolidation and in-situ treatment conducted within AOC do not trigger land disposal restrictions (SEE ALSO: 63 FR 28620; 5/26/98). EPA believes that wood treating sites can be excellent candidates for use of AOCs.
 
05/19/1998PROVISIONAL ELIMINATION OF F032 WASTE CODEMemo
 Description: A provisional elimination of the F032 waste code for decontaminated equipment does not apply to contaminated soils. The original provision (55 FR 50450; 12/6/90) required new process wastes not to show any level of dioxin. The amendment (57 FR 61492; 12/24/92) specifies that facilities that switch to an alternative chemical (other than chlorophenol) are not required to identify their wastes as F032 as long as they continue to manage the waste as F034 or F035. Storage yard soils contaminated with infrequent or incidental drippage (kickback) would not carry a listing if wood preserving plants develop and implement a contingency plan for emergency response to drippage.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues, Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 10: Comments Related to Regulatory Impact Analysis for TC-Metal Hazardous Waste Issues Raised in Original Proposed Rule, August 22, 1995, and in Second Supplemental Proposed Rule, May 12, 1997Publication
 Description: This document reviews public comments relevant to the toxicity characteristic metals requirements and provides EPA's rationale for reaching its conclusions.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues, Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 11: Comments Related to Newly Identified Mineral Processing Waste Treatment Standards, Grab Versus Composite Sampling, Radioactive Mixed TC-Metal Wastes, and Sulfide Waste IssuesPublication
 Description: This document responds to public comments relevant to appropriate sampling methods, treatment standards for newly identified mineral processing wastes, radioactive mixed waste with toxicity characteristic metal wastes, and sulfide waste issues.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 1: Comments Related to Phase III Proposed Rule, March 2, 1995Publication
 Description: This document responds to public comments relevant to foundry sand issues in LDR Phase III proposed rule (60 FR 11702; March 2, 1995), and provides EPA's responses to the comments.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 2: Comments Related to Phase IV Proposed Rule Rule, August 22, 1995Publication
 Description: This document presents public comments on original Phase IV proposed rule (60 FR 43654; August 22, 1995), including comments on UHCs, the TC, HWIR, state authorization, wood preserving, wastewater exclusion, and treatment standards for metal bearing wastes, and provides EPA's responses to the comments.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 3: Comments Related to First Supplemental Proposed Rule, January 25, 1996Publication
 Description: This document presents public comments on the first supplemental proposed rule (61 FR 2337; January 25, 1996), including comments on HWIR, state authorization, manufactured gas plant issues, and treatment standards for metal bearing wastes, and provides EPA's responses to the comments.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 4: Comments Related to First Notice of Data Availability, May 10, 1996Publication
 Description: This document presents public comments on the First Notice of Data Availability (61 FR 21418; May 10, 1996), including comments on lead and silver treatment standards and wood preserving wastewater exclusion, and provides EPA's responses to the comments.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 5: Comments Related to Second Notice of Data Availability, March 5, 1997Publication
 Description: This document presents public comments on the Second Notice of Data Availability (62 FR 10004; March 5, 1997) concerning the addition of iron filings to foundry sand, and provides EPA's responses to the comments.
 
04/30/1998Response to Comments Document: Land Disposal Restrictions - Phase IV: Final Rule Promulgating Treatment Standards for Metal Wastes and Mineral Processing Wastes; Mineral Processing Secondary Materials and Bevill Exclusion Issues; Treatment Standards for Hazardous Soils, and Exclusion of Recycled Wood Preserving Wastes; Volume 6: Comments Related to Second Supplemental Proposed Rule, May 12, 1997Publication
 Description: This document presents public comments on the Second Supplemental Proposed Rule (62 FR 26041; May 12, 1997), including comments on UHCs, HWIR, state authorization, MGP issues, wood preserving wastewater exclusion, underground injection, and treatment standards for metal-bearing wastes and contaminated soil, and provides EPA's responses to the comments.
 
04/27/1998REPORTING WASTEWATERS MANAGED IN RCRA-EXEMPT UNITS ON THE 1997 HAZARDOUS WASTE REPORTMemo
 Description: EPA considered dropping the reporting requirement for wastewaters on the 1997 Hazardous Waste (Biennial) Report. Based on concerns raised by data users, EPA decided not to change the requirement that hazardous wastes going to RCRA-exempt units be reported (NOTE: See 2001 Biennial Report Forms for current requirements). EPA did change the system type code in an effort to simplify the reporting. EPA does not plan to overrule state or regional guidance which may have contradicted this policy. Reporting for wood preserving wastewaters may be affected by the conditional exclusion added by the land disposal restrictions (LDR) Phase IV rulemaking .
 
