PRELIMINARY DATA SUMMARY
             FOR THE
   WOOD PRESERVING SEGMENT
              OF THE
 TIMBER PRODUCTS PROCESSING
    POINT SOURCE CATEGORY
     Engineering and Analysis Division
     Office of Science and Technology
           Office of Water
United States Environmental Protection Agency
           Washington,D.C.
           September 1991

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                                    PREFACE

             This is one of a series of Preliminary Data Summaries prepared by the
Office of Science and Technology of the U.S. Environmental Protection Agency.  The
Summaries contain engineering, economic and environmental data that pertain to
whether the industrial facilities in various industries discharge pollutants in their
wastewaters and whether the EPA should pursue regulations to control such discharges.
The summaries were prepared in order to allow EPA to respond to the mandate of
section 304(m) of the Clean Water Act, which requires the Agency to develop plans to
regulate industrial categories that contribute to pollution of the Nation's surface waters.

             The Summaries vary in terms of the amount and nature of the data
presented.  This variation reflects several factors, including the overall size of the
category (number of dischargers), the amount of sampling and analytical work performed
by EPA in developing the Summary, the amount of relevant secondary data that exists
for the various categories, whether the industry had been the subject  of previous studies
(by EPA or other parties), and whether or not the Agency was already committed to a
regulation for the industry. With respect to the last factor, the pattern is for categories
that are already the  subject of regulatory activity (e.g., Pesticides, Pulp and Paper) to
have relatively short Summaries. This is because the Summaries are  intended primarily
to assist EPA management in designating industry categories for rulemaking. Summaries
for categories already subject to rulemaking were developed for comparison purposes
and contain only the minimal amount of data needed to provide some perspective on the
relative magnitude of the pollution problems created across the categories.
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                            ACKNOWLEDGEMENTS


            Preparation of this Preliminary Data Summary was directed by

Mr. Richard E. Williams of the Engineering and Analysis Division, with support provided
under EPA Contract No. 68-CO-0032.


            Additional copies of this document may be obtained by writing to the
following address:


            Document Control Officer
            Engineering and Analysis Division (WH-552)
            U.S. Environmental Protection Agency
            401 M Street, S.W.
            Washington, D.C. 20460
                                     111

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                          TABLE OF CONTENTS
                                                                   Page
PREFACE ..................................... ... ................. ii

ACKNOWLEDGEMENTS  .................... . ...................... iii

EXECUTIVE SUMMARY  ........................................... vii

SECTION I   INTRODUCTION ...................................... I_!

           A    Background ........................................ I_l
           B.    Purpose and Authority ............................... I_l
           C.    Regulatory Status Under the CWA  ................. '.'.'.'.'. 1-4
           D.    Related Regulatory Activities .......................... 1-5

SECTION H    SUMMARY OF METHODOLOGY .......................  H-l

           A    Review and Assessment  .............................  n-1
           B.    Sampling and Analytical Program .......... ; ...........  H-2

SECTION HI   INDUSTRY DESCRIPTION ...........................  m-1

           A.    Summary ............................ ...........  ni-1
           B.    Standard Processes and Practices ......................  ni-2
           C.    Subcategorization .................................  ni-9

SECTION IV   WASTE CHARACTERIZATION .......................  IV-1

           A.    Wastewater Generation .............................  IV-l
           B.    Wastewater Characterization .........................  IV-3

SECTION V    INDUSTRY POLLUTANT LOADS .......................  V-l

SECTION VI   CONTROL AND TREATMENT TECHNOLOGIES  ........  VI- 1

           A    Introduction .....................................  VI-1
           B.    Current Practices .................................  VI-1
           C.    Applicable Control and Treatment Technologies  ..........  VI-9

REFERENCES
                                   IV

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                                LIST OF TABLES
1-1


1-2


n-i

n-2

m-i

IV-l


IV-2


IV-3


IV-4


IV-5


V-l



V-2



V-3



VI-1
 Summary of Effluent Guidelines and Standards for Wood
 Preserving-Boulton Subcategory	1-7

 Summary of Effluent Guidelines and Standards for Wood
 Preserving-Steam Subcategory	1-8

 Summary of Analytical Program	H-4

 1987ITD List of Analytes	H-5

 Typical Composition of Creosote	  III-3

 Summary of Reported Analytical Results, Wood Preserving
 Facility A	IV-25

 Summary of Reported Analytical Results, Wood Preserving
 Facility B	IV-29

 Summary of Reported Analytical Results, Wood Preserving
 Facility C  	IV-33

 Summary of Reported Analytical Results, Wood Preserving
 Facility D  	IV-46

 Summary of Reported Analytical Results, Wood Preserving
 Facility E  	IV-56

 Estimated Annual Raw Wastewater Pollutant Loads at 1.26
 gal/cubic ft., Boulton Subcategory Facilities, Preliminary
 Characterization Study of the Wood Preserving Industry	V-8

Estimated Annual Raw Wastewater Pollutant Loads at 0.96
 gal/cubic ft., Boulton Subcategory Facilities, Prehminary
 Characterization Study of the Wood Preserving Industry	V-9

Estimated Annual Raw Wastewater Pollutant Loads, Steam
 Subcategory Facilities, Preliminary Characterization Study of
the Wood Preserving Industry	 V-10

Range of Average Raw Waste Concentrations, Preliminary
Characterization Study of the Wood Preserving Industry	VI-11

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                               LIST OF FIGURES
IV-1



IV-2




IV-3



IV-4




IV-5
                                                                          Page
Facility A - Process Flow Schematic	  IV-6



Facility B - Process Flow Schematic	IV-10




Facility C - Wastewater Treatment System Schematic	    IV-14



Facility D - Process Flow Schematic	IV-18



Facility E - Process Flow Schematic	IV-22
                                      VI

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                               EXECUTIVE SUMMARY

              The Engineering and Analysis Division (BAD, formerly the Industrial
 Technology Division) of the U.S. Environmental Protection Agency (EPA) conducted a
 preliminary characterization study of the wood preserving industry hi response to section
 304(m) of the Water Quality Act of 1987.  Section 304(m) requires the Agency to
 develop a plan that identifies categories of sources discharging toxic or nonconventional
 pollutants for which effluent limitations guidelines and/or standards have not been
 previously published. Section 304(m) also directs that a schedule for the annual review
 and revision of promulgated effluent guidelines be  developed.  The Agency has identified
 the wood preserving subcategories of the timber products processing point source
 category as candidates for study under the section 304(m) directive.

             As part of the study, the Agency conducted engineering site visits at 14
 wood preserving facilities and sampling episodes at five of the facilities visited.
 Wastewater and sludge samples were collected during the sampling episodes. Based on
 analysis of the samples  collected, the range of annual pollutant loads for raw wastewaters
 on an industry-wide basis  is approximately:
             Volatile Organics
                   Priority Organics
                   Nonpriority Organics
             Semivolatile Organics
                   Priority Organics
                   Nonpriority Organics
             Dioxins/Furans1
             Pesticides/Herbicides
             Metals
660-1,200 Ibs/yr
5,400-16,000 Ibs/yr
45,000-75,000 Ibs/yr
103,000-169,000 Ibs/yr
21-21.5 Ibs/yr
37-37.6 Ibs/yr
163,000-164,000 Ibs/yr
   '2,3,7,8-TCDD was not detected in any samples. The pollutant loads presented are in terms of total
mass, not 2,3,7,8-TCDD equivalents.
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             Semi-quantitative Metals
             Conventional Pollutants
                   BOD
                   Oil & Grease
                   TSS
225,000-237,000 Ibs/yr
3,450,000-3,500,000 Ibs/yr
229,000-232,000 Ibs/yr
804,000-806,000 Ibs/yr
The estimates presented above do not include pollutant loadings from facilities that treat
only with inorganic preservatives. Facilities that treat with inorganic preservatives have
not been allowed to  discharge process wastewater directly to the surface waters of the
United States since 1974.  These facilities have not been allowed to discharge process
wastewater to publicly-owned treatment works (POTWs) since 1982.

             Most facilities that treat wood with organic preservatives practice some
degree of reuse and recycle of process waters. For this reason, the pollutant loadings
shown above for raw wastewater are higher than those actually discharged by the wood
preserving industry.

             Various control technologies, including both process changes and end-of-
pipe treatment, are  available to reduce  the pollutant loads discharged from wood
preserving facilities. Process changes include wastewater volume reduction, waste stream
segregation, and drippage control.  End-of-pipe treatments include oil/water separation,
chemical flocculation, slow sand filtration, biological treatment, and evaporation.

              This document summarizes the most current information available
 regarding the discharge of wastewater by the wood preserving industry containing priority
 and nonpriority pollutants included on the 1987 Industrial Technology Division List of
 Analytes.  Section I discusses the Agency's authority for conducting this study and the
 current regulatory status  of the wood preserving industry. The methodology used in
 conducting the study is described in Section  II. A profile and description of the wood
 preserving industry  are presented in Section  IE.  A description of the facilities sampled
 along with the analytical results for each sampling episode is provided in Section IV.
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Section V presents estimates of industry raw waste pollutant loads based on information
from the sampling episodes, and Section VI discusses control and treatment technologies
that may be applicable to this industry.
                                        IX

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                                    SECTION I
                                 INTRODUCTION
 A.
 BACKGROUND
             Wood preserving facilities treat wood with chemical preservatives to
 prevent or delay deterioration or decay. The most common preservatives used are
 creosote, pentachlorophenol, and various formulations of waterborne, inorganic
 chemicals. Wood preserving processes consist of conditioning to remove moisture from
 the wood followed by the application of preservative. There are over 500 wood
 preserving facilities in the United States.

             This document summarizes the most current information available
 regarding the generation and management of wastewater and solid wastes by the wood
 preserving industry. The objectives of this document are to 1) provide a summary of
 current information on wood preserving liquid and solid wastes, and 2) provide a
 technical basis for evaluating whether the  industry should undergo further study.
B.
PURPOSE AND AUTHORITY
             The purpose of this study was to obtain a preliminary characterization of
wastewaters and solid wastes generated by the wood preserving industry, and to develop
an estimate of the pollutant loadings in wastewater from wood preserving operations.

             The U.S. Environmental Protection Agency (EPA) is required by Section
301(d) of the Federal Water Pollution Control Act Amendments of 1972 and 1977 (the
Clean Water Act), to review and revise, if necessary,  effluent limitations and standards
promulgated pursuant to Sections 301, 304,  and 306.  In conjunction with this review
program, and as a result of a court settlement with several environmental  groups, EPA
has undertaken a major examination of toxic pollutants discharged by industrial sources.
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            To achieve these goals, the Engineering and Analysis Division (BAD) is
responsible for (1) developing, proposing, and promulgating effluent limitations
guidelines, based on best practicable control technology (BPT) and best available
technology economically achievable (BAT), new source performance standards (NSPS),
pretreatment standards for existing and new sources (PSES and PSNS), and for
developing best management practices (BMPs) for industrial facilities; (2) ensuring the
adequacy and validity of scientific, economic and technical data and findings used to
support the effluent limitations and standards; (3) gathering, developing and analyzing
data and background information basic to the annual review and periodic revision of the
limitations and standards; and (4)  developing technical information required for the
judicial review of effluent limitations guidelines and standards.

             Section 304(m), added by the Water Quality Act of 1987, established a new
process for planning the development of effluent limitations guidelines and standards
under the Clean Water Act (CWA). Section 304(m) directs EPA to publish biennial
plans for the annual review and revision of promulgated effluent guidelines and
standards.  On January 2, 1990 (55 FR 80), the wood preserving subparts of the timber
products processing point source category were identified as a segment of the industry
for which additional information should be collected under the Section 304(m) directive
(see 55 FR 97).

             M addition to its responsibilities under the CWA, EPA is also charged by
the Resource Conservation and Recovery Act of 1976 (RCRA), as amended, with
oversight of cradle-to-grave management of hazardous wastes.  Section 3018(a) of
RCRA, as amended by the 1984 Hazardous and Solid Waste Amendments  (HSWA),
directed EPA to submit a report to Congress concerning wastes discharged through
sewer systems to publicly owned treatment works (POTWs) that are exempt from RCRA
regulation as a result of the Domestic Sewage Exclusion of RCRA. The Domestic
 Sewage Exclusion (DSE), which was established by Congress in section 1004(27) of
 RCRA, provides that solid or dissolved material in domestic sewage is not solid waste as
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 defined in RCRA.  Therefore, such materials cannot be considered a hazardous waste
 for purposes of RCRA. The Domestic Sewage Exclusion applies to industrial wastewater
 discharged to municipal sewers that contain domestic sewage, even if the industrial
 wastewater would otherwise be considered hazardous.

             Implicit in the Domestic Sewage Exclusion is the assumption that the
 pretreatment program mandated by the CWA can ensure adequate control of industrial
 discharges to sewers.  This program, detailed under section 307(b) of the CWA and
 implemented in 40 CFR Part 403, requires EPA to establish pretreatment standards for
 pollutants discharged to POTWs  by industrial facilities for those pollutants that interfere
 with, pass through, or otherwise are incompatible with the operation of POTWs.

             Section 3018(b) of RCRA directs the Administrator to revise existing
 regulations and promulgate pretreatment standards for specific hazardous pollutants
 when necessary to ensure that hazardous wastes discharged to POTWs are controlled
 adequately.  These standards are to be promulgated pursuant to RCRA, section 307 of
 the CWA, or any other appropriate authority possessed by EPA.

