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

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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.

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