United States            Solid Waste and
                    Environmental Protection      Emergency Response          EPA/530-F-92-029
                    Agency                (OS-305)                 October 1992

                    Office of Solid Waste
&EPA        Environmental
                    Fact  Sheet
                     FINAL MODIFICATIONS TO THE
                     WOOD PRESERVING REGULATIONS
                     The Environmental Protection Agency (EPA) has promulgated a final rule
                     that modifies several components of the regulations established in 1990
                     for managing wastes generated in the wood preserving industry. EPA
                     initially proposed such modifications in the December 5. 1991 Federal
                     Register.
         Background

            On December 6, 1990, EPA published in the Federal Register a final
         rule listing three categories of wood  preserving wastes as
         "hazardous." The rule subjected the management of these wastes
         to regulation under the Resource Conservation and Recovery Act
         (RCRA) and established standards for  managing hazardous wastes
         on "drip pads," a containment and collection system commonly used
         in the wood preserving industry.

            Following promulgation of the December 1990 rule, EPA and
         industry representatives  together identified problems with
         implementing and interpreting the regulations.  As a result. EPA
         published a notice of proposed rulemaking in the Federal Register
         on December 5, 1991 to modify the wood preserving regulations, and
         requested public comment on the proposal.

         Action

            EPA has evaluated the comments received and is now making
         final a set of modifications to the wood preserving requirements, not
         unlike those proposed in 1991. The modifications amount to

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the establishment of more practical, less prescriptive drip pad
management and design standards.  The  modifications include:

  • narrowing the scope  of the wastewater listings to those
   wastewaters  that  come in contact with process contaminants,
  • eliminating the F032 designation for past users of chlorophenolic
   formulations if F034 or F035 wastes  are  currently being
   generated,
  • revising the drip pad cleaning requirements to require cleaning as
   needed to facilitate weekly inspections,
  • adding requirements that drip pad surface materials be chemically
   resistant and be maintained to prevent deterioration,
  • replacing the requirement that new drip pad coatings, sealers, and
   covers be "impermeable" with a choice between the use of a
   coating/sealer on the surface or the installation of a liner and leak
   detection system equipped with leak collection,
  • replacing the requirement that existing and new drip pads be
   "impermeable" with a requirement that they meet a numerical
   permeabiltiy standard, and
  • requiring the cleanup of storage yard "drippage" and contingency
   plans for such cleanup.

   EPA believes  these modifications will  not  diminish the
environmental protectiveness of the regulations.
Contact

   For further information, or to order a copy of the Federal
Register notice, please call the RCRA Hotline Monday through
Friday, 8:30 a.m. to 7:30 p.m., EST. The national toll-free number
is  (800) 424-9346; for the hearing impaired, it is (TDD)  (800)
553-7672.  In Washington, D.C., the number is (703) 920-9810 or
TDD(703)  486-3323.   Or write to: RCRA Information  Center, Office
of Solid Waste (OS-305), U.S. EPA 401 M Street,  S.W., Washington,
D.C. 20460.  Information  is also available from the Small Business
Ombudsman Hotline. The national toll-free number is (800)  305-5027.

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