             EPA's Office of Water submitted The Report to Congress on the Discharge
 of Hazardous Wastes to Publicly Owned Treatment Works  (EPA-530-SW-86-004) to
 Congress on February 7, 1986.  This report, referred to as the Domestic Sewage Study or
 DSS, examined the nature and  sources of hazardous wastes discharged to POTWs,
 measured the effectiveness of EPA's program in dealing with such discharges, and
 recommended ways  to improve the programs to achieve better control of hazardous
 wastes being discharged to POTWs.

             The DSS concluded that the Domestic Sewage Exclusion should be
 retained at the present time and recommended ways to improve various EPA programs
under the CWA to obtain better control of hazardous wastes being discharged to
POTWs.  In addition, the DSS recommended research efforts to fill information gaps,
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and indicated that other statutes (such as RCRA and the Clean Air Act) should be
considered, along with the CWA, when establishing controls for either hazardous waste
dischargers or receiving POTWs or both.

             One of the recommendations of the DSS was that EPA review and amend
categorical pretreatment standards to achieve better control of the pollutants in
hazardous wastes. The DSS recommended that the Agency modify existing standards to
improve control of organic priority pollutants, organic non-priority pollutants, and
conventional pollutants, and that EPA promulgate categorical pretreatment standards for
industrial categories not included in the Natural Resources Defense Council consent
decree (NRDC v. Train. 8 ERC 2120, D.C.C. June 8, 1976).

             This preliminary characterization study of the wood preserving industry was
conducted under the authority of Sections 301(d) and 304(m) of the CWA, which require
periodic review and revision of limitations promulgated pursuant to Sections 301, 304,
and 306 of the CWA,
C.
REGULATORY STATUS UNDER THE CWA
             This study constitutes the fourth wastewater study of the wood preserving
industry subcategories of the timber products processing point source category.  Effluent
guidelines, new source performance standards, and pretreatment standards for new
sources for the wood preserving segment were promulgated in April 1974, pretreatment
standards for existing sources were promulgated in December 1976, and revisions to the
regulations were published in January 1981. Limited information that has been gathered
indicates that significant procedural and operational changes have occurred at wood
preserving facilities since 1981.  The current effluent guidelines and standards for the
Boulton and steam subcategories are presented in Tables 1-1 and 1-2, respectively.  The
limitation for all levels of control for the Wood Preserving-Waterborne or Nonpressure
subcategory is no discharge of process wastewater pollutants.  The information presented
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 in this preliminary data summary will be used by the Agency to evaluate whether the
 existing guidelines and standards for wood preserving should be studied further.
 D.
RELATED REGULATORY ACTIVITIES
              On December 6, 1990 (55 FR 50450), EPA amended its hazardous waste
 listing regulations under the Resource Conservation and Recovery Act (RCRA) by listing
 as hazardous three categories of wastes from wood preserving operations that use
 chlorophenolic, creosote, and/or inorganic (arsenical and chromium) preservatives. The
 listed wastes are wastewaters, process residuals, preservative drippage, and spent
 formulations from wood preserving processes generated at plants that use
 (1) chlorophenolic formulations, (2) creosote formulations or (3) inorganic preservatives
 containing arsenic and chromium (F032, F034, and F035, respectively). The new listings
 do not include K001, bottom sediment sludge from the treatment of wastewater from
 wood preserving processes that use creosote and/or pentachlorophenol.

             The term "wastewaters" in these listings includes, but is not limited to,
 wastewater generated from steam conditioning the wood prior to applying the
 preservative, preservative formulation recovery and regeneration wastewater, and water
 used to wash excess preservative from the surface of preserved wood.  Operations that
 involve the rinsing of drums, storage tanks, the process area, and equipment also
 generate wastewater that is included in the listings.  Finally, water, including rainwater,
 that accumulates in door and retort sumps and rainwater falling on or in the immediate
vicinity of the treating cylinder or work tank area is also included in the listings. Storage
 area rainwater is not included in the listing definition.

             The term "process residuals" in the listings includes materials such as
sawdust, wood chips, sand,  dirt, and stones that are attached to the wood when it enters
the treating cylinder or tank and are washed off the wood during the treating process.
These  materials will form a residue in the treating cylinder or tank, and may settle out of
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the preservative solution elsewhere in the process or be removed during filtration of the
preservative prior to its reuse. Tar and emulsified or polymerized oils may also settle
out in the treating cylinder or tank during wood preserving operations using creosote or
pentachlorophenol. These wastes are also considered process residuals.

             The term "drippage" refers to excess preservative that exudes from the
wood following treatment. The December 6, 1990 listing does not apply to precipitation
runoff from treated wood in the storage yard or runoff from the storage yard itself.  The
listing preamble states that drippage must cease on the process area drip pad before the
treated wood can be moved to the storage yard.

             As discussed in Part B of this section, wastewaters discharged to sewers
and eventually to POTWs by wood preserving facilities are exempt from RCRA
regulations under the Domestic Sewage Exclusion of RCRA. Similarly, treated effluent
from wastewater treatment at wood preserving facilities discharged under a NPDES
permit is also exempt from RCRA regulations (40 CFR Part 261.4).  However, when the
hazardous waste listings for the wood preserving industry discussed above become
effective, these wastewaters will be subject to RCRA requirements when they are
managed on site and prior to discharge.  Once a listed wastewater is discharged from a
wood preserving facility, the RCRA requirements no longer apply. The wastewater is
subject to Clean Water Act pretreatment standards if it is indirectly discharged, and all
NPDES permit provisions if it is directly discharged.
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                   Table 1-1

       Summary of Effluent Guidelines and
Standards for Wood Preserving-Boulton Subcategory
Level of Control
BPT
BAT
NSPS
PSNS
PSES
Limitations
No discharge of process
No discharge of process
wastewater pollutants
wastewater pollutants
No discharge of process wastewater pollutants
No discharge of process
wastewater pollutants
Maximum for any 1 day
Oil & Grease
Copper
Chromium
Arsenic
mg/1
100
5
4
4
gm/m3 production
20.5
0.62
0.41
0.41
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                      Table 1-2

Summary of Effluent Guidelines and Standards for
        Wood Preserving-Steam Subcategory
Level of Control
BPT




BAT
NSPS
PSNS
PSES



Limitations
kg/1000 m3 of product
(A)
COD 1,100
Phenok 2.18
Oil & Grease 24.0
pH 6.0-9.0
(B)
550
0.65
12.0
6.0-9.0
Reserved
No discharge of process wastewater pollutants
No discharge of process wastewater pollutants
Maximum for any 1 day
mg/I
Oil & Grease 100
Copper 5
Chromium 4
Arsenic 4
gm/m3 production
20.5
0.62
0.41
0.41
(A) - Maximum for any one day.

(B) - Average of daily values for 30 consecutive days.
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                                   SECTION II

                         SUMMARY OF METHODOLOGY


             In this study, EPA directed its efforts toward characterizing current

practices and processes in the wood preserving industry. The efforts included a review of

published information on the industry and a sampling and analytical program, as
described below.
A.
REVIEW AND ASSESSMENT
            A review of available information on the wood preserving was conducted.
The documents reviewed included:


            •      Wood preserving trade association documents;

            •      EPA documents including the Development Document for Effluent
                   Limitations Guidelines and Standards for the Timber Products
                   Processing Point Source Category, January 1981 and the Background
                   Document Supporting the Proposed Listing of Wastes for Wood
                   Preservation and Surface Protection Processes, December, 1988; and,

            •      Lists of wood preserving plants and statistics from various sources.


            Information gathered during this review included:
                   Descriptions of standard industry processes and practices, including
                   waste generation and waste treatment and handling;

                   Industry statistics on wastewater generation rates, production levels,
                   preservatives used, and trends in the industry;

                   Waste characterization data, including water use and wastewater
                   characterization data; and

                   Information on control and treatment technologies.
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             It is important to note that the information available does not represent a
survey of 100 percent of the wood preserving industry.  However, the available
information does indicate some trends in the industry.  In the last decade, wood
preserving facilities have been switching from the use of traditional organic preservatives,
such as creosote and pentachlorophenol, to the use of waterborae preservatives.  In 1973,
seventeen percent  of the industry production was wood treated with waterborne
preservatives, as reported by the American Wood Preservers Association (AWPA). In
1986, 59 percent of the industry production was wood treated with waterborne
preservatives (Reference 1). Another trend in  the industry was the increase in extensive
internal recovery, reclamation, and reuse and recycling of wood preserving solutions to
reduce the volume of wastewaters and sludges generated.

             To obtain a current assessment of industry practices and waste
characteristics, EPA conducted and engineering site visit and waste sampling program in
1988 and 1989.  During this program, engineering site visits were conducted at thirteen
wood preserving facilities and sampling episodes were conducted at five wood preserving
facilities as discussed below.
B.
SAMPLING AND ANALYTICAL PROGRAM
             Based on the industry information reviewed, a site selection/plant sampling
program was initiated in an effort to obtain a current characterization of the wood
preserving industry and the types of liquid and solid wastes generated by the wood
preserving industry. Selection of facilities for engineering site visits focused on pressure
treating plants using creosote or pentachlorophenol preservatives.  Facilities that use
waterborne preservatives have been subject to a "no discharge" standard since 1974, and
wastewater generated at these facilities is typically reused in preparing preservative
formulations. Since no facilities were identified during this study that use waterborne
preservatives and treat or discharge wastewater, no facilities that use waterborne
preservatives were included in the sampling program.
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             Facilities selected for site visits were intended to be characteristic of the
 organic pressure treating subcategories represented in terms of processing steps and level
 of production.  Facilities were also selected to represent effective, state-of-the-art
 handling and disposal of waste effluents and sludges.  Considerations in selecting
 facilities for sampling were the processes employed, accessibility of sampling points, and
 the rate of wastewater flow through the facility's treatment system.  The rate of
 wastewater  flow was a consideration because some facilities batch treat wastewater and
 discharge it on a schedule that is too infrequent or unpredictable to allow for reasonable
 scheduling of sample collection.

             Using the criteria listed above, thirteen facilities were selected for site
 visits and five of the thirteen visited were selected for sampling.  A description of the
 five facilities sampled is  presented in Section IV.  Treatment system influent and effluent
 samples were collected if representative samples could be obtained. Samples were also
 collected at intermediate points in the wastewater treatment system where appropriate.
 Trip blanks, sample blanks, and duplicate samples were  collected and analyzed for
 quality assurance/quality control purposes.

             The samples obtained were analyzed for constituents on the 1987 Industrial
 Technology Division List of Analytes. This list contains  conventional pollutants,
 excluding fecal colifonn,  and EPA's Priority Pollutants, excluding asbestos, as well as 285
 other inorganic nonconventional pollutants or pollutant characteristics.  The pollutants
 on the List of Analytes were derived from other EPA lists, including the Superfund
 Hazardous Substance List, the RCRA Appendix Vffl and Appendix IX, and the list of
 analytes proposed to be added to RCRA Appendix VII by the Michigan Petition
 (49 FR 49793).

             A summary of the analytical program, listing the types of  waste samples
and QA/QC samples collected  and the types of analyses performed on  these samples, is
provided in  Table H-l. A full list of analytes is presented in Table H-2.
                                        II-3

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                                   Table H-2
                           1987 ITD List of Analytes
Volatile Organic Pollutants

1,1,1,2-tetrachloroethane
1,1,1-trichloroethane
1,1,2,2-tetrachloroethane
1,1,2-trichloroethane
1,1-dichloroethane
1,1-dichloroethene
1,2,3-trichloropropane
1,2-dibromoethane
1,2-dichloroethane
1,2-dichloropropane
1,3-dichloropropane
1,3-dichloropropylene
l,3-dichloro-2-propanol
1,4-dioxane
l-bromo-2-chlorobenzene
l-bromo-3-chlorobenzene
2-butenal
2-chloroethyl vinyl ether
2-hexanone
2-picoline
3-chloropropene
4-methyl-2-pentanone
acetone
acrolein
acrylonitrile
allyl alcohol
benzene
bromoform
bromodichloromethane
bromomethane
carbon disulfide
carbon tetrachloride
chlorobenzene
chloroethane
chloroform
chloromethane
chloroprene
cis-l,3-dichloropropene
dibromochloromethane
dibromocbloropropane
dibromomethane
dichlorofhioromethane
diethyl ether
dimethyl sulfone
ethyl benzene
ethyl cyanide
ethyl methacrylate
isobutyl alcohol
methacrylonitrile
methyl ethyl ketone
methyl iodide
methyl methacrylate
methylene chloride
N,N-dimethylformamide
tetrachloroethene
toluene
trans-1,2-dichloroethene
trans-l,3-dichloropropene
trans-l,4-dichloro-2-butene
trichloroethene
trichlorofluoromethane
vinyl acetate
vinyl chloride

Semivolatile Organic Pollutants

1,2,3-trichlorobenzene
1,2,3-trimethoxybenzene
1,2,4,5-tetrachlorobenzene
1,2,4-trichlorobenzene
1,2-dichlorobenzene
1,2-diphenylhydrazine
1,3,5-trithiane
1,3-dichlorobenzene
1,4-dichlorobenzene.
1,4-dinitrobenzene
                                       II-5

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                                   Table H-2

                                  (Continued)
Semivolatile Organic Pollutants (Cont.)

