EPA/625/R-93/014
                                    November 1993
  GUIDES TO POLLUTION PREVENTION:
          Wood Preserving Industry
    RISK REDUCTION ENGINEERING LABORATORY
                     AND
CENTER FOR ENVIRONMENTAL RESEARCH INFORMATION
      OFFICE OF RESEARCH AND DEVELOPMENT
     U.S. ENVIRONMENTAL PROTECTION AGENCY
             CINCINNATI, OHIO 45268
                                      Printed on Recycled Paper

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                              NOTICE
    This guide has been subjected to U.S. Environmental Protection Agency
peer and administrative review, and approved for publication.  Approval does
not signify that the contents necessarily reflect the views and policies of the
U.S. Environmental Protection Agency, nor does mention of trade names,
commercial products, or processes constitute endorsement or recommendation
for use.

    This document is intended as advisory guidance only to the wood preserv-
ing industry in developing approaches for pollution prevention.  Compliance
with environmental and occupational safety and health laws is the responsibil-
ity of each individual business and is not the focus of this document.

    Worksheets are provided for conducting waste minimization assessments
of wood preserving plants.  Users are encouraged to duplicate portions of this
publication as needed to implement a waste minimization program.
                                   11

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                           FOREWORD
    This guide provides an overview of the wood preserving industry and pre-
sents  options for minimizing waste generation  through  source^ reduction and
recycling.  Treatment with both oilborne and waterborne preservatives is dis-
cussed in this guide.  However, because, in the United States, the majority of
wood is treated with chromated copper  arsenate, the guide focuses on water-
borne preservatives.

    Process wastewater, surface runoff water, and sludge are possible sources
of contamination in the wood preserving industry, although hi waterborne pro-
cesses the  majority  of wastewater is reused.  Process  wastewater  includes
water from conditioning, kiln drying, treated wood washing, accumulations in
doors or retort sumps, preservative formulation recovery, and rinsing. Surface'
runoff water flows from nonprocess areas, such  as treated wood storage yards.
Sludge consists of  oil-water emulsions,  water/debris  mixtures, and wood
debris.   Reducing  the amount of mis waste will benefit both the wood
preserving  industry and the environment.

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                  ACKNOWLEDGMENTS
    This guide is based in part on waste minimization assessments (Waste
Minimization Practices  at Two CCA Wood-Treatment Plants) conducted by
Battelle for the  U.S. Environmental Protection Agency (EPA).   Battelle
expanded  the CCA waste minimization  report under subcontract to EPA
(USEPA Contract 68-CO-0003) to produce this guide. Battelle personnel con-
tributing to the guide include Bob Olfenbuttel, work assignment manager;
Leslie  Hughes,  task leader;  Abraham Chen,  technical  engineer; and Bea
Weaver, production editor.

    Paul Randall of the U.S. Environmental Protection  Agency, Office  of
Research and Development, Risk Reduction Engineering Laboratory,  was the
project officer responsible for the preparation and review of this guide.  Other
contributors and reviewers include
Darrell D. Nicholas
Associate Director
Mississippi Forest Products
  Laboratory
P.O. Drawer FP
Mississippi State, MS 39762-5724

Susan L. LeVan
Assistant Director, PMR
Forest Products Laboratory
USDA Forest Service
One Gifford Pinchot Drive
Madison, WI 53705-2398
Tom Kyzer
Manager, Environmental Services
Chemical Specialties, Inc.
One Woodlawn Green, Suite 250
Charlotte, NC  28217

William J. Baldwin, Vice President
Technical and Environmental
 Services and
Jeff Meadows, Manager
Environmental Health
 and Safety
Hickson Corporation
3941 Bonsai Road
Conley, GA 30027
                                 . iv

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                                          CONTENTS
Section

Notice  .	

Foreword  	

Acknowledgments	

1.   Introduction	

     Overview of Waste Minimization  	'.	
     Facility Planning for Pollution Prevention .	,. .