06/02/1997TWO-YEAR CAPACITY VARIANCE FOR SOILS CONTAMINATED WITH WOOD PRESERVING WASTESMemo
 Description: EPA has established a two-year national capacity variance (until May 12, 1999) from the land disposal restrictions (LDR) treatment standards for soils contaminated with F032, F034, and F035. During the variance soil contaminated with these wastes may be disposed in a landfill or surface impoundment only if such unit is in compliance with 268.5(h)(2).
 
04/01/1997Environmental Fact Sheet: Treatment Standards Finalized For Wood Preserving Wastes; Less Paperwork Required Under Land Disposal Restrictions (LDR) ProgramPublication
 Description: Describes the promulgation of the rule setting LDR treatment standards for listed hazardous waste from wood preserving operations at the universal treatment standard levels. Removes LDR treatment standards for the group of hazardous wastes known as the California List, thus simplifying the LDR program. Amends the definition of solid waste to exclude processed scrap metal and containerized shredded circuit boards from full hazardous waste management when they are properly recycled. Eliminated approximately 1.6 million hours of LDR recordkeeping.
 
01/23/1997PROPOSED EXCLUSION FOR RECYCLED WOOD PRESERVING WASTEWATERSMemo
 Description: EPA intends to propose an exclusion from the definition of solid waste for recycled wood preserving wastewaters and spent wood preserving solutions. The exclusion will be proposed as part of the land disposal restrictions (LDR) Phase IV second supplemental proposal. Language of the exclusion will refer to wood preserving sites as “plants” rather than “facilities” to avoid confusion with RCRA permitted facilities (SEE ALSO: 63 FR 28556; 5/26/98).
 
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).
 
06/04/1996CLARIFICATION OF REQUIREMENTS INVOLVING THE COUNTING OF WOOD PRESERVING WATERS FOR BIENNIAL REPORTINGMemo
 Description: Hazardous wastewater from wood preserving plants (F032, F034, and F035) is not subject to quantity determination for the Biennial Report or for determining generator status when recycled in an on-site process without prior storage or accumulation (SEE ALSO: Section 261.4(a)(9)). If the waste is stored or accumulated prior to reuse, the generator must count the waste unless it has already been counted once.
 
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.
 
04/08/1994REGULATORY STATUS OF WOOD STICKERS USED FOR WOOD PRESERVING OPERATIONSMemo
 Description: Although the F032, F034, and F035 listings do not generally apply to treated wood products that are discarded, wood "stickers" (pieces of wood used during wood preserving to separate bundles of lumber) that come into contact with wood preservative are listed hazardous waste when discarded.
 
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.
 
12/24/1992CLARIFICATION ON WHAT CONSTITUTES DIOXIN RELATED MATERIALSMemo
 Description: Contains a list of waste codes that contain dioxin (F020, F022, F023, F026, F027, F028, F032, D017, D041, D042). The F-listed dioxin waste codes do not apply if waste contains dioxin but does not meet the listing description. Waste exhibits the toxicity characteristic only if the level of constituent exceeds the regulatory level. F039, K043, and K099 have land disposal restrictions (LDR) for certain dioxins and furans. If waste meets the listing description, the waste code applies even if no Appendix VIII constituents are present. For purposes of F021, a pentachlorophenol derivative includes any substance which is related structurally and can be made from pentachlorophenol (PCP), including sodium pentachlorophenate, octachlorodibenzodioxin, octachlorodiphenyl ether, and potassium pentachlorophenate. Derivatives from tri- and tetrachlorophenol include tri- and tetra-chlorophenoxy derivatives of carboxylic acids. F020 -F023, F026-F028 hazardous waste must be incinerated in an unit meeting 99.9999 DRE or burned in thermal treatment unit meeting same DRE. Waste that contains Appendix VII constituents but cannot be traced to the original process that would generate the waste meeting listing description is exempt from regulation unless characteristic.
 
12/11/1992CLARIFICATION OF HAZARDOUS WASTE LISTINGS PERTAINING TO WOOD PRESERVING OPERATIONSMemo
 Description: Wood preserving is defined as any process intended to preserve wood from structural attack. The definition is based on intent of treatment, not on type of process. Dipping operations could be wood preserving. Sodium pentachlorophenate used as wood preservative is F032 when discarded.
 