1,4-napMhoquinone
1,5-naphthalenediamine
l-chloro-3-nitrobenzene
1-methylfluorene
1-methylphenanthrene
1-naphthylamine
2,3-dichloroaTriline
2,3-dichloronitrobenzene
2,4,5-trichlorophenol
2,4,5-trimethylaniline
2,4-dimethylphenol
2,4-dinitrophenol
2,4-dinitrotoluene
2,6-dichlorophenol
2,6-dMtrotoluene
2,6-di-tert-butyl-p-benzoquinone
2-chloronaphthalene
2-chlorophenol
2-isopropylnaphthalene
2-methylbenzothiazole
2-methylnaphthalene
2-nitroaniliiie
2-naphthylamine
2-nitrophenol
2-phenylnaphthalene
2-(methyltbio)benzotbiazole
3,3-dichlorobenzidine
SjS-dimetho^benzidiiie
3,6-dimeth.ylphenanthrene
3-methylcholanthrene
3-nitroaniline
4,4'-methylene bis(2-chloroaniline)
4,5-methylene phenanthrene
4-aminobiphenyl
4-bromophenyl phenyl ether
4-chlorophenyl  phenyl ether
4-chloro-2-nitroaniline
4-chloro-3-methylphenol
4-nitrobiphenyl
4-nitrophenol
5-chloro-o-toluidine
5-nitro-o-toluidine
7,12-dimethylbenz(a)anthracene
acenaphthene
acenaphthylene
acetophenone
alpha-terpineol
aniline
anthracene
aramite
benzanthrone
benzidine
benzoic acid
benzo(a)anthracene
benzyl alcohol
biphenyl
bis(2-chloroethoxy)methane
bis(chloroethyl)ether
bis(2-chloroisopropyl)ether
bis(2-ethylhexyl)phthalate
benzo(a)pyrene
benzo(b)fluoranthene
benzo(gbi)perylene
benzo(k)fluoranthene
benzyl alcohol
biphenyl
bis(2-chloroethoxy)methane
bis(chloroethyl)ether
bis(2-chloroisopropyl)ether
bis(2-ethylhexyl)phthalate
bis(chloromethyl)ether
bromoxynil
butyl benzyl phthalate
carbazole
chrysene
dibenzothiophene
                                        n-6

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                                   Table H-2
                                  (Continued)
Semivolatile Organic Pollutants (Cont)

dibenzo(a,h)anthracene
dichloran
diethyl phthalate
dimethyl phthalate
dinitrocresol
diphenyl ether
diphenyl sulfide
diphenylamine
di-n-butyl phthalate
di-n-octyl phthalate
di-n-propyhiitrosamine
erythritol anhydride
ethylene thiourea
ethyhnethane sulfonate
fluoranthene
fluorene
hexachlorobenzene
hexachlorobutadiene
hexachlorocyclopentadiene
hexachloroethane
hexachloropropene
hexanoic acid
indeno(l,2,3-cd)pyrene
isophorone
isosafrole
longifolene
nitrobenzene
N,N-dimethylformamide
N-decane
N-docosane
N-dodecane
N-eicosane
N-hexacosane
N-hexadecane
N-nitrosodiethylamine
N-nitrosodimethylamine
N-nitrosodiphenylamine
N-nitrosodi-n-butylamine
N-nitrosomethylethylamine
N-nitrosomethylphenylamine
N-nitrosomorpholine
N-nitrosopiperidine
n-octacosane
n-octadecane
n-tetracosane
n-tetradecane
n-triacontane
o-anisidine
o-cresol
o-toluidine
pentachlorobenzene
pentachloroethane
pentachlorophenol
pentamethylbenzene
perylene
phenacetin
phenanthrene
phenol
phenothiazine
pronamide
pyrene
pyridine
p-chloroaniline
p-cresol
p-cymene
p-dimethylaminoazobenzene
p-nitroaniline
resorcinol
safrole
squalene
styrene
thianaphthene
thioacetamide
thiophenol
                                       H-7

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                                  Table H-2

                                 (Continued)
Semivolatile Organic Pollutants (Cont.)
captafolthioxanthone
triphenylene
tripropylene glycol methyl ether

Pesticides and Herbicides

2,4,5-T
2,4,5-TP
2,4-D
4,4'-DDD
4,4'-DDE
4,4'-DDT
aldrin
alpha-BHC
azinphos-ethyl
azinphos-methyl
beta-BHC
captafol
captan
carbophenothion
chlordane
chlorfenvinphos
chlorobenzilate
chlorpyrifos
coumaphos
crotoxyphos
cygon
delta-BHC
demeton
diallate
diazinon
dichlone
dichlorvos
dicrotophos
dieldrin
dinoseb
dioxathion
disulfoton
endosulfan I
endosulfan n
endosulfan sulfate
endrin
endrin aldehyde
ethylenebisdithiocarbamic acid, salts and
 esters
famphur
fensulfothion
fenthion
gamma-BHC
heptachlor
heptachlor epoxide
hexamethylphosphoramide
isodrin
kepone
leptophos
malathion
maneb
methoxychlor
methyl parathion
mevinphos
mirex
monocrotophos
nabam
naled
nitrofen
parathion ethyl
PCB-1016
PCB-1221
PCB-1232
PCB-1242
PCB-1248
PCB-1254
PCB-1260
PCNB
phorate
phosmet
                                       II-8

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                                  Table H-2
                                 (Continued)
 Pesticides and Herbicides (Cont.)

 phosphamidon
 sulfotepp
 TEPP
 terbufos
 tetrachlorvinphos
 thiram
 toxaphene
 trichlorofon
 tricresylphosphate
 trifluralin
 trimethylphosphate
 zineb
 ziram

 Dibenzo-p-Dioxins and Dibenzofurans

 2,3,7,8-TCDD
 dibenzofuran
 heptachlorodibenzofurans
 heptachlorodibenzo-p-dioxins
 hexachlorodibenzofurans
 hexachlorodibenzo-p-dioxins
 octachlorodibenzofurans
 octachlorodibenzo-p-dioxins
 pentachlorodibenzofurans
 pentachlorodibenzo-p-dioxiiis
 tetrachlorodibenzofurans
 tetrachlorodibenzo-p-dioxins

 Elements

 aluminum
 antimony
 arsenic
barium
beryllium
bismuth
 boron
 cadmium
 calcium
 cerium
 chromium
 cobalt
 copper
 dysprosium
 erbium
 europium
 gadolinium
 gallium
 germanium
 gold
 hafnium
 holnium
 indium
 iodine
 iridium
 iron
 lanthanum
 lead
 lithium
 lutetium
 magnesium
 manganese
 mercury
 molybdenum
 neodymium
 niobium
 osmium
palladium
phosphorus
platinum
potassium
praseodymium
                                     n-9

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                                  Table II-2
                                 (Continued)
Elements (Cont.)

rhenium
rhodium
ruthenium
samarium
scandium
selenium
silicon
silver
sodium
strontium
sulfur
tantalum
tellurium
terbium
thallium
thorium
thulium
tin
titanium
tungsten
uranium
vanadium
ytterbium
yttrium
zinc
zirconium

Conventional Pollutants

BODS
oil and grease, total recoverable
pH
TSS
Classical Nonconventional Pollutants

ammonia, as N
chloride
COD
conductivity
corrosivity
flash point
fluoride
nitrate/nitrite
nitrogen, Kjeldahl, total
reactivity
residue, filterable
salinity (with calcium)
salinity (with sodium)
sulfate
total cyanide
TDS
total organic carbon
total phosphorus
total solids
total sulfide
total volatile solids
                                      n-io

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                                   SECTION III
                            INDUSTRY DESCRIPTION
A.
SUMMARY
             Wood preservatives are used to delay deterioration and decay of wood
caused by wood-destroying organisms such as insects, fungi, and marine borers.  The
term "wood preservative" may also refer to fire retardants, which prevent wood from
supporting its own combustion.  There are approximately 587 wood preserving facilities
in the United States. The industry produces over 500 million cubic feet of treated wood
per year.  Data from 1987 (Reference 1) show that 97.8 million cubic feet of wood were
treated with creosote, 48.6 million cubic feet with pentachlorophenol, and 419 million
cubic feet with waterborne preservatives.  Approximate yearly production within each
wood preserving subcategory of the timber products processing point source category in
1984 was 419 million cubic feet for the Wood Preserving-Waterborne or Nonpressure
subcategory, 125 million cubic feet for the Wood Preserving-Steam subcategory, and 21.4
million cubic feet for the Wood Preserving-Boulton subcategory (Reference 2).  The
average volume of wastewater generated per volume of wood treated is approximately
0.52 gal/ft3 for facilities in the steam subcategory and 1.26 gal/ft3 for plants in the
Boulton subcategory (Reference 3).  Facilities using waterborne preservatives typically do
not discharge any wastewater.

            A description of the chemicals and processes used by the industry is
presented below.
                                       m-i

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B.
STANDARD PROCESSES AND PRACTICES
1.
Types of Preservatives
             The most common preservatives used in wood preserving are creosote,
pentachlorophenol, and inorganic arsenical and/or chromate salts (inorganics).

             Creosote generically refers to mixtures of relatively heavy residual oils
obtained from the distillation of tar or crude petroleum. Typical constituents of creosote
are listed in Table TTT-1.  Although creosotes can be derived from a variety of tars,
including wood, petroleum, and coal-based tars, only coal tar-based creosotes are
generally accepted for use as wood preservatives.  Creosote formulations are used mainly
in treating railroad ties, fence posts, lumber and timbers, crossarms, poles, and marine
and fresh-water piling.

             Pentachlorophenol is one of a group of synthetic organic compounds, called
chlorophenols, which are commercially manufactured by reacting chlorine with phenol.
For wood preserving, pentachlorophenol is used in a wide variety of solvents including
heavy petroleum and creosote oils, light petroleum solvents, and volatile solvents.
Standard petroleum oils are most frequently used in preparing the treating formulations,
which typically contain 5 percent total pentachlorophenol. Pentachlorophenol impurities
have been found to include penta- to octachlorinated dioxins and furans.
Pentachlorophenol formulations are used primarily to treat poles, crossarms, lumber,
timbers, and fence posts.
                                        IH-2

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                                  Table IH-1
                      Typical Composition of Creosote2
           Major Components
 Acenaphthene
 Anthracene
 Benz(a)anthracene
 Benzo(a)pyrene
 Benzofluorenes
 Biphenyl
 Carbazole
 Chiysene
 Dibenz(a,h)anthracene
 Dibenzofuran
 Dimethylnaphthalenes
 Fluoranthene
 Fluorene
 Methylanthracenes
 Methylfluorenes
 1-Methylnaphthalene
2-Methylnaphthalene
Methylphenanthrenes
Naphthalene
Phenanthrene
Pyrene
Range of Concentrations
    in Creosote (%)
        9-14.7
          2-7
       0.16-0.26
       0.04-0.06
        1.0-2.0
        0.8-1.6
        1.2-2.0
        2.6-3.0
       0.01-0.04
        4.0-7.5
        2.0-2.3
        0.5-10
        7.3-10
        3.9-4.0
        2.3-3.0
        0.9-12
        1.2-12
         3.0
        1.3-18
        16-21
        1.0-8.5
  2IARC Monographs, Volume 35, "Coal Tar and Derived Products."
                                     HI-3

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             Inorganic preservatives consist of arsenical and chromate salts and
fluorides dissolved in water.  The most commonly used inorganic preservatives include:

             •      Chromated Copper Arsenate (CCA);
             •      Ammoniacal Copper Arsenate (ACA);
             •      Acid Copper Chromate (ACC);
                   Chromated Zinc Chloride (CZC); and
             •      Fluor-Chrome-Arsenate-Phenol (FCAP).

The most frequently used formulation is CCA, which is typically diluted in water to 1 to
2 percent total CCA concentration.  Inorganic preservative mixtures are likely to undergo
chemical changes when heated to high temperatures during treatment.  Maximum
acceptable temperatures range from 120°F to 150°F.  Inorganics are used primarily for
the treatment of lumber and timber for the building industry.
 2.
Conditioning
             The wood preserving process consists of two basic steps:  (1) conditioning
 the wood to reduce its natural moisture content and increase its permeability to
 preservatives, and (2) impregnating the wood with the preservative.  Various
 combinations of conditioning and preservative application processes  are used at wood
 preserving facilities depending on the type of wood treated and the end use of the wood.
 Conditioning methods include:

              •      Steam conditioning;
              •      Vapor drying;
              •      Boulton conditioning;
                                        m-4

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             •      Kiln drying; and
             •      Air drying.

             Steam Conditioning.  Conventional steam conditioning (open steaming) is a
process in which wood is subjected to direct steam impingement at an elevated pressure
in a closed vessel or retort, thus vaporizing the water content of the wood. Immediately
following steaming, a vacuum is applied for one  to three hours to pull the steam and
vaporized wood water from the retort. Steam condensate that forms in the retort is
removed  through traps and is generally conducted to oil/water separators for removal of
free oils.  The steam condensate may be further  treated prior to reuse or discharge off
site.

             A variation of conventional steam conditioning is closed steaming, in which
steam is generated in situ by covering coils in the retort with water from a reservoir and
heating the water by passing process steam through the coils. The water is returned to
the reservoir after oil separation and is reused during the next steaming cycle. A small
blowdown from the storage tank is necessary to remove excess water and control the
level of wood sugars in the water.  Because the steaming water may be reused, closed
steaming generates less wastewater than open steaming.

             Modified closed steaming is another variation of the steam conditioning
process in which steam condensate is allowed to  accumulate in the retort during the
steaming operation until it covers the heating coils. Direct steaming is then discontinued
and the remaining steam required for the cycle is generated within the retort by using
the heating coils. At the end of the steaming cycle, the water in the cylinder is
discharged after oil contaminants are removed.