             Planning and Organization Phase	
             Assessment Phase	
             Feasibility Analysis Phase  	
             Implementation Phase	

     References	

2.   Profile of the Wood Preserving Industry	

     Industry Description	
     Process Description	

             Pressure Treating Processes	
             Non-Pressure Treating Processes	

     Waste Description	
     References	

3.   Waste Minimization Options for the Wood Preserving  Industry

     Introduction  	,	
     Recycling and Source Reduction Options	

             Treatment Plant Design  	
             Treatment Practices	
             Recycling Practices	
             Housekeeping Practices  	
             Training Practices  	
             Storage and Handling Practices'	
             Disposal Practices	
             Preservative/Process Alternatives	
Page
 111
 IV
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  8

  8
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 11
 11

 11
 12
 13
 13
 14
 14
 14
 14

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                                      CONTENTS
                                         (Continued)
Section
     Economic Considerations
     References  	
4,    Waste Minimization Assessment Worksheets
APPENDIX A:
     Wood Preserving Industry Field Assessments:  Case Studies
APPENDIX B:
     Where to Get Help:  Further Information on Pollution Prevention
Page

 15
 15

 17
 31
 39
                                            VI

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                                          SECTION 1
                                      INTRODUCTION
   This  guide  is designed to provide the wood pre-
serving industry with waste minimization options.  It
also provides worksheets for carrying out waste mini-
mization assessments.  The guide is intended for use
by  the   wood preserving  industry  and  regulatory
agency   representatives,   industry   suppliers,   and
consultants.

   In  the following sections of this manual you will
find:

   •   A profile of the wood preserving industry and
      the processes used in it (Section 2)

   •   Waste minimization  options  for  the  industry
      (Section  3)

   •   Waste   minimization  assessment  worksheets
      (Section  4)

   •   Appendices, containing

      — Case studies of waste generation and waste
         minimization practices of three facilities

      — Where to get help: sources of useful techni-
         cal and regulatory information

   The  worksheets are the result  of  updating and
expanding  a  CCA waste minimization  study  by
Battelle (Chen and Olfenbuttel  1993).  Waste genera-
tion and management  practices were  surveyed, and
potential waste minimization options were identified.

Overview of Waste Minimization

   Waste minimization is a policy specifically man-
dated by the  U.S. Congress in the 1984 Hazardous
and  Solid  Waste Amendments  to  the  Resource
Conservation  and Recovery Act (RCRA).   As  the
federal  agency  responsible  for  writing  regulations
under  RCRA,  the U.S.  Environmental  Protection
Agency (EPA) has an interest in ensuring that new
methods and approaches are developed for minimizing
hazardous  waste and that  such information is made
available to the industries concerned.  This guide is
one of the approaches EPA is using to provide indus-
try-specific information about hazardous waste mini-
mization.   The options and procedures  outlined can
also  be  used in efforts  to  minimize other  wastes
generated in a business.

   In the working definition used by EPA, waste min-
imization consists of source reduction and recycling.
Of the  two approaches,  source  reduction is usually
considered preferable to recycling.  While a few states
consider treatment of waste an approach to waste min-
imization, EPA does  not; and thus treatment is not
addressed in this guide.

Facility Planning for
Pollution Prevention

   With the  Pollution Prevention  Act of 1990, the
U.S. Congress  established  pollution prevention as a
"national objective."  To encourage the adoption of
pollution prevention measures in industry, EPA pub-
lished   the  Facility  Pollution  Prevention    Guide
(USEPA 1992) as a successor to the Waste Minimiza-
tion  Opportunity Assessment Manual (USEPA  1988),
which  was a general manual for waste minimization.
The   Waste  Minimization  Opportunity Assessment
Manual explained how to conduct waste minimization
assessments, and develop  options for  reducing  the
amount of hazardous waste generated at a facility.

