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Hide details for Drip PadsDrip Pads
 Description: EPA provided answers to various questions submitted by the Treated Wood Council regarding hazardous waste generators that are drip pad operators. EPA reaffirmed, as we did in the preamble of the November 28, 2016, final Hazardous Waste Generator Improvements Rule (81 FR 85732, 85768), that very small quantity generators (VSQGs) may accumulate hazardous waste on drip pads if they comply with the technical requirements of 40 CFR 265 Subpart W for drip pad operations. A generator accumulating hazardous waste on drip pads is not required to comply with Subparts G and H of 40 CFR 265 and 40 CFR 265.44(c) during closure.
 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.
 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.
 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.
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