             Vapor Drying. Vapor drying consists of exposing wood in a closed vessel
to vapors  from an organic chemical.  Selected derivatives of petroleum and coal  tar, such
                                       m-5

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as high-flash naphtha, or Stoddard solvent, are preferred; but numerous chemicals,
including blends, are also employed as drying agents in this process.  Vapors for drying
are generated by boiling the chemical in an evaporator. The vapors are conducted to
the retort containing the wood, where they condense on the wood, give up their latent
heat of vaporization, and cause the water in the wood to vaporize. The water vapor thus
produced, along with excess organic vapor, is conducted from the vessel to a condenser
and then to a gravity-type separator.  The water layer is discharged from the separator
and the organic chemical is returned  to the evaporator for reuse. At the end of the
heating period, the flow of organic vapors to the vessel is  stopped, and a vacuum is
applied for 30 minutes to 2 hours to remove the excess vapor along with any additional
water. Since the drying cylinder frequently serves as the pressure treatment cylinder, the
wood can be treated immediately after conditioning.

             Boulton Conditioning.  Boulton conditioning consists of heating wood in a
preservative formulation in a pressure treating cylinder under vacuum conditions. The
preservative, which has a boiling point higher than the boiling point of water, serves as a
heat transfer medium. After the temperature in the treating cylinder is raised to
operating temperature, a vacuum is drawn and water vaporizes from the wood, passes
through the preservative bath, and is collected in a condenser.  The condensate then may
go to an oil-water separator and any further treatment or recycling steps. Boultonizing is
usually limited to wood that is to be  treated with creosote or pentachlorophenol
formulations through a pressure treatment process.

             Kiln Drying.  In kiln drying, lumber or poles are placed in dry kilns in
which air is circulated. Drying temperatures and times vary  with wood species and the
type of product.  Kiln drying may produce wastewater in the form of condensate, which
drains from the kiln during the drying cycle. Wood treated with inorganic preservatives
may be kiln  dried after treatment to remove excess water.
                                        m-6

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             Air Drying.  Air drying consists of allowing wood to dry at ambient
temperatures in storage yards for several months or longer.
3.
Preservative Application
             After conditioning, preservatives may be applied by either pressure or
nonpressure processes.  Pressure processes for applying wood preservatives employ a
combination of air and hydrostatic pressure and vacuum. Pressure treatment is
accomplished by submerging wood in a preservative solution within a sealed cylinder, or
retort. Nonpressure processes are usually carried out in open tanks, at atmospheric
pressure.  Wood is immersed in the treating chemicals, which may be at ambient
temperature or above. Each of the major preserving processes is discussed below.

             Pressure Treatment Processes. There are two basic types of pressure
treatment processes, distinguished by the particular sequence of application of vacuum
and pressure.  The first pressure method is referred to in the industry as the "empty cell"
process.  In the empty cell process, the retort is first pressurized to force the preservative
into the wood.  The pressure cycle is followed by a vacuum to remove excess
preservative.  The empty cell process is used to obtain relatively deep penetration with
limited absorption of preservative, typically desired for products such as railway ties,
poles, fence posts, and construction lumber.  The second method, known as the "full cell"
process, results in higher retention of preservative but limited penetration compared to
the empty cell process. In the full cell process, a vacuum is drawn on the retort, and the
preservative is added, breaking the vacuum.  The preservative is then forced into the
wood under pressure. The full cell process is particularly desirable for wood used in the
marine environment.  The difference between the empty cell and full cell processes can
be viewed simply as whether the objective is to fill the wood cells (full cell) or just to
coat them (empty cell) with preservative. There is no difference  hi the types of wastes
generated by full cell and empty cell processes, although wood treated by the full cell
                                       m-7

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process may drip more and has a greater tendency to bleed than wood treated by the
empty cell process.

             A vacuum-only preservative process is also used.  This process is simpler to
control than the pressure-vacuum processes but requires more complex equipment than
is generally used for nonpressure processes.  The vacuum-only process is performed by
enclosing wood in an airtight container, pulling an initial vacuum, and adding
preservative solution to atmospheric pressure.  The preservative is driven into the wood
by the pressure difference between the initial vacuum and the atmospheric pressure.  A
final vacuum may be applied to control preservative retention and recover excess
solution.  The vacuum-only method is commonly used to treat window sashes with
pentachlorophenol.

             Nonpressure Treatment Processes.  A limited quantity of wood is treated
by nonpressure processes. Nonpressure processes include brushing or spraying, dipping,
soaking, and thermal processes. The length of treatment and the concentration of the
preservative are important factors  in nonpressure processes because the preservative is
driven into the wood by diffusion.

             In the brushing and spraying methods of preserving wood, the preservative
is applied to the surface of the wood in a thick layer and is allowed to soak in.  Creosote
and pentachlorophenol preservatives are generally applied by these methods. Brushing
and spraying are  most effective when applied to  end-gram surfaces because better
penetration occurs in the  direction of the grain.  The preservative is usually mixed  and
stored in tanks or drums.

             Dipping is generally used to treat structural forms of timber and consists of
immersing wood  in a bath of preservative for a few seconds or a few minutes. Like
brushing and spraying, dipping is also used to  apply creosote and pentachlorophenol
                                        m-8

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preservatives, although it generally uses more preservative. Dipping has the advantage
over brushing and spraying of more adequately treating the wood by further penetration
due to the longer contact period between the wood and the preservative.

             Soaking involves immersing wood in an unheated oil solution (commonly a
pentachlorophenol formulation) for periods ranging from two days to one week. The
wood must be well-conditioned, i.e., dry, to achieve maximum absorption of the
preservative. The effectiveness of treatment by soaking depends on the type of wood
and on the product being treated.  It is also possible to soak wood in water-based
solutions for several days or even weeks at ambient temperature.  This process is also
referred to as steeping.

             The thermal process involves the immersion of conditioned wood in
successive baths of hot and cool preservative. Each stage typically takes 8  to 48 hours,
depending on the ambient temperature and the water content of the wood. The hot
baths expand the outer layers of the timbers and evaporate moisture through the surface
of the wood. The  cold bath causes the air and vapor in the outer shell of the  wood to
contract, thereby forming a partial vacuum. Atmospheric pressure then forces the
surrounding preservative into the wood. Creosote and pentachlorophenol formulations
are generally used in the thermal process, however, inorganic formulations have been
used.
C.
SUBCATEGORIZATION
             The wood preserving subcategories of the timber products processing point
source category were established when effluent guidelines and standards were first
promulgated for the industry in 1974. When revisions to the regulations were
promulgated in 1982, the title of the subcategory originally called Wood Preserving was
                                       m-9

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changed to Wood Preserving - Waterborne or Nonpressure to be more descriptive of the

subcategory. The subcategories are:
                   Wood Preserving - Waterborne or Nonpressure: This subcategory
                   includes wastewater from all nonpressure wood preserving treatment
                   processes and all pressure wood preserving processes employing
                   waterborne inorganic salts;

                   Wood Preserving - Steam:  This subcategory includes wastewater
                   from wood preserving processes that use direct steam impingement
                   on wood as the predominant conditioning method, processes that
                   use the vapor drying process as the predominant conditioning
                   method, processes which use the same retort to  treat with both salt
                   and oil type preservatives, and steam conditioning processes which
                   apply both salt type and oil type preservatives to the same stock;
                   and

                   Wood Preserving - Boulton: This subcategory includes wastewater
                   from wood preserving operations which use the  Boulton process as
                   the predominant method of conditioning.
                                       ni-io

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                                   SECTION IV
                           WASTE CHARACTERIZATION

A.           WASTEWATER GENERATION

             Process wastewater is defined under 40 CFR Part 401 of Chapter N-
Effluent Guidelines and Standards as any water which, during manufacturing or
processing, comes into direct contact with or results from the production or use of any
raw material, intermediate product, finished product, byproduct, or waste product (40
CFR 401.llq). The existing effluent limitations guidelines and standards for the wood
preserving industry regulate  all process wastewaters and precipitation runoff from the
immediate process area where the process equipment is located. The term "process
wastewater" specifically excludes material storage yard runoff (either raw material or
processed wood storage).

             The major sources of wastewater in the wood preserving industry are
internal wood water which is removed from the wood during the conditioning process
and steam condensate which is generated during conditioning.  The wood water and
steam condensate become contaminated from contact with the wood constituents, oil and
grease, and preservative.  Other sources  of wastewater include wastewater generated
during preservative formulation recovery and regeneration, drippage and spills from the
retort, precipitation runoff, and wastewater from other miscellaneous sources.
Wastewater  generation can vary from one facility to another and is based on  the types of
conditioning and preservative application processes performed by the  facility, as well as
the facility's housekeeping and waste  management practices.

             The sources  of wood preserving wastewaters for each subcategory are
further described  below.
                                       IV-1

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                  Boulton Subcategory.  In the Boulton process, the conditioning step
                  takes place in a preservative bath in the retort while the retort is
                  operated under vacuum. The wastewater produced by this
                  conditioning method consists of the water driven out of the wood
                  and some residual preservative. The volume of wastewater
                  produced will vary according to wood type and preservative
                  formulation.

                  Steam Subcategory. In steam conditioning, the wood is subjected to
                  direct, semi-direct or closed steaming in order to vaporize the water
                  contained in the wood.  The wastewater resulting from steam
                  conditioning consists of the water driven out of the wood and, in
                  some cases, contaminated steam condensate.

                  Waterborne or Nonpressure Subcategory.  Wood treated with
                  inorganic arsenical and/or chromate salts is almost exclusively
                  conditioned by air or kiln drying.  Inorganic processes can be
                  operated with no net generation of wastewater because, 1) the
                  conditioning methods used produce little or no wastewater, and  2)
                  any excess water can be used in making up the next batch of
                  preservative chemicals.  Furthermore, condensate from vacuum
                  systems and precipitation that falls in the treatment area may be
                  used as makeup water for inorganic preservative formulations. In
                  the air drying, or seasoning process, the untreated wood is kept  in a
                  storage yard for long periods of time to reduce the moisture content
                  by natural evaporation.  This process does not produce
                  contaminated wastewater.  In loin drying, the moisture content is
                  removed by holding the raw or fresh wood in controlled
                  temperature  and humidity conditions. Kiln drying following
                  inorganic preservative application may produce a small amount  of
                  condensate contaminated with the preservative that can be reused.
                  Air or kiln drying may also be used to condition wood prior to
                  treatment with organic preservatives.
             In addition to the above identified sources of wastewater for each

Subcategory, there are other sources of wastewater generation at wood preserving

facilities.  Some of the water driven out of the wood will accumulate in organic wood

preserving formulations. This water is then separated from the preservative formulation

using an oil/water separator.  In processes utilizing a pressure/vacuum retort, not all of
                                       IV-2

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the wastewater generated in the retort can be effectively condensed and collected.
Contaminated steam or condensate may leak from the retort door gaskets or drip from
the door as it is opened; preservative solution residuals may also spill out as the door is
opened. Slowdown from wet air pollution control devices, drum rinsates, vehicle and
equipment washdown wastewater, process area washdown wastewater, and pole washer
wastewater are other possible sources of wastewater.
B.
WASTEWATER CHARACTERIZATION
             The purpose of this section is to describe the characteristics of wastewaters
and sludges generated by wood preserving processes.  The information and data
presented were developed from samples and information collected during this study of
the wood preserving industry.

             The Agency conducted sampling episodes at four wood preserving facilities
in 1988 and one in 1989. Three of the facilities use the Boulton process or a
modification of the Boulton process to condition and treat most of their wood. One of
the facilities uses air drying to condition their wood but also conditions and treats wood
using the Boulton process. Two of the Boulton facilities also use a thermal process to
condition and treat a small percentage of their  stock.  The other Boulton facility treats
some wood using waterborne preservatives. One of the facilities sampled is in the steam
subcategory.  This facility uses modified closed  steaming followed by pressure treatment.
All five facilities use pentachlorophenol and/or creosote as preservatives. Two of the
facilities are indirect dischargers and three  do not discharge any wastewater.

             All sampling and analysis efforts were conducted using appropriate quality
assurance and quality control procedures as specified by Handbook for Sample
Preservation of Water and Wastewater. U.S. EPA, EMSL, Cincinnati, OH, EPA-600/4-
82-029, September 1982, and procedures as specified in each Agency-approved method.
The pollutants analyzed for these samples are presented in Section II of this document.
                                       IV-3

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Analytical data summaries for each facility are presented at the end of this section. Data
are presented only for pollutants that were detected at least once in the sampled streams
for each facility.  A description of each facility and a schematic diagram of the
wastewater treatment system at the facility are provided in the following sections.  To
maintain confidentiality, each facility has been assigned a letter code.
1.
Wood Preserving Facility A (Boulton Subcategorv)
             This facility, located in the Pacific Northwest, treats utility poles, posts, and
pilings. The facility is capable of treating approximately 600,000 cubic feet of wood per
year. The stock treated by the facility is approximately 50 percent Douglas fir and 50
percent western cedar.

             Facility A treats wood with pentachlorophenol  dissolved in a carrier solvent
that is similar to No. 2 diesel oil.  Ninety-five percent of the  wood treated by the facility
is treated in a single retort eight feet in diameter and 120 feet in length operated under
pressure.  The process used is the Lowry-Boulton method in which conditioning occurs
under vacuum conditions, then the vacuum is released and the retort is allowed to  stand
at atmospheric pressure.  The preservative solution is then added and the retort is
pressurized to drive the preservative into the wood.

             A small number of utility poles are treated in an open tank (known as a
butt tank) by a thermal process. The poles are placed in the tank of preservative
solution and conditioned by heating the preservative to 200°F. After conditioning, the
hot preservative is pumped out and replaced with a cold preservative solution that is
taken up  by the conditioned wood.

             The facility also performs ancillary operations  including cutting and
debarking poles and storing untreated and treated poles.  The facility is capable of
treating wood with creosote  hi addition to pentachlorophenol, however, creosote has not
                                         IV-4

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 been used at the facility since 1982.  Some creosote remained in tanks on-site at the time
 of the sampling episode.