   The Facility Pollution Prevention  Guide expands
the  scope  of  the  Waste  Minimization  Opportunity
Assessment  (WMOA) Manual to  emphasize  "multi-
media" pollution prevention.  It  explains the manage-
ment  strategies  needed  to  incorporate  pollution
prevention into company  policies and how to establish
a company-wide pollution prevention program,  con-
duct assessments,  implement options, and  make the
program an ongoing one.  It is intended to help small-
to medium-sized production facilities  develop broad-
based,  multimedia  pollution prevention programs.
Methods of evaluating, adjusting, and  maintaining the
program are described.  Later chapters deal with cost

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analysis for pollution prevention projects and with the
roles of product design and energy  conservation in
pollution prevention.  Appendices consist of materials
that will support the pollution  prevention effort such
as  assessment worksheets  and sources of additional
information.

   The method  described in the WMOA Manual is
generally  the  same  as  the  method for  carrying out
facility pollution prevention planning.  It is a systema-
tic  procedure for identifying ways to reduce or elimi-
nate waste.  The four phases of a waste minimization
opportunity  assessment are planning and organization,
assessment,  feasibility  analysis, and  implementation.
The steps involved in  conducting a waste  minimiza-
tion assessment are outlined in Figure  1 and presented
in more detail below. Briefly, the assessment consists
of a careful  review of a facility's operations and waste
streams and selection  of specific areas  to  assess.
After a particular waste stream or area is established
as  the WMOA focus,  a number of options with the
potential  to  minimize  waste  are  developed  and
screened.  The technical and economic feasibility of
the selection options are then evaluated. Finally, the
most   promising  options    are    selected   for
implementation.

PLANNING AND ORGANIZATION PHASE

  Essential elements of planning and  organization for
a waste minimization program are getting management
commitment for the program, setting waste minimiza-
tion goals, and organizing an assessment program task
force.

ASSESSMENT  PHASE

  The assessment phase involves a number of steps:

  •  Collect process and facility data
  •  Prioritize and select assessment targets
  •  Select assessment team

  •  Review data and inspect site
  •  Generate options

  •  Screen and select options  for feasibility study.
Collect Process and Facility Data

   The waste streams at a facility should be identified
and  characterized.  Information about waste streams
may  be  available on hazardous  waste  manifests,
National  Pollutant  Discharge  Elimination  System
(NPDES) reports, routine  sampling  programs,  and
other sources.

   Developing a basic understanding of the processes
that  generate waste  at a facility is essential to the
WMOA  process.   Flow diagrams should be prepared
to identify the quantity, types, and rates  of waste gen-
erating processes.  Also, preparing material balances
for the different processes can be useful  in  tracking
various process components and identifying losses or
emissions  that  may  have  been  unaccounted  for
previously.

Prioritize and Select Assessment Targets

   Ideally, all waste  streams in a facility  should be
evaluated for potential waste minimization  opportuni-
ties.    With limited  resources, however, the facility
manager may need to concentrate waste minimization
efforts in a specific  area.   Such  considerations as
quantity  of waste, hazardous properties  of  the waste,
regulations, safety of employees, economics, and other
characteristics need to be evaluated in selecting target
streams or operations.

Select Assessment Team

   The team should include people with direct respon-
sibility for and knowledge  of the particular  waste
stream or area of the facility being addressed. Equip-
ment operators  and people involved in routine  waste
management should not be ignored.

Review Data and Inspect Site

   The assessment team  evaluates process  data in
advance of the inspection.  The inspection should fol-
low the target process from the point where raw mate-
rials  enter to  the point  where products and  wastes
leave.  The team should identify the suspected sources
of waste.  This may  include the  production process,
maintenance,  operations,  and  storage  areas.   The

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 The Recognized Need to Minimize Waste
    PLANNING AND ORGANIZATION

 • Get management commitment
 9 Set overall assessment program goals
 • Organize assessment program task force
       Assessment Organization &
         Commitment to Proceed
            ASSESSMENT
• Collect process and facility data
• Prioritize and select assessment targets
• Select people for assessment teams
• Review data and inspect site
• Generate options
• Screen and select options for further study
Select New Assessment
Targets and Reevaluate
   Previous Options
          Assessment Report of
            Selected Options
        FEASIBILITY ANALYSIS

    • Technical evaluation
    • Economic evaluation
    • Select options for implementation
         Final Report, Including
         Recommended Options
        	t	
           IMPLEMENTATION

     1 Justify projects and obtain funding
     1 Installation (equipment)
     1 Implementation (procedure)
     • Evaluate performance
Repeat the
 Process
        Successfully Implemented
       Waste Minimization Projects
Figure 1.  Waste Minimization Assessment Procedure

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inspection may result in the formation of preliminary
conclusions  about waste  minimization  opportunities.
Full confirmation  of these  conclusions may require
additional data collection, analysis, and/or site visits.

