United States Office of Solid Waste Environmental Protection and Emergency Response EPA/530-SW-91-008 Agency (OS-305) November 1990 Office of Solid Waste &EPA Environmental Fact Sheet WOOD PRESERVING WASTES LISTED AS HAZARDOUS The Environmental Protection Agency (EPA) has added three wastes generated by the wood preserving industry to EPA's list of hazardous wastes requiring regulation. This rule finalizes portions of a December 1988 proposed rule. Included are management standards for drip pads used in the collection of preservative drippage from treated wood. BACKGROUND The wood preserving industry treats wood to be used as railroad ties, utility poles, and dimensional outdoor lumber with chemical formulations to retard decay. These formulations commonly incorporate toxic materials such as pentachlorophenol, creosote, and inorganic (chromium and arsenical) preservatives. Similar chemicals are often used to surface treat freshly sawed wood to prevent sap stain formation. EPA published a proposed rule on December 30, 1988, to list as hazardous three waste categories from the wood preserving industry and one waste category from the wood surface treatment industry. The proposed rule and final rule fulfill, in part, a requirement under the 1984 Hazardous and Solid Waste Amendments to identify additional wastes as hazardous. ACTION EPA is listing as hazardous three categories of wastes from wood preserving processes that use chlorophenolic (FO32), creosote (F034), and/or inorganic arsenical and chromium (F035) preservatives. Each category includes process residuals, wastewaters, treated wood drippage, and spent preservative. The constituents of concern in these wastes typically occur at concentrations that pose a substantial threat to human health and the environment when the wastes are ------- mismanaged. EPA is deferring its final determination on listing wastes from wood surface treatment processes described in the proposed rule (F033) until more information on which to support a decision is collected. These wastes also will be designated as hazardous substances under the Comprehensive Environmental Response, Compensation, and Liability Act (CERCLA). A release of one pound or more will trigger the CERCLA reportable quantity requirements. This final rule establishes comprehensive management standards for existing and new "drip pads" that are used in the collection of preservative drippage in the process area of wood preserving facilities. The standards include requirements for drip pad design and operation, inspections, and closure of the unit, to ensure toxic chemicals are not released to streams or ground water. Most facilities with well-designed drip pads will be able to continue operation, with minor upgrades, for many years. Also, generators are required to hold the treated wood on drip pads until drippage has ceased. CONCLUSION Wood preserving chemicals can cause harm to human health and the environment when mismanaged. In ensuring the safer management of these wastes, EPA also gave careful consideration to the impact of this rulemaking on the wood preserving industry. The regulatory approach that the Agency eventually chose, following extensive deliberation, will minimize the cost and disruption to the industry, while ensuring that the environment is protected from risks posed by future wood preserving. 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) 553-7672. In Washington, D.C., the number is (202) 382-3000 or TDD (202) 475- 9652. Or write to: RCRA Information Center, Office of Solid Waste (OS- 305), U.S. EPA, 401 M Street, SW, Washington, D.C. 20460. ------- |