             Sources of wastewater at the facility are tree sap and moisture removed
 from the wood during conditioning, precipitation captured in the retort area, in the
 tankage areas and in open separating tanks, and equipment washdown water. The
 wastewater collection system consists of sumps for collection  of spillage, storm water, and
 equipment washdown water, and tanks for storage of storm water and sap water
 condensate. The wastewater treatment system consists of two oil/water separators. The
 effluent is discharged to the municipal sewer. A schematic diagram of the process and
 wastewater treatment system is shown in Figure IV-1.

             Wastewater consisting of the sap and moisture removed from the wood is
 generated during the conditioning process. This portion of the wastewater stream is
 drawn off under vacuum, condensed, and pumped to the primary oil/water separator.
 Drippage, storm water, and equipment washdown water collected in the various sumps
 are also pumped to the  primary oil/water separator.  Periodically, the water layer  from
 the primary oil/water separator is drained  into the secondary separator,  a four-stage API
 type oil/water separator. Residual water from the  oil/preservative layer in the second
 separator  is evaporated  in an evaporator tank. The oil/preservative mixture is returned
 to work tanks for reuse. Wastewater is discharged from the second separator to a
 holding pit. The pit discharges into the municipal sewer.

            Most of the water treated and discharged to the municipal sewer system is
 storm water. The facility does not measure the volume of storm water captured and
 discharged to the sewer. Approximately 900 to 1200 gallons of sap water are generated
per charge of wood to the pressure retort.  The facility treats  approximately 240 charges
 of wood per year.  Plant personnel estimate that the wastewater treatment system
 discharges an average of 1,000 to 3,000 gallons of treated wastewater per week to the
municipal sewer system.
                                       IV-5

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                      IV-6

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             The facility has a steam generating system consisting of a wood-fired boiler,
vapor condensers, and a cooling tower. The steam generated is used to heat the
preservative for the Lowry-Boulton and thermal treatment processes. Cooling water for
the vapor condensers is  cycled to the cooling tower and then reused. Similarly, vacuum
seal water is a part of the same closed system and is recycled to the cooling tower and
back. The thermal treatment process does not generate any wastewater as the tank is
open and the sap water  and collected storm water evaporate to the atmosphere.  Boiler
exhaust steam and boiler blowdown water are discharged to the holding pit with the
wastewater from the second oil/water separator and  then discharged to the municipal
sewer.
             Two samples of the influent to the secondary oil/water separator and two
samples of the effluent from the secondary oil/water separator were collected at this
facility for a total of four samples.  Since the facility treats wastewater on a batch basis,
all samples were collected as grab samples.  The influent samples were grab samples
collected from the inlet pipe to the separator.  The effluent samples were also grab
samples collected from the discharge pit after the separator.  Samples were collected on
two different days.  On each day, the influent and the effluent sample were collected at
approximately the same time.  Sample collection locations are shown on Figure IV-1.  A
summary of the analytical results for the sampling episode is presented in Table F/-1 at
the end of this section.

             The final effluent from Facility A meets the existing discharge limits for oil
and grease, copper,  chromium, and arsenic.  There was a decrease in the concentration
of each of these pollutants in the effluent samples compared to the influent samples.
However,  the concentration of pentachlorophenol was higher in the effluent samples
than in the influent  samples. The influent concentrations of  pentachlorophenol were
4,751 ug/1 and 4,124 ug/1 on Day 1 and Day 2 of sampling, respectively.  The effluent
                                       IV-7

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concentrations of pentachlorophenol were 7,237 ug/1 and 5,053 ug/1 on Day 1 and Day 2
of sampling, respectively.

             Influent sample concentrations of dioxins/furans were generally higher than
their respective concentrations in the effluent samples.  There was no consistent trend in
the concentrations of pesticides/herbicides between the influent and the effluent
samples; some concentrations increased and others decreased. Metal concentrations
generally increased in the effluent samples compared to the influent samples.
2.
Wood Preserving Facility B (Boulton Subcategorvt
             This facility, located in the Pacific Northwest, treats utility and telephone
poles with pentachlorophenol and creosote.  The facility produces approximately 100,000
cubic feet of treated Douglas fir and western red cedar per month.  Approximately
ninety percent of the faculty's stock is treated with a solution of five percent
pentachlorophenol in a medium aromatic oil that is similar to No. 2 diesel oil. The
remaining stock is treated with a solution of creosote and coal tar.

             The facility conditions wood by air drying.  Alternatively, wood may be
conditioned using the Boulton process.  The facility pressure treats wood in one of two
pressure retorts that are eight feet in diameter and 147 feet in length.  One retort is used
exclusively for treating with pentachlorophenol and the other is used for both
pentachlorophenol and creosote. The preservative solution is moderately heated in
storage tanks using indirect steam.  In the preservative application step, the preservative
mixture is transferred to the retort while the retort is subjected to high pressure, in a
procedure known as the Rueping process.  The preservative application step is followed
by a final steaming cycle and a final stripping step under vacuum to remove excess oil
 and dry the wood surface.
                                        IV-8

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             The facility treats a small number of utility poles in an open tank (known
as a butt tank) by a thermal process. The poles are placed in the tank of preservative
solution and conditioned by heating the preservative to 200°F.  After conditioning, the
hot preservative is pumped out and replaced with a cold preservative solution that is
then taken up by the conditioned wood.  The facility also performs  ancillary operations
including cutting, drilling, and debarking green wood and storing untreated and treated
wood.

             Sources of wastewater at the facility are tree  sap and  moisture removed
from the wood during conditioning and storm water.  Storm water is collected from the
drip pads in front of the retorts and from sumps in the retort and storage tank areas.
The facility disposes of wastewater by evaporation and has  no discharge. A schematic
diagram of the process and wastewater treatment system at Facility B is shown in
Figure IV-2.

             The plant has separate treatment systems for wastewater generated by
pentachlorophenol preservation and that generated by creosote preservation.  Vapors
from the retorts are condensed and stored in hot wells.  The pentachlorophenol
wastewater is gravity fed to an oil/water separator somewhat like a circular clarifier and
then piped to a single stage separator box. The recovered  pentachlorophenol mixture is
recycled to the process.  Following the separator box, the water is pumped to a cooling
tower for evaporation or to the condensers for use as a coolant. The creosote
wastewater is treated in a cylindrical tank separator followed by a four-stage API type
separator.  The recovered creosote is reused in the process and the  water is pumped to
the cooling tower.

             The facility does not blow down cooling water from the cooling tower tank.
Almost no sediment collects in the cooling tower tank because the facility continuously
filters the preservative solution in the storage/work tanks through a filter press to
remove solids.  The filter press solids are disposed of as hazardous waste. Additionally,
                                       IV-9

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IV-10•

-------
the facility has an effective dust control program that includes vacuuming the wood after
cutting or drilling to prevent solids from getting into the preservative solution.

             One grab sample of the cooling tower water was collected at Facility B.
The sample was dipped from the surface of the cooling water in the collection tank
below the cooling tower.  The water was a yellowish-brown color but the presence of
free oil was not observed. A summary of the analytical results for this sample  is
presented in Table IV-2 at the end of this section.

             The concentration of oil and grease in the cooling tower water at Facility B
was  160 mg/1 and the concentration of pentachlorophenol was 30,745 ug/1.  Overall, the
concentrations of semivolatile organic, metal, and conventional pollutants and
dioxins/furans were higher in the cooling tower water at Facility B than in the  final
treated wastewater from any of the other facilities sampled.  The concentration of
pesticides/herbicides was lower in the cooling tower water at the Facility B than in the
final treated wastewater from any of the other facilities sampled with the exception of
Facility D. The concentration of volatile organic pollutants in the cooling tower water at
Facility B was higher when compared to final effluent samples from some of the other
facilities and lower when compared to others.
3.
Wood Preserving Facility C (Boulton Subcategorvt
             This facility, located in the Pacific Northwest, treats poles, lumber, shaped
products, plywood, pilings, and playground equipment.  Ninety percent of the facility's
product is treated poles.  The facility produces approximately 5.7 million cubic feet of
treated Douglas fir, western red cedar, and pine per year.

             Facility C treats wood with organic preservatives including creosote,
pentachlorophenol, and copper naphthanate, and waterborne preservatives including
chromated copper arsenate (CCA).  The facility has six pressure retorts ranging in length
                                       IV-11

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from 60 to 180 feet. One of the retorts is used only for CCA preservation, and the other
five may be used with any preservative, including CCA.

             The facility uses the Boulton process followed by pressure treatment for
conditioning and treating wood with organic preservatives. The preservative solutions
used are a creosote/coal tar mixture, a solution of three to five percent
pentachlorophenol dissolved in a light  aromatic hydrocarbon solvent, and copper
naphthanate dissolved in a petroleum solvent.  The facility may also treat wood with a
mixture of creosote and pentachlorophenol.

             Wood that is to be treated with waterborne preservatives is first
conditioned by air drying or kiln drying.  The wood is then placed hi a retort, and the
retort is filled with preservative solution then pressurized to drive the preservative into
the wood.

             Sources of wastewater at the facility are tree sap and moisture removed
from the wood during the Boulton conditioning process in which creosote and/or
pentachlorophenol are used, storm water and drippage.  Storm water and drippage are
collected from the drip pads in front of the retorts and from sumps in the retort area,
the storage tank farm, and the wastewater treatment area. The facility has four different
oil/water separation systems: one for collected storm water and drippage, one for
wastewaters generated by the creosote treatment  process, one for wastewaters generated
by the pentachlorophenol treatment process, and  one for wastewaters from the combined
use of creosote and pentachlorophenol. Wastewater from all four oil/water separation
systems is treated in the facility's biological treatment system.  All wastewater generated
during treatment with waterborne preservatives is reused.

              Collected storm water and drippage are pumped to a Monarch oil/water
separator.  Monarch separators achieve separation by coalescing oil on treated plates
with subsequent gravity separation. The separated water fraction is pumped to the
                                        IV-12

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facility's biological treatment system, and the oil fraction is returned to a work tank for
reuse.

             Wastewater from the creosote treatment process flows through one of two
8,000 gallon heated storage tanks and then to a five-stage API type oil/water separator.
The oil fraction is piped to a work tank for reuse.  The water fraction is pumped to a
secondary Monarch separator.  The oil fraction from the secondary separator is also
returned to a work tank, and the water fraction flows to the facility's biological treatment
system.

             Wastewater from the pentachlorophenol treatment process flows through a
different primary oil/water separator. The oil fraction is piped to a work tank for reuse
and the water fraction is pumped to a secondary Monarch separator.  The oil fraction
from the secondary separator is returned to a work tank.  The water fraction from the
secondary separator flows through an additional separator and then to the facility's
biological treatment system.

             The facility also has separate primary and secondary oil/water separators
for wastewater from the occasional combined use of creosote and pentachlorophenol.
Wastewater from all of the facility's secondary separators is combined and pumped to
the biological treatment system, at a flow rate of approximately 10,000 gallons per day.
A schematic diagram of the biological treatment system is shown in Figure IV-3.

             The biological treatment system consists of, in sequence,  two equalization
tanks, a two-stage anaerobic digester, two aerobic activated sludge tanks, a gravity
clarifier, and a dissolved air flotation (DAF) clarifier.  Wastewater from the DAF
clarifier is pumped to  a holding tank, then to a storage tank, and finally to a cooling
tower for evaporation.  Cooling tower blowdown is routed back to the gravity clarifier.
The facility does not discharge any wastewater.
                                       IV-13

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IV-14

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             Sludge from the bottom of the gravity clarifier and the top of the DAF
clarifier is piped to a sludge thickening tank. Polymer is added to the thickening tank to
aid in dewatering of the sludge. After settling in the thickening tank, the sludge is
dewatered in a filter press.  The filter cake is a K001 hazardous waste and is
appropriately disposed.

             Three samples each of the influent to the biological treatment system, the
influent to the activated sludge tanks, and the treated wastewater from the biological
treatment system were collected at this facility.  A duplicate sample of the treated
wastewater from the biological treatment system and a sample of the activated sludge
were also collected. Sample collection locations are shown on Figure IV-3.  Samples
were collected over three consecutive 24-hour sample periods. Facility C has a
continuous wastewater flow, and all samples at Facility C were 24-hour composites
collected at four hour intervals rather than grab samples.  A summary of the analytical
results for the sampling episode is presented in Table IV-3 at the end of this section.

             Although Facility C does not discharge wastewater, the treated wastewater
from the biological treatment system meets the current effluent guidelines for Boulton
subcategory facilities. The concentration of oil and grease in the influent to the
biological treatment system ranged from 15 to 18 mg/1, and the concentration in the
treated wastewater from the biological treatment system ranged from 5 to 6.7 mg/1. In
contrast, the concentration of pentachlorophenol generally increased across the biological
treatment system; the biological treatment influent concentrations ranged from 1,874 to
2,209 ug/1 and the concentration in the treated wastewater from the biological treatment
system ranged from <50 to 3,727 ug/1.

             Components of creosote that were detected in the wastewater at Facility C
include acenaphthene, biphenyl, carbazole, dibenzofuran, fluoranthene, fluorene, 2-
methylnaphthalene, naphthalene,  and pyrene. The concentrations of these pollutants in
                                      IV-15

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the treated wastewater from the biological treatment system were lower than the
concentrations in the influent to the biological treatment system for all samples analyzed.
             Effluent sample concentrations of metals were generally lower than their
respective concentrations in the influent samples.  However, for the third sampling
period, the effluent sample concentrations of metals were generally higher than their
respective concentrations in the influent samples.  Dioxins/furans and
pesticides/herbicides were analyzed in only one sample, an effluent sample, on the first
day of sampling.
4.
Wood Preserving Facility D (Boulton Subcategory)
             This southern wood preserving facility pressure treats sawn hardwood
timber using a coal tar creosote.  The facility treats approximately three million cubic
feet of timber per year. The wood is 85 percent red oak or white oak and is primarily
used for railroad ties.