Generate Options

   The objective of this step is to generate a compre-
hensive set of waste minimization options for further
consideration. Since technical and economic concerns
will be  considered in  the later  feasibility  step,  no
options are ruled out at this time.  Information from
the site inspection, as well as  trade associations, gov-
ernment  agencies,  technical  and trade reports,  equip-
ment vendors, consultants, and plant  engineers and
operators may serve  as sources  of ideas for waste
minimization options.

   Both source reduction and recycling options should
be  considered.   Source  reduction may be accom-
plished through good operating practices, technology
changes, input material changes, and product changes.
Recycling includes  use  and reuse of water,  solvents,
rinsates,   and  other  recyclable   materials,  where
appropriate.

Screen and Select Options for Further Study

   This screening  process is  intended  to select  the
most promising options for a  full technical  and eco-
nomic  feasibility study.  Through either an informal
review  or a quantitative decision-making  process,
options that appear marginal,  impractical, or inferior
are eliminated from consideration.

FEASIBILITY ANALYSIS PHASE

   An option must be shown to be technically and eco-
nomically feasible to merit  serious consideration  for
adoption  at   a  facility.    A technical  evaluation
determines whether a proposed option will work in a
specific  application.   Both process  and equipment
changes need to be assessed for their  overall effects
on waste quantity and product quality.  A major con-
cern is  the impact of any proposed changes on  the
product license.  Minor changes may be implemented
rather easily, but major changes may require review
and  approval of  the revised process.   The  time
required  for  this activity may make  some options
impossible.
   An economic  evaluation is carried out using stan-
 dard measures of profitability, such as payback period,
 return on investment,  and net  present value.   As in
 any project, the cost elements of a waste minimization
 project can be broken down into capital costs  and
 operating costs.   Savings  and changes in revenue and
 waste disposal costs also need to be considered, as do
 present  and future cost  avoidances.   In  cases of
 increasingly   stringent   government   requirements,
 actions that may  increase the cost of production may
 be necessary.

 IMPLEMENTATION PHASE

   An option that passes both technical and economic
 feasibility reviews should be implemented. The proj-
 ect  can  be  turned  over to the appropriate group  for
 execution while the WMOA team, with management
 support, continues the  process of tracking wastes and
 identifying other opportunities for waste minimization.
 Periodic reassessments may be conducted to see if the
 anticipated waste regulations were achieved.  Data can
 be tracked and reported for each implemented idea in
 terms  such  as pounds of waste per production unit.
 Either  initial investigations of waste  minimization
 opportunities or the reassessments can be conducted
 using the worksheets in this manual.

 References

Chen,  Abraham  S. C. and Robert  F.   Olfenbuttel.
   1993.  Waste Minimization Practices at Two CCA
   Wood-Treatment Plants.   Report to U.S. Environ-
   mental Protection Agency, Risk Reduction Engi-
   neering  Laboratory,   Office   of  Research   and
   Development, Cincinnati, OH.

USEPA.   1992.  Facility  Pollution 'Prevention Guide.
   EPA/600/R-92/088,  U.S. Environmental Protection
   Agency,  Office  of Research  and Development,
   Washington, DC.

USEPA.    1988.    Waste Minimization   Opportunity
   Assessment  Manual     EPA/625/7-88/003,  U.S.
   Environmental   Protection  Agency,   Hazardous
   Waste   Engineering   Research   Laboratory,
   Cincinnati, OH.