10/15/1992Environmental Fact Sheet: Final Modifications to the Wood Preserving RegulationsPublication
 Description: This fact sheet announces a final rule that modifies several aspects of the regulations for wastes from the wood preserving industry under RCRA.
 
12/10/1991EXTENSION OF COMMENT PERIOD FOR LDR SOIL FEDERAL REGISTER NOTICEMemo
 Description: Discusses the extension of the comment period for land disposal restrictions (LDR): Potential Treatment Standards for Newly Identified and Listed Wastes and Contaminated Soil (56 FR 55160; 10/24/91) on issues related to mineral processing wastes, wood preserving wastes, and spent potliners (SEE ALSO: 57 FR 37194; 8/18/92, 60 FR 43654; 8/22/95, 61 FR 2338; 1/25/96, 62 FR 25997; 5/12/97).
 
12/01/1991RECLAIMED SPENT WOOD PRESERVATIVE EXCLUSION IN 40 CFR 261.4(A)(9)Question & Answer
 Description: Spent wood preserving solutions that are reclaimed are no longer solid wastes and so are not derived from listed wastes F032, F034, or F035 (SEE ALSO: 63 FR 28556; May 26, 1998). Wood treated with the reclaimed preservative is not a hazardous waste when placed on land.
 
06/01/1991ADMINISTRATIVE STAY FOR WOOD PRESERVING WASTESQuestion & Answer
 Description: Description of administrative stay of the effective date for wood preserving wastes F032, F034, and F035.
 
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.
 
11/25/1987TREATMENT SURFACE IMPOUNDMENTS, REGULATORY OPTIONS AVAILABLE TO WOOD PRESERVERSMemo
 Description: A wood preserving treatment surface impoundment is not a hazardous waste experiment unit. A wood preservative surface impoundment must obtain a permit, close, or convert to a land treatment unit.
 
07/02/1987SOLID WASTE MANAGEMENT UNIT FOR THE PURPOSE OF CORRECTIVE ACTION UNDER 3004(U), DEFINITION OFMemo
 Description: Addresses the definition of deliberate in the context of a solid waste management unit (SWMU) and 3004(u) corrective action authorities. Releases need not have been known by the owner/operator to be deliberate. They must only have been routine and systematic. Includes examples of SWMUs. A wood preservative kickback area is an example of a SWMU.
 
06/19/1987REGULATORY STATUS OF VARIOUS TYPES OF PENTACHLOROPHENOL WASTESMemo
 Description: F021 is for pentachlorophenol (PCP) manufacturing wastes, not for wood-preserving wastes like dip tank bottom sludge or discarded pentachlorophenol (PCP)-treated wood (SEE ALSO: F032). F027 is for unused PCP wood preservatives, not for used formulations which come in contact with wood that remains in process vessel or dip tank after treatment or contained-in treated wood (posts, poles, railroad ties); K001 for treatment sludges from wastewater from PCP or creosote wood preserving, not dip tank bottom sludge from PCP wood preserving facilities (SEE ALSO: 261.24 and 261.31)
 
04/09/1987F027 LISTING - USED AND UNUSED FORMULATIONS IN WOOD PRESERVINGMemo
 Description: In regards to the F027 listing, the word 'used' includes formulations that have contacted wood or which remain in a dip or process tank after preservation. The formulations do not have to be spent to be classified as used; even after one treatment, a formulation is considered to be used. Dipping a piece of wood in a container of unused preservative in order to claim it as used is sham use.
 
09/12/1986WOOD TREATMENT CYLINDER CREOSOTE SUMPSMemo
 Description: A sump collecting nonhazardous creosote from drips, leaks, or spills from wood treatment operations may be considered a solid waste management unit (SWMU) (SEE ALSO: 55 FR 50450; 12/6/90, F034 listing in 261.31, 264 Subpart W, 265 Subpart W, and 55 FR 30798; 7/27/90).
 
04/07/1986ENVIRONMENTAL RELEASES FROM WOOD PRESERVING PLANTSMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
04/07/1986WOOD PRESERVING AND SURFACE PROTECTION FACILITIES, CONTROLLING ENVIRONMENTAL RELEASES FROMMemo
 Description: A summary of EPA regulations applicable to releases from wood preserving facilities. The wood preserving process wastewater effluent is subject to the CWA (SEE ALSO: 261.4(a)(9)). The storage or mixing tanks, kraft bags can be empty containers under section 261.7. Discusses the applicability of the F020, F021, F026, F027 listings. Dioxin wastes are acutely hazardous and are subject to the 1 kg threshold. Wastewater treatment sludges from creosote and pentachlorophenol (PCP) are K001. An explanation of the closure of units used to treat these process wastewaters. The applicability of the EP (extraction procedure) toxicity characteristic (SUPERSEDED: see 261.24) to wood preserving wastes. A discussion of section 3004(u) and (v) corrective action at wood preserving facilities.
 