             Most of the wood treated by the facility is air dried for eight to twelve
months prior to treatment, although  the facility may also condition and treat green wood
using the Boulton process.  The wood is pressure treated in one of three retorts that are
each eight feet in diameter and 104 feet in length.  The primary preservative application
process is a type of empty-cell process known as the Rueping process.  In this process,
the retort is charged with wood, closed, and subjected to 30 to 40 psi of air pressure.
Once the retort is under pressure, it is filled with creosote. The pressure is  then raised
to 180 psi and the creosote is heated to 180°F. The creosote is heated indirectly by
steam in closed coils located in the bottom of the pressure retorts. There is no contact
of the steam or the steam  condensate with the wood or creosote.  After the pressure
treatment cycle, the creosote is pumped out of the cylinder and returned to  a storage
tank. The wood is then placed under vacuum by a vacuum pump to draw excess
                                       IV-16

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 creosote, or "kickback" out of the wood prior to removing it from the retort. The final
 vacuum cycle lasts from one to two hours.

             Following preservation, the wood is removed from the retort and allowed
 to stand on a drip pad for four to six hours. The drip pad collects drippage from the
 treated wood as well as some creosote that spills from the retort as the wood is
 unloaded.  The drip pad is washed down daily with steam and water. The washdown
 water and any rain water falling on the drip pad dram to a storm water collection pump
 station and are then pumped to the preservative recovery system by a level-activated
 pump.

             Sources of process water at the facility are condensed vapors generated
 from the Boulton conditioning process, process area storm water and washdown water
 collected from the drip pad,  and storm water collected in the tank farm areas.  All
 process waters are collected in sumps and routed to the preservative recovery system
 consisting of a primary oil/water separator and two identical, parallel secondary
 oil/water separators.   The wastewater stream from the secondary oil/water separators is
 routed to four 15,000 gaUon equalization basins prior to discharge through a flow
 metering system to a municipal wastewater collection system. A schematic diagram of
 the process, preservative recovery system, and wastewater treatment system is shown hi
 Figure IV-4.

            All process water from the  facility is pumped to the primary oil/water
separator for gravity separation of the creosote and water fractions. Process water from
the primary separator is pumped, with added polymers, to two secondary oil/water
separators in parallel.  Effluent from the secondary separators discharges to a series of
four open-top equalization basins.  Wastewater flows from the equalization basins to a
holding  sump and, when the sump is full, to a flow metering station that discharges to
the municipal sewer.  Creosote recovered in  the primary and secondary separators is
reused in the wood treating process.
                                      IV-17

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IV-18

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             Steam and hot water from the pressure retort steam coils are collected and
sent through a condenser. The hot water is then piped to cooling basins and discharged
to the first of the four equalization basins. Water for use as vacuum pump seal water is
recycled from the fourth equalization basin back to the production process and is
discharged to the preservative recovery system after use.  The facility effluent discharge
rate is between 6,000 and 30,000 gallons of wastewater daily.

             Storm water runoff from untreated and treated wood storage areas is
collected in runoff ditches and discharged to a storm water ditch outside the facility
without undergoing treatment.

             Samples were collected over three consecutive 24-hour sample periods at
this facility.  All samples were 24-hour composites collected at four hour intervals.
During the first and third sampling periods, samples were collected from the  discharge
trough of the primary oil/water separator (sample point 2) and from the flow monitoring
pit prior to discharge to the sewer (final effluent sample point 4). During the second
sampling period, samples were collected from the primary oil/water separator inlet pipe
(sample point 1) and discharge trough (sample point 2), from the discharge point of one
of the two secondary oil/water separators (sample point 3) and from the flow monitoring
pit (sample point 4). A sample of sludge was collected from the pit into which the sump
in the drip track in front of the pressure retorts drains (sample point 5).  Sample
collection locations are shown on Figure IV-4. A summary of the analytical results for
the sampling episode is presented in Table IV-4 at the end of this section.

             The final effluent for Facility D met the existing discharge limits for oil
and grease, arsenic, chromium, and copper. There was a decrease in the concentration
of oil and grease, copper, and arsenic in the final effluent samples compared  to the
concentration in the influent to the primary separator.  Chromium was not detected in
the influent or effluent samples.
                                      IV-19

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             Components of creosote detected in the wastewater at Facility D included
acenaphthene, anthracene, biphenyl, carbazole, chrysene, dibenzofuran, fluoranthene,
fluorene, naphthalene, phenanthrene, pyrene, 1-methylphenanthrene, and 2-
methylnaphthalene. There was a decrease in the concentration of these pollutants in the
effluent samples compared to the influent sample with the exception of carbazole,
fluoranthene, phenanthrene, and 2-methylnaphthalene, which were present at higher
concentrations in the effluent samples than in the influent sample.

             The concentration of metals in the effluent sample was three times higher
than in the primary separator influent sample during the second sampling period.
Dioxins/furans and pesticides/herbicides were analyzed in only one sample, a final
effluent sample.
5.
Wood Preserving Facility E (Steam Subcategory)
             This southern wood preserving facility treats southern yellow pine using
pentachlorophenol.  The facility produces approximately 85,000 cubic feet of treated
telephone and utility poles per month.

             Wood treated by Facility E is air dried for one week to six months prior to
steam conditioning and pressure treatment in one of two retorts eight feet in diameter
and 90 feet in length. The facility uses modified closed steaming to condition their
wood. Upon completion of the steaming cycle, a vacuum is applied to the retort to
remove moisture from the wood and contaminated steam condensate. The preservative
solution is then forced into the wood using the "full cell" pressure treatment process.
Following the injection step, the wood is held in the retort for several hours  so that as
much excess preservative solution as possible can be collected and returned to the work
tanks.
                                       IV-20

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             Sources of wastewater at the facility include sap water removed from the
wood during steam conditioning, contaminated steam condensate from the conditioning
process, drippage from the retorts when the retorts are opened to remove treated
product, and precipitation water that falls in the work area (the area around the retorts).
These wastewaters are  collected and treated. The facility stores both treated and green
wood in uncovered storage areas.  Storm water falling in the storage  areas is not
controlled and flows off the property.

             Preservative left hi the retorts after a treatment cycle is completed is
drained to one of two sumps which are used to separate the pentachlorophenol solution
from the water.  The pentachlorophenol solution is returned to the work tank, and the
water is piped to a holding tank. Any oily layer in the holding tank is also returned to
the work tank.  Sap water, steam condensate, drippage, and storm water collected in the
retort area are also drained to the sumps for separation.

             Wastewater from the holding tank is drained to a spray cooling system in
which wastewater is cycled through spray nozzles into a concrete-lined tank for cooling.
Some of the spray cooling system wastewater is pumped through a barometric condenser
to provide water for steaming of the retorts. Some evaporation occurs from the spray
cooling system, but water does accumulate in the tank.  When the level of wastewater in
the tank is too high, water is withdrawn from the tank and pumped to the facility's
wastewater treatment system. When the overall flow of wastewater is high, as in the
winter months, excess wastewater is pumped to two holding tanks for storage prior to
entering the facility's wastewater treatment system. The facility does  not have accurate
flow measurements to determine a water balance around the spray cooling system.

            The facility's wastewater treatment system consists of, in sequence, a
flocculation tank, a settling tank, a filter tank, a temper tank, and a BioTrol packed
submerged film bioreactor, as shown in Figure IV-5.  Bacteria, nutrients, and caustic are
added to the wastewater in the temper tank  to produce an optimum environment for
                                      IV-21

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 biological treatment.  At the time of the sampling episode, the effluent from the
 bioreactor was being routed back to the spray cooling pond for recycling or evaporation
 while the facility waited for approval to discharge to the local POTW.

             Samples were collected at four locations over three consecutive 24-hour
 sample periods at this facility. All samples were 24-hour composites collected at four
 hour intervals.  Sample collection locations are shown on Figure IV-5.  During all three
 sampling periods, samples were collected from the discharge line of the main holding
 tank (sample point 1), from one of the three spray nozzles for the spray cooling pond
 (sample point 2), from a tap  on the temper tank (bioreactor influent sample point 3),
 and from the discharge hose  of the bioreactor (sample point  4). During the second
 samplmg period, a duplicate sample of the bioreactor effluent (sample point 4) and a
 duplicate sample of the water in the spray cooling pond (sample point 2) were collected
 for quality assurance/quality  control purposes. In addition to the samples described
 above, a grab sample  of the sludge from the top of the fiocculation tank (sample point 5)
was collected during the third sampling period.  A summary of the analytical results for
the sampling episode is presented in Table IV-5 at the end of this section.

            Although Facility E was not discharging process wastewater at the time of
the sampling episode,  the bioreactor effluent met the existing discharge limits for oil and
grease, arsenic chromium, and copper.  There was a decrease in the concentration of oil
and grease, copper, and arsenic in the bioreactor effluent samples compared to the
concentration in the influent to the wastewater treatment system, the discharge from the
holding tank. Chromium was not detected in  the holding tank discharge or bioreactor
effluent samples.

            The concentration of pentachlorophenol generally decreased in the
bioreactor effluent samples compared to the holding tank discharge samples. The
concentration of pentachlorophenol in the holding tank discharge ranged from  <50 to
38,373 ug/1 and the concentration in the bioreactor effluent was <50 ug/1.
                                      IV-23

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             Effluent sample concentrations of metals were generally higher than their
respective concentrations in the influent samples.  Dioxins/furans and
pesticides/herbicides concentrations were lower in the effluent samples than in the
influent samples.
                                        IV-24

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                                    SECTION V
                          INDUSTRY POLLUTANT LOADS

             This section presents estimated raw wastewater pollutant loads for the
 Boulton and Steam subcategories of the Timber Products Processing Point Source
 Category. All plants within the Waterborne or Nonpressure subcategory are subject to a
 "no discharge of process wastewater pollutants" regulation.  Therefore, sampling episodes
 were not conducted at these facilities and pollutant loads were not calculated for the
 Waterborne or Nonpressure subcategory. For  both the Boulton and Steam
 subcategories, estimated pollutant loads are presented for the following groups of
 pollutants:
                   Priority and nonpriority volatile organics;
                   Priority and nonpriority semivolatile organics;
                   Dioxins and furans;
                   Pesticides and herbicides;
                   Metals;
                   Semi-quantitative metals; and
                   Conventional pollutants.
             It is important to note that these estimated raw wastewater pollutant loads
are based on a Limited amount of data from this preliminary characterization study of the
wood preserving industry.  Raw wastewater pollutant loadings for wood preserving
operations using organic preservatives are determined by calculating the loading after the
initial oil/water separation stage  (Reference 3, pp. 81 and 90).  Raw wastewater
pollutant concentrations for the Boulton subcategory were calculated using data from
Facilities A, C, and D. Only treated effluent data were available from Facility B,  the
other Boulton subcategory facility, and these data were not included in the pollutant
loading calculations. Similarly, wastewater generation rates for the Boulton subcategory
were calculated using data from Facilities A, C, and D because no wastewater generation
rate data were available from Facility B. For  comparison purposes, raw wastewater
                                       V-l

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pollutant loads were also calculated using wastewater generation rate data collected from
14 Boulton facilities in a 1981 study of the wood preserving industry (Reference 3).

             Raw wastewater pollutant concentrations for the steam subcategory were
calculated using data from Facility E, the only steam facility sampled for this preliminary
characterization study of the wood preserving industry.  No wastewater generation rate
data were available from Facility E, and hence, raw wastewater pollutant loads for the
Steam subcategory were calculated using wastewater generation rate data collected from
eight steam facilities in the 1981 study (Reference 3).  The pollutant concentration data
used to calculate raw wastewater pollutant loads are presented in Table IV-1 and Tables
IV-3 through IV-5 of this document.

             Under the existing regulations at the time of the sampling episodes, very
few Steam or Boulton subcategory facilities discharged wastewater to publicly-owned
treatment works (POTWs), and even fewer discharged wastewater directly to receiving
streams. Most facilities recycled or evaporated wastewater on site.  Therefore, the raw
wastewater pollutant loadings presented here represent the pollutant loadings generated
by the industry at the time of the sampling but do not represent the loadings discharged
by the industry, as very few facilities were actually discharging.

             Outlined below is the methodology that was used to estimate the raw
wastewater pollutant loads.
 1.
Average raw wastewater concentrations of individual compounds were
calculated from the raw wastewater concentration data obtained during this
preliminary characterization study of the wood preserving industry.  The
average concentrations of individual compounds were then summed to
obtain a total concentration for each pollutant group. The estimates take
into account only pollutants that were reported above detection limits in  at
                                        V-2

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 least one raw wastewater sample for each subcategory. Within each
 subcategoiy, three different methods were used to estimate average
 concentrations for each pollutant as described below.

 •      Method A - In this method, if a pollutant was not
       detected above the detection limit in an individual
       sample, the concentration of the pollutant in that
       sample was assumed to be zero in calculating an
       average concentration for the pollutant.

       Method B - In this method, if a pollutant was not
       detected above the detection limit in an individual
       sample, the concentration of the pollutant in that
       sample was assumed to be equal to the detection limit
       in calculating an average  concentration for the
       pollutant.

 •      Method C - In this method, if a pollutant was not
       detected above the detection limit in an individual
       sample, that sample point was not included in
       calculating an average concentration for the pollutant.