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                                           SECTION 2
             PROFILE OF THE WOOD PRESERVING INDUSTRY
Industry Description

   The wood preserving industry in the United States
is over a hundred years old.   Preserved wood is used
primarily  in  the  construction, railroad,  and  utilities
industries to prevent rotting when wood is exposed to
damp soil, standing water,  or rain and as protection
against termites and marine borers.  While wood may
be  treated with either  oilborne or waterborne pre-
servatives, over the years the industry has turned more
and more to waterborne  preservatives.    In 1988,
23 percent of the wood treated  in the United States
was treated with oilborne preservatives.  The volume
of  wood  treated  with waterborne  preservatives was
75 percent.   Table 1 shows the  volume  of wood
treated in: 1988 by product and  type of preservative.
Approximately 600 million cubic  feet of wood are
treated with  wood  preservatives and fire retardants
each year (USEPA 1992).

Process Description

   Historically, the wood-preserving industry has used
three major preservative systems: creosote, pentachlo-
rophenol (PCP), and waterborne  inorganics.   Creosote
and pentachlorophenol are the major oilborne preser-
vatives used in the industry.  These organic preserva-
tives are  used primarily for older processes,  such as
for  treating  crossties, crossarms,  and utility poles.
The most commonly used inorganic (waterborne) pre-
servatives  are chromated copper arsenate (CCA) and
ammoniacal copper-zinc-arsenate (ACZA).

    Creosote is an oily, translucent,  brown  to black
liquid.  It is applied  either at full  strength  or diluted
with petroleum oil or coal tar.  Creosote is denser
than water and is produced from the high temperature
carbonization of bituminous coal. It contains approxi-
mately 85 percent polynuclear aromatic hydrocarbons
(PAHs),  10 percent phenolic compounds, and 5 per-
cent   nitrogen-,   sulfur-,   or   oxygen-containing
heterocycles.
   Technical grade PCP contains

   •  PCP (85 to 90 percent)
   •  2,3,4,6-tetrachlorophenol (4 to 8 percent)
   •  higher chlorophenols (2 to 6 percent)
   •  dioxins and furans (0.1 percent).

   CCA and ACZA derive, in part, from arsenic acid,
copper oxide, and chromic acid.  Table 2 shows the
standardized formulations  of CCA  and ACZA and the
ranges  in proportion of the chemical compounds they
contain.

   Creosote was first used in the 1870s  to treat cross-
ties  with  a  full-cell  treatment process,  which was
developed in 1838.  The  first waterborne preservative
(acid copper  chromate) was used  in  1929,  and soon
afterward  a new oilborne  preservative (pentachloro-
phenol) was  introduced in  1931.  Before the end of
the decade, two more waterborne  preservatives (CCA
and  ammoniacal copper  arsenate) were  developed
(Barnes and Nicholas 1992).

   The majority of wood  treated with waterborne pre-
servatives is  treated with CCA.   CCA is  shipped to
treating plants  as  a  50  or  60 percent  concentrate,
which  is  stored in a  concentrate storage  tank and,
when needed, is diluted with water in a work tank to
1 to 2 percent.

   Wood  can be preserved with  creosote,  PCP, and
waterborne   preservatives  using   pressure  treating
processes.   Non-pressure  treating  processes can also
be used for  some preservatives but  are not used to
treat wood with CCA.  Standard  treatment specifica-
tions for various commodities  and wood products are
found in the American Wood Preservers' Association
Standards (1992).

PRESSURE TREATING PROCESSES

   Treatment in a pressure cylinder (Figure 2) is the
preferred  commercial approach for preserving wood.
Pressure treating processes include full-cell or modi-
fied full-cell processes and  the  empty-cell process.