03/20/1986DETERMINATION OF THE PRESENCE OF WASTEWATER TREATMENT SLUDGES AND/OR THE PRESENCE OF WASTEWATERMemo
 Description: Wastewater management generates a wastewater treatment sludge. To prove wastewater management has created a sludge, one need only show that the the unit or soil after contact with wastewater is physically or chemically different from the virgin unit or soil. Even when fully treated, industrial wastewater remains a wastewater for listings. Management of electroplating or wood preserving wastewater at any point in the wastewater treatment train creates an F006 or K001 sludge, regardless of the actual sludge contaminants or concentrations. Discussion of the delisting option.
 
03/03/1986SPENT CARBON USED TO REMOVE DISSOLVED PENTACHLOROPHENOL (PCP) FROM GROUNDWATERMemo
 Description: Spent carbon used to treat groundwater contaminated by product pentachlorophenol (PCP) spill is acute hazardous waste F027. Under other circumstances, carbon is not regulated (SEE ALSO: 261.24 and 261.31: F032).
 
02/11/1986WOOD TREATED WITH CREOSOTE, DISPOSAL OFMemo
 Description: Creosote-treated wood is unlikely to be a HW. It is not listed (K001, K035) and it is unlikely to be characteristic. The FIFRA regulations prohibit burning of creosote-treated wood.
 
07/16/1985CREOSOTE TREATED CROSS TIES, DISPOSAL OF, FIFRA INTERFACEMemo
 Description: Creosote-treated railroad cross ties are not likely characteristic. FIFRA may place controls on their handling and disposal. U051 creosote and K001 and K035 do not apply to treated cross ties destined for disposal.
 
04/16/1985FEDERAL REGULATIONS ON DISPOSAL OF TOXIC AND HAZARDOUS SUBSTANCESMemo
 Description: The owner of a recreational sailboat discarding an empty can containing pentachlorophenol (PCP) wood preservative residues is typically considered a CESQG not subject to hazardous waste (HW) management regulations. Marinas can arrange for collection of such HW from CESQG boat owners.
 
03/04/1985DIOXIN IN WASTES FROM WOOD PRESERVING PROCESSES USING PENTACHLOROPHENOLMemo
 Description: F-listed dioxin wastes are rarely generated at wood preserving facilities, although if wood preserving facility makes chlorophenolic formulations or discards unused chlorophenolic formulations, they would generate F-listed dioxin wastes. EPA may amend K001 to address chlorinated dioxins and furans (see also: 261.31: F032-F035). F021 and F027 are listed for acute toxicity (H), while F028 is listed as a toxic waste (T).
 
01/18/1985K001-LISTED WASTES FROM WOOD PRESERVING PROCESSESMemo
 Description: EPA is aware of no single analytical method with which to determine the presence of creosote. U051 applies to raw creosote that is discarded. K001 applies to wastes from wood preserving processes that use creosote and/or pentachlorophenol (PCP).
 
09/01/1984WASTEWATER FROM WOOD PRESERVINGQuestion & Answer
 Description: The K001 listing does not cover wastewater from wood preserving processes that use creosote and/or pentachlorophenol (PCP) (SEE ALSO: F032, F034).
 
07/25/1984WASTEWATER TREATMENT EFFLUENT FROM PROCESSES THAT GENERATE K001 AND F006 WASTEWATER TREATMENT SLUDGEMemo
 Description: The F006 and K001 listings apply to sludge generated anywhere in the wastewater treatment process. Effluent from the wood preserving waste treatment train is not K001. The definition of a material leaving a sand filter is the same as the material entering the filter. Wastewater passing through a filter remains wastewater.
 
04/26/1984WASTEWATER TREATMENT SLUDGES FROM WOOD PRESERVING PROCESSES USING CREOSOTE AND/OR PENTACHLOROPHENOLMemo
 Description: Wood preserving oil/water separator sludges and thermal dehydrator sludges may be K001 if creosote and/or pentachlorophenol (PCP) was used. Storage/work tank sludges mixed with the above sludges are listed. Historic estimation rates of waste generation are provided.
 
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