 Based on available data, Methods A and B provide an estimate of the
 range of mass loads for the industry.  Method A assumes that if a specific

 concentration value was not reported for a pollutant, the pollutant was not

 present in the sample.  Method B assumes that if a specific concentration
 value was not reported for a pollutant, the pollutant was present in the

 sample at a concentration just below the detection limit  Method C does

 not account for the fact that pollutants are not always present at reportable

 concentrations.  Therefore, Method C overestimates pollutant loads and
 can be viewed as a "worst case" approach.


 For the Boulton subcategory, the average pollutant concentrations were

 calculated based on two days of data from Facility A (Sample Point 1),

three days of data from Facility C (Sample Point 1),  and three days of data
                           V-3

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2.
from Facility D (Sample Point 2). At Facilities A and D, the samples were
collected at the influent to a secondary oil/water separator and, hence, had
already undergone primary oil/water separation.  At Facility C, the
samples were collected at the influent to a biological treatment system and
the wastewater sampled had undergone both primary and secondary
oil/water separation.  Only treated effluent data are available for Facility
B, the other Boulton subcategory facility, and these data were not included
in the calculation of raw wastewater pollutant loads.

For the Steam subcategory, the average pollutant concentrations were
calculated based on three days of data from Facility E (Sample Point 1).
The samples were collected  at the influent to a spray cooling pond, after
primary oil/water separation had occurred in the  sumps in the retort area.

Wastewater generation rates for facilities in the Boulton and Steam
subcategories were calculated using available data. For the Boulton
subcategory, two  separate methods were used to estimate the volume of
wastewater discharged per mass of wood produced.  The first method used
the average of the production normalized wastewater generation rates for
fourteen Boulton facilities measured during the 1981 study of the wood
preserving industry (Reference 3). A flow rate of 1.26 gallons of
wastewater generated per cubic feet of treated wood was estimated using
this method. The second method used the average of the production
normalized wastewater generation rates reported for Facilities A, C, and D.
A flow rate of 0.96 gallons of wastewater generated per cubic foot of
treated wood was estimated using this method. Wastewater generation
rate data were not collected from Facility B for this preliminary
 characterization study of the wood preserving industry.
                                        V-4

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4.
 For the steam subcategoryj; wastewatgr volumes were estimated using the
 average of production normalized wastewater generation rate data
 collected from eight steam subcategory facilities during the 1981 study
 (Reference 3).  The resulting estimate is 0.52 gallons of wastewater
 generated per cubic foot of treated wood.  Wastewater generation rate data
 were not collected from Facility E for this preliminary characterization
 study.

 The annual production of treated wood for each subcategory was
 calculated using available data.  Available  data included the amount of
 wood treated with each type  of preservative (pentachlorophenol, creosote,
 inorganics) in 1987 and the percentage of facilities within each subcategory
 that treat with each preservative (References 1 and 3).  The amount of
 wood treated within each subcategory was  calculated by multiplying the
 percentage of facilities within each subcategory that use a specific
 preservative by the total amount of wood treated with that preservative.
 This methodology was chosen because data were not available indicating
 the number of facilities in each subcategory nor the production data for
 each facility in the industry.  Based on these calculations, approximately
 21.5 million cubic feet of wood are conditioned annually by the Boulton
 method and slightly over 129  million cubic  feet of wood are conditioned by
 the steaming method.

 Raw wastewater pollutant loadings were calculated by multiplying the
 average concentrations calculated in Step 1 by the production normalized
wastewater generation rates calculated in Step 2 and then multiplying by
the annual subcategory production calculated in Step 3.
                                       V-5

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             Tables V-l and V-2 show the estimated pollutant loads for the Boulton
subcategory for each of the three methods used to estimate the average pollutant
concentrations. The pollutant loads presented in Table V-l are based on the average
discharge flow rate from data collected at fourteen Boulton facilities during the 1981
study, and the pollutant loads presented in Table V-2 are based on the average discharge
flow rate from data collected at Facilities A, C, and D during this preliminary
characterization study. Table V-3 shows the estimated pollutant loads for the Steam
subcategory for each of the three methods used to estimate the average pollutant
concentrations. The pollutant loads presented in Table V-3 are based on the average
discharge flow rate from data collected at eight steam facilities during the 1981 study.

             The methodology outlined above was used to estimate raw wastewater
pollutant loads.  However, the numbers calculated are not estimates of the mass of
pollutants discharged to surface waters by wood preserving facilities.  First, the loads are
based on raw wastewater concentrations prior to complete treatment. Most facilities
employ treatment systems ranging from simple oil/water separation to multistage
oil/water separation and biological treatment.  Second, the loads are based on total
wastewater generation rates prior to discharge flow reduction techniques such as
evaporation, which are used by many facilities to reduce the amount of wastewater
discharged.

              Moreover, the  majority of wood preserving facilities do not discharge
 directly to surface waters. Data collected from 131 facilities indicate that 70 percent of
 Boulton and Steam subcategory facilities have no wastewater discharge (Reference 3).
 Of the facilities that do discharge wastewater, the vast majority are indirect dischargers.
 Of the 14 facilities that were visited in  1988 and 1989 for this preliminary
 characterization study, 11 facilities did not discharge any process wastewater, three
 facilities were indirect dischargers, and none of the facilities discharged directly.
                                         V-6

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              Existing effluent limitations guidelines require that Boulton subcategory
 facilities do not discharge wastewater.  Although existing BPT limitations for wood
 preserving facilities in the Steam subcategory allow a direct discharge, no Steam
 subcategory facilities that directly discharge wastewater were identified during the
 preliminary characterization study.

              It should also be noted that the estimated pollutant loads for the Steam
 subcategory are determined using data solely from facilities that employ the "closed
 steaming" process.  Closed steaming, a widely used alternative to the open steaming
 process, rninimizes contamination of steam condensate and typically results in a reduced
 volume of wastewater.  Consequently, the raw wastewater loads reported for the Steam
 subcategory may underestimate the average raw wastewater pollutant loads from steam
 facilities if open steaming facilities are considered. Additional investigation of discharges
 from open steaming facilities would  be required to quantify the discharge load difference
 between open and closed steaming facilities.

              Once again, these estimated raw wastewater pollutant loads are based on a
 limited amount of data.  Wastewater discharge flows and pollutant concentrations are
 dependent upon various factors such as preservative used, type of wood treated, facility
 specific procedures and practices and facility-specific control measures utilized.
 Wastewater flows and pollutant concentrations may vary widely from facility to facility
within each subcategory.
                                        V-7

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                                     Table V-l

  Estimated Annual Raw Wastewater Pollutant Loads at 1.26 gal./cubic ft.
                          Boulton Subcategory Facilities
     Preliminary Characterization Study of the Wood Preserving Industry

  (Based on Subcategory Average Wastewater Generation Rate of 1.26 gal/cubic ft.)
Pollutant Group
Volatile Organics
Priority Organics
Nonpriority Organics
Semivolatile Organics
Priority Organics
Nonpriority Organics
Dioxins/Furans*
Pesticides/Herbicides
Metals**
Semi-quantitative Metals
Conventional Pollutants
BOD
Oil & Grease
TSS
Method A
Obs/yr)

870
7,100

41,000
94,000
0.49
0.93
3,700
45,000

190,000
12,000
5,700
Method B
Obs/yr)

900
7,200

41,000
95,000
0.49
1.20
3,700
ND

190,000
12,000
5,700
Method C
(lbs/yr)

1,200
16,000

46,000
130,000
0.49
1.60
4,400
47,000

190,000
12,000
5,700
*Note that 2,3,7,8-TCDD was detected in only two samples during this study, and the load presented here is
a total mass and is not in terms of 2,3,7,8-TCDD equivalents.

**Calciura and Sodium were not included in the Metals calculations.

In Method A calculations, the concentration of individual pollutants was assumed to be zero if a specific
value was not reported.

In Method B calculations, the concentration of individual pollutants was assumed to be equal to the detection
limit if a specific value was not reported.

In Method C calculations, only pollutant concentrations above detection limits were considered.

ND - Not detected: no detection limit was reported.
                                           V-8

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                                       Table V-2

   Estimated Annual Raw Wastewater Pollutant Loads at 0.96 gal/cubic ft.
                           Boulton Subcategory Facilities
     Preliminary Characterization Study of the Wood Preserving Industry

    (Based on Subcategory Average Wastewater Generation Rate of 0.96 gaL/cubic ft.)
Pollutant Group
Volatile Organics
Priority Organics
Nonpriority Organics
Semivolatile Organics
Priority Organics
Nonpriority Organics
Dioxins/Furans*
Pesticides/Herbicides
Metals**
Semi-quantitative Metals
Conventional Pollutants
BOD
Oil & Grease
TSS
Method A
Obs/yr)

660
5,400

31,000
72,000
0.37
0.71
2,800
35,000

150,000
8,900
4,400
Method B
(Ibs/yr)

690
5,500

31,000
72,000
037
0.94
2,800
ND

150,000
8,900
4,400
Method C
(Ibs/yr)

940
12,000

35,000
100,000
0.37
1.24
3,400
35,000

150,000
8,900
4,400
*Note that 2,3,7,8-TCDD was detected in only two samples during this study, and the load presented here is
a total mass and is not in terms of 2,3,7,8-TCDD equivalents.

**Calcium and Sodium were not included in the Metals calculations.

In Method A calculations, the concentration of individual pollutants was assumed to be zero if a specific
value was not reported.

In Method B calculations, the concentration of individual pollutants was assumed to be equal to the detection
limit if a specific value was not reported.

In Method C calculations, only pollutant concentrations above detection limits were considered.

ND - Not detected: no detection Emit was reported.
                                          V-9

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                                     Table V-3

             Estimated Annual Raw Wastewater Pollutant Loads
                           Steam Subcategory Facilities
    Preliminary Characterization Study of the Wood Preserving Industry

  (Based on Subcategory Average Wastewater Generation Rate of 0.52 gal./cubic ft.)
Pollutant Group
Volatile Organics
Priority Organics
Nonpriority Organics
Semivolatile Organics
Priority Organics
Nonpriority Organics
Dioxins/Furans*
Pesticides/Herbicides
Metals**
Semi-quantitative Metals
Conventional Pollutants
BOD
Oil & Grease
TSS
Method A
(lbs/yr)

ND
ND

13,800
31,000
21
36
160,000
190,000

3,300,000
220,000
800,000
Method B
(lbs/yr)

ND
ND

14,000
31,000
21
36
160,000
—

3,300,000
220,000
800,000
Method C
(lbs/yr)

ND
ND

29,000
39,000
21
36
160,000
190,000

3,300,000
220,000
800,000
*Note that 2^,7,8-TCDD was detected in only two samples during this study, and the load presented here is
a total mass and is not in terms of 2^,7,8-TCDD equivalents.

**Calcium and Sodium were not included in the Metals calculations.

In Method A calculations, the concentration of individual pollutants was assumed to be zero if a specific
value was not reported.

In Method B calculations, the concentration of individual pollutants was assumed to be equal to the detection
limit if a specific value was not reported.

In Method C calculations, only pollutant concentrations above detection limits were considered.

ND - Not detected: no detection limit was reported.
                                          V-10

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                                   SECTION VI
                  CONTROL AND TREATMENT TECHNOLOGIES

             INTRODUCTION
             Based on the limited number of observations made during this preliminary
 characterization study, it appears that wastewaters from wood preserving processes
 contain a wide range of pollutants and that the types of pollutants found are, in general,
 consistent from one facility to another.  A range of average raw waste concentrations
 detected for each pollutant group is provided in Table VI-1. These findings are based
 on data collected during this study at four Boulton subcategory facilities and one Steam
 subcategory facility, all of which use organic preservatives (pentachlorophenol and
 creosote).  No sampling was performed at facilities that use inorganic preservatives
 because these facilities reuse all process wastewater and have no net wastewater
 discharge.

             The following discussion of current practices and applicable control and
 treatment technologies is based on information previously presented in Section VII of
 the Development Document for Effluent Limitations Guidelines for the Timber Products
Point Source Category (EPA 440/1-81/023, 1981) (Reference 3) and Section IV of the
Background Document Supporting the Proposed Listing of Wastes From  Wood Preservation
and Surface Protection Processes (EPA,  1988) (Reference 2).
B.
CURRENT PRACTICES
1.
In-PIant Controls
            In-plant controls are measures that a facility can use to reduce the quantity
or strength of its wastewater and thus reduce or simplify treatment needs.  Other in-plant
                                      VI-1

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measures are used to contain wastewater to avoid uncontrolled discharge. In-plant
controls employed by wood preserving facilities include reducing the volume of
wastewater generated and controlling drippage of preservative from treated wood.

             Volume Reduction

             Segregation of uncontaminated water from contaminated process water is
one method employed to reduce wastewater volumes.  One of the main sources of
uncontaminated residual water at wood preserving plants is steam coil condensate.
While in the past this water was frequently mixed with process wastewater, most facilities
now segregate it, thus reducing the total volume of wastewater. Some facilities reuse
steam coil condensate for boiler feed water, a practice that became feasible with the
development of turbidity sensing equipment to monitor the water and sound a warning if
oil enters the coil condensate return system.  Reuse of steam coil condensate, while
meaningful from a waste load reduction standpoint, can also represent a significant
energy saving in terms of heat recovery.