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                            Table 1.  Production of Treated Wood in the United States, 1988a
                                                Volume of Wood Treated (1,000 cu ft)
                                                    Creosote   Pentachloro-    Waterborne      Fire
                                  Products        solutions'1     phenol      preservatives0   retardants
Crossties
Switch and bridge ties
Poles
Crossarms
Piling
Fence posts
Lumber
Timbers
Plywood
Other products
Total products
1988
Total products
1987*
56,990
6,315
14,675
122
3,734
1,242
3,113
2,850
—
1,441
90,482
97,822
780
—
41,778
1,229
108
1,356
1,251
1,283
17
68
47,870
48,557
—
—
14,738
122
5,859
9,805
350,220
40,884
8,732
20,206
450,566
418,984
—
—
—
—
—
—
5,283
—
3,956
991
10,230
10,618
                            aEstimate based on reported production of 476 treating plants plus estimated produc-
                             tion of 100 nonreporting plants.  1987 production data added for comparison.
                            bCreosote, creosote-coal tar, and creosote-petroleum.
                            ฐCCA, ACZA, ACC. and CZC.
                            ''Wood Preservation Statistics, 1987.
                            Source: USEPA 1992.
              The full-cell process is used to obtain maximum, reten-
              tion of preservative.  The empty-cell process  is used
              to obtain deep penetration,  with relatively low reten-
              tion of  preservative.   Waterborne  preservatives are
              generally applied by the full-cell or  modified full-cell
              processes.  For treatment with  oilborne preservatives,
              the empty-cell process is used whenever possible.

                 In the full-cell (Bethel)  pressure treating process,
              an  initial vacuum is  applied to remove air from the
              cylinder and the  wood cells.   Preservative  is then
              transferred  to  the cylinder through  piping from the
              preservative work tank  without breaking the vacuum.
              Hydrostatic or  pneumatic pressure  is applied until the
              preservative permeates  the wood or until the  desired
              retention  is obtained.   The excess preservative is
returned to the work tank for reuse.  Preservative tem-
peratures during the pressure  period  usually do not
exceed the  temperatures specified below:
   Oilborne Preservatives
   Waterborne Preservatives
      ACZA
      CCA
200-210ฐF

    150ฐF
  Ambient
A final vacuum  may  be applied to remove  excess
preservative.  The treated wood is removed from the
cylinder and  placed  on a drip  pad where it remains
until dripping has ceased.  For waterborne preserva-
tives, all solution dripping onto the pad,  as well  as
washdown  water, flows to a collection sump.  It is
then transferred to a dilution water tank. The dilution
_

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                        Table 2. CCA and ACZA Formulations
Preservative
CCA
Type A
Standard
Range
Type B
Standard
Range
Type C
Standard
Range
ACZA
Standard
Range

Chromium (VI) as
Cr03


65.5
59.4-69.3

35.3
33.0-38.0

47.5
44.5-50.5


Compound (%)
Copper as Zinc as
CuO ZnO


18.1
16.0-20.9

19.6
18.0-22.0

18.5
17.0-21.0

50.0 25.0
45.0-55.0 22.5-27.5

Arsenic as
As205


16.4
14.7-19.7

45.1
42.0-48.0

34.0
30.0-38.0

25.0
22.5-27.5
   Source: American Wood Preservers' Association 1992
                          •vent             high pressure
                                  vacuum  PumP
                                                        vent
vent
freshly treated
wood storage
                process
                water
                                                                paved contain-
                                                                ment area
   Source: USEPA 1992

       Figure 2.  Waterborne Wood Preservative Pressure-Treating Facility

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 water is blended with additional concentrate to make
 fresh treating solution.

   The  modified full-cell process differs from the full-
 cell process in that lower levels of initial vacuum are
 used.  The amount of vacuum is determined by the
 wood treated and the final retention desired.

   Two empty-cell  processes are commonly used.  In
 the Rueping empty-cell process, air under pressure is
 forced into the treating cylinder.  Air penetrates the
 wood before preservative is transferred to the cylinder.
 Pressure is raised until the desired amount of preser-
 vative has  been  absorbed.   Surplus preservative is
 removed from the  wood  with a final vacuum.  The
 process is the same in the Lowry  empty-cell, process,
 except  no  initial pressure is applied.  In both pro-
 cesses,  air  compressed in  wood drives out part of the
 preservative absorbed during the pressure period when
 pressure is released (USDA 1987).