             The reuse of process water is becoming more common  in the wood
preserving industry.  Facilities treating wood with inorganic preservatives are subject to a
 "no discharge of process wastewater pollutants" regulation, and all of these facilities
 reuse their process water. Also, several facilities that treat with  organic preservatives
 reuse treated wastewater for boiler make-up or cooling water. Due to the nature of
 contamination present in wood preserving wastewater, some degree of treatment is
 required prior to reuse of wastewater for these purposes.  According to a survey of the
 wood preserving industry conducted in 1987 by the American Wood Preservers Institute
 (AWPI), 56 percent of the facilities using only a creosote preservative reuse their process
 water.  Of the facilities using either pentachlorophenol or a combination of
 pentachlorophenol and creosote, 40 percent reuse their process water (Reference  1).
                                         VI-2

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             Many wood preserving facilities are reducing the volume of wastewater
 generated by changing their wood treating practices and procedures.  For example, in
 recent years facilities have moved away from open steaming to modified closed or closed
 steaming. In the modified closed steaming process, condensate from direct steaming is
 allowed to accumulate in the retort during the steaming operation until it covers the
 heating coils.  At that point, direct steaming is stopped and the remaining steam is added
 to the system through the heating coils. This process change results in a reduced volume
 of contaminated condensate. In closed steaming, where no steam or condensate comes
 in direct contact with the wood or the preservative, condensate is returned to the boiler
 to be reused instead of being discarded.

             The principal advantage of modified closed steaming or closed steaming
 over open steaming, aside from reducing the volume of wastewater released by a plant, is
 that wastewater effluents from the retort are less likely to contain emulsified oils. The
 direct steam impingement on the wood employed during open steaming can cause oil
 emulsions to form in the wastewater. In modified closed steaming or closed steaming,
 oils in the wastewater from the conditioning process generally remain as a separate layer,
 known as free oil. Free oils are  more easily separated from the wastewater than
 emulsified oils; and, as a result of the reduction in oil content, the oxygen demand and
 the solids content of the wastewater are reduced significantly.  A possible disadvantage
 of the use of modified or closed  steaming is the fact that the rate of heat transfer of
 modified steaming is slower than direct steaming, and therefore, treating cycle times will
 be longer, resulting  in a reduced production rate.

            The technical feasibility of converting a wood preserving plant from open
steaming to  modified or closed steaming has been demonstrated by many plants within
recent years. The decision to convert a plant to the closed steaming process is based on
economic and product quality considerations related to the lower cost of end-of-pipe
treatment of a smaller volume of wastewater generated by a converted plant, possible
                                       VI-3

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reduced production rate, and possible effects on product quality resulting from changes
in the operational procedures.

             Drippage Control

             A major portion of the wastewater generated at wood preserving plants
comes from spills and drippage in the process area. According to the industry survey
conducted in 1987 by the AWPI, 91 percent of the facilities treating with inorganic
preservatives have an impervious or a surface covered drip pad, and approximately 50
percent of the facilities treating with organic preservatives have an impervious or a
surface covered drip pad (Reference 1).  Drip pads are used to collect any preservative
that drips from the treated wood when it is first removed from the treating cylinder.  A
larger percentage of the inorganic plants have surfaced drip pads because these facilities
are usually newer than wood preserving facilities that treat with organic preservatives,
and the facilities are specifically designed to collect and reuse any preservative drippage.
Most of the facilities that have surfaced drip pads report collecting and reusing or
treating any drippage.

             Another location where preservative drippage may occur is the long-term
 storage yard for treated wood. Only 13 percent of the facilities treating with
 pentachlorophenol and/or creosote have surfaced storage pads for treated wood. Of the
 facilities  treating with inorganic preservatives, 38 percent have some surfaced storage
 area (Reference 1).
 2.
End-of-Pine Treatment
              Wastewater treatment operations used by wood preserving facilities include
 oil/water separation, chemical flocculation, slow sand filtration, biological treatment, and
 evaporation.
                                         VI-4

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             Oil/Water Separation

             Because of the deleterious effects that oil has on all subsequent steps in
 wastewater treatment, efficient oil/water separation is a prerequisite to effective
 wastewater treatment in the wood preserving industry. Oil, whether free or in an
 emulsified form, accounts for a significant part of the oxygen demand of wood preserving
 effluents. The oil also serves as a carrier for toxic pollutants such as polynuclear
 aromatics, pentachlorophenol, and other chlorinated phenolics that are present in wood
 preserving wastes at levels higher than the pollutant's solubility in water.

             Oil/water separators of the API (American Petroleum Institute) type are
 extensively used by wood preserving plants for primary oil separation.  API-type oil
 separators are preceded and followed at many plants by a rough oil separation and a
 second oil separation stage, respectively. Rough oil separation occurs either hi the
 blowdown tank or in a surge tank preceding the API separator.  Secondary separation
 usually occurs in another API separator operated hi series with the first, or it may be
 conducted in any vessel or lagoon where the detention time is sufficient to permit further
 separation of free oil.

             Chemical Flocculation

             Because oil/water emulsions  are not broken by mechanical oil removal
procedures, chemical flocculation is  required to reduce the oil content of wastewaters
containing emulsions. Lime, ferric chloride, various polyelectrolytes, and clays of  several
types are used in the wood preserving industry for this purpose. Automatic metering
pumps and mixing equipment have been installed at some plants to expedite the process
of flocculation, which is usually carried out on a batch basis.  COD reductions of 30 to
80 percent or higher are achieved by chemical flocculation, primarily as a result of oil
removal. Average COD removal is about 50 percent.
                                       VI-5

-------
            Influent oil concentration to the flocculator varies with the efficiency of
mechanical oil separation and the amount of emulsified oil present in the wastewater.
The latter variable in turn is affected by type of preservative (either pentachlorophenol
in a petroleum solution, pure creosote, or creosote in a coal tar or petroleum solution),
conditioning method used, and design of oil-transfer equipment.  Pentachlorophenol
preservative solutions cause more emulsion problems than creosote  or its solutions, and
plants that steam condition - especially those that employ open steaming - have more
emulsion problems than plants that use the Boulton conditioning method.  Plants that
use low pressure, high volume oil transfer pumps have less trouble with emulsions than
those that use high pressure, low volume equipment.

             At many plants, decantation is part of the flocculation system.  Solids
removal is expedited by use of vessels with cone-shaped bottoms. Frequently, the solids
are allowed to accumulate from batch to batch, a practice which is reported to reduce
the amount of flocculating agents required.

             Slow Sand Filtration

             Many plants which flocculate wastewater subsequently filter it through sand
beds to remove the solids.  When properly conducted, this procedure is highly efficient in
removing both the solids resulting from the process as well as some of the residual oil.
The solids which accumulate on the bed are removed periodically along with the upper
inch or so of sand.

             The application of incompletely flocculated wastewater to filter beds will
 severely impact the performance of the filter beds.  The residual oil retards percolation
 of the water through the bed, thus necessitating the replacement of the oil saturated
 sand.  This has happened frequently enough at some plants that the sand filters have
 been abandoned and a decantation process used instead.
                                        VI-6

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             Biological Treatment

             Wastewater generated by the wood preserving industry is amenable to
biological treatment.  In fact, biological treatment can reduce concentrations of COD,
total phenols, oil and grease, pentachlorophenol, and organic toxic pollutants in wood
preserving wastewaters. The amount of reduction of these pollutants in the wastewater
depends on influent wastewater quality, detention time in the biological system, amount
of aeration provided,  the acclimation of the biota, and the type of biological system
employed. Trickling filters, aerated lagoons, oxidation ponds, and activated sludge
systems are all used by one or more plants in the industry.

             The biological treatment systems in place in the industry vary from aerated
tanks with very short detention time and limited aeration capacity to sophisticated multi-
stage systems comprised of activated sludge followed by aerated lagoons and oxidation
ponds.  Most plants which use biological treatment do so as a pretreatment step prior to
discharge to a POTW or recycle of treated effluent.

             Evaporation

             Evaporation is a widely used technology for the minimization and
elimination of the discharge of process wastewater pollutants to the surface waters of the
United States. This technology has been selected by many wood preserving facilities in
order to meet the requirements of federal  and state regulations controlling the discharge
of process wastewater pollutants.

             Two types of evaporative technology are common in the wood preserving
industry. One is evaporation of wastewater in a cooling tower, and the other is thermal
evaporation.  Cooling tower evaporation is used primarily by Boulton process facilities.
In this system, the wood water vapor is drawn out of the  treating cylinder and passes
                                       VI-7

-------
through the shell side of a surface condenser. The wood water vapor is condensed by
cooling water passing through the tube side of the surface condenser. The condensed
wood water is sent to an accumulator and from there to an oil/water separator for
removal of oils.  The separated water fraction from the oil/water separator is added to
the cooling water, which recirculates through the tube side of the surface condenser
picking up heat, then through a forced draft cooling tower where evaporation occurs.
Rain water and cylinder drippings may also be routed to the oil/water separator and
subsequently added to the cooling water.

             Because the vacuum cycle in a Boulton facility lasts from 12 to 40 hours,
sufficient waste heat is usually available to evaporate all of the wastewater generated at
a facility without the addition of heat from an external source or the discharge  of
wastewater. Heat from an external source, usually process steam, may be added to assist
the evaporation of peak volumes of wastewater generated from time to time.

             In the steam conditioning process, total cycle time is much shorter, usually
less than 10 hours; the vacuum phase of the cycle is usually one to three hours.
Therefore, there is not a continuous (or nearly  continuous) source of waste heat
available to evaporate wastewater.  Generally, the  availability of heat for the evaporation
of process wastewater from steaming operations is not sufficient to eliminate the
discharge of process wastewater.

             The second method of evaporation is thermal evaporation using an
external heat source. As this method is particularly energy intensive and expensive, it is
not always a feasible method. Some facilities perform preliminary operations such as
sawing or debarking their wood before they preserve it. These processes generate waste
wood which may be burned and used as a heat source for evaporation.
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             In the past, some wood preserving facilities have reported storing or
 disposing of process wastewater in land-based units such as surface impoundments
 (Reference 2). However, application of wastewater to land may cause media transfer
 problems such as groundwater contamination.
 C.
APPLICABLE CONTROL AND TREATMENT TECHNOLOGIES
             This section discusses several control and treatment technologies which
 may be applicable to treat wood preserving wastewaters including membrane systems,
 adsorption, and chemical oxidants. These technologies have not yet been demonstrated
 in the wood preserving industry.  A model treatment system for a wood preserving
 facility would probably require a combination of these treatment steps based on site-
 specific factors to achieve complete control.

             Membrane Systems

             Membrane filtration is a term applied to a number of different processes
 or technologies capable of achieving different degrees of separation. For the removal of
 organic materials such as pentachlorophenol and creosote constituents, reverse osmosis
 (RO) or ultraffltration (UF) can be used. The basic difference between the two
processes is that  the RO membrane is capable of rejecting inorganic salts while the UF
membrane allows them to pass through.  Salt rejection occurs because of the repulsion of
the charged inorganic ions from the surface of the membrane and the adsorption of the
pure water to the membrane.  RO membranes are usually classified by their ability to
reject sodium chloride (NaCl). In general, the higher the NaCl rejection, the smaller the
pores in the membrane.

            For uncharged organic molecules, the mechanism of removal is a molecular
sieving action with  the rejection obtained related to the size and shape of the molecule.
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Various organic compounds will either be rejected or pass through, depending on the
pore size of the membrane.

             In order for membrane systems to be effective, the influent wastewater to
the membrane system must be relatively "clean" (low in suspended solids).  Because of
this requirement, membrane systems have had limited application in the past.

             Adsorption and Synthetic Adsorbents

             Polymeric adsorbents have been recommended for use under conditions
similar to those in which carbon adsorption is employed. Advantages of these materials
include efficient removal of both polar and nonpolar molecules from wastewater, and the
ability to tailor an adsorbent for a particular contaminant.  Clay minerals, such as
altapulgite clay, have also been recommended for use in removing certain organics and
heavy metals from wastewater. This technology also requires a fairly "clean" influent to
be efficient and cost effective.

              Chemical Oxidation

              The use of chlorine and hypochlorite as a treatment to oxidize phenol-
based chemicals in wastewater has been investigated in the past.  The continued use of
chlorine as an oxidizing agent for phenols is in question for various reasons. There  is a
concern over recent supply problems and the increasing cost of the chemical.
Additionally,  there is potential for the formation of chlorinated organics including
trihalomethanes and chlorinated dioxins and furans. For these reasons, attention is  now
being given to other oxidizing agents. Some of the other agents being researched are
hydrogen peroxide, ozone, and potassium permanganate.
                                       VMO

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                                       Table VM

                   Range of Average Raw Waste Concentrations
     Preliminary Characterization Study of the Wood Preserving Industry
                Pollutant
                Volatile Organics
                Semivolatile Organics
                Dioxins/Furans*
                Pesticides/Herbicides
                Metals**
                Conventionals
                             BOD
                             Oil and Grease
                             TSS
                Nonconventionals
                             COD
                             TOC
                                                      Concentration Range
   1 - 60 mg/1
  10 - 400 mg/1
   1 - 40 ug/1
   2 - 70 ug/1
  7-300 mg/1

 300 - 8,000 mg/1
  10 -  900 mg/1
 10 - 4,000 mg/1

800 - 40,000 mg/1
 100 - 6,000 mg/1
*Note that 2,3,7,8-TCDD was only detected in two samples of this study, and the concentration presented
here is a total concentration and is not in terms of 2,3,7,8-TCDD equivalents. OCDD and OCDF were the
predominant species found.

**Calcium and Sodium were not included in the Metals analysis.
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REFERENCES
1.     Micklewright, James T.  Wood Preservation Statistics, 1987, A Report to the Wood
      Preserving Industry in the United States, 1989.

2.   .  Background Document Supporting the Proposed Listing of Wastes from Wood
      Preservation and Surface Protection Processes.  EPA, 1988.

3.     Development Document for Effluent Limitations Guidelines and Standards for the
      Timber Products Point Source Category. EPA 440/1-81/023, 1981.

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