   Prior to treatment,  wood is usually seasoned in the
 open air or conditioned  in the cylinder.   Wood is
 sometimes  incised to increase preservative penetration.
 Open air drying  is used to  prepare  large  stock  (i.e.,
 cross ties,  poles) for treatment with organic (oilborne)
 preservatives.  KUn drying is used primarily for water-
 borne treatment.  Steaming, heating, and vapor drying
 are methods for conditioning wood prior to treatment
 with oilborne preservatives (USDA 1987).

 NON-PRESSURE TREATING PROCESSES

   Non-pressure treating  processes  include thermal;
 cold soak; and brush, dip, and spray  methods.  In the
 thermal process, wood is immersed in hot preservative
 (such as creosote or PCP) for several hours, followed
 by soaking at ambient temperature.  In cold soaking,
 wood is immersed in  a preservative (e.g., PCP) solu-
 tion at  ambient temperature.  In the  brush, dip, and
 spray methods, liquid preservative oil is  applied  to
 wood surfaces (USEPA 1992).

Waste Description

   Figure 3 and  Table 3 show possible  sources of
pollution from oilborne and  waterborne preservative
treatment processes, respectively.   Waste  generated
includes  process  wastewater,  surface runoff  water,
and/or sludges.
   Process wastewater includes wastewater from con-
 ditioning (retort condensate), kiln drying, treated wood
 washing, accumulations in doors or retort sumps, pre-
 servative formulation recovery, and rinsing.  Surface
 runoff water flows  from non-process  areas  such  as
 treated wood storage yards. Plants treating wood with
 oilborne preservatives  produce large quantities  of
 wastewater, including process water and  surface run-
 off water.  Waterborne processes produce little or  no
 process wastewater because drips,  rainwater collected
 in process areas, and water used to clean drip pads are
 directed to a sump and reused to make fresh working
 solution.  As a result, no contaminated water is dis-
 charged as hazardous waste.

   Sludges  produced by wood-treating  plants  con-
 sist of oil-water emulsions or polymers,  bark,  saw-
 dust, dirt, wood chips, and debris.   The sludges, dirt,
 and  solid  waste  collected from  the  drip  pads, rail
 trench,  cylinder door pits, and screens to the floor
 sumps are drummed for disposal at a hazardous land-
 fill.    However,  landfill disposal  is  becoming  an
 environmental issue, and restrictions may  soon pre-
 clude this disposal option (Barnes and Nicholas 1992).
References

American  Wood  Preservers'  Association.
   Standards.  Woodstock, MD.
1992.
Barnes, H. M. and D. D. Nicholas.  1992. "Alternative
   Preservative Systems: Pros & Cons."  Arsenic and
   Mercury  Workshop on  Removal, Recovery, Treat-
   ment,  and  Disposal.   EPA/600/R-92/105,  U.  S.
   Environmental Protection Agency, Risk Reduction
   Engineering Laboratory,  Office of  Research and
   Development, Cincinnati, OH, and Waste  Manage-
   ment Division,  Office  of Solid Waste and Emer-
   gency Response, Washington, DC.

USDA. 1987.  "Wood Handbook:  Wood as  an Engi-
   neering Material."   Agriculture  Handbook  Vol-
   ume 72.  U.S.  Department of  Agriculture,  Forest
   Products  Laboratory,  Forest  Service, Washington,
   D.C.

USEPA.   1992.  Contaminants and Remedial Options
   at Wood  Preserving  Sites.    EPA/600/R-92/182,
   U. S.   Environmental   Protection  Agency,  Risk
   Reduction  Engineering  Laboratory,  Office  of
   Research  and Development, Cincinnati, OH.

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                        POP Solids
                      (Blocks or Bags)
Carrier Oil
  (Bulk)
                                  Chemical Delivery
                               (Pallets-
                              Rail/Truck)
           oil spills, drips
  (Bulk
 tankers)
                             Chemical Storage & Mixing
                                   (Tankage/CHI)
 Oil Solution
  (Tankage)
                                  Solution Storage
                                     (Tankage)
  Oil/water
  Separator
                                 Pressure Treatment
                                  (Retort Cylinder)
             Wastewater
              treatment
                                   Freshly-treated
                                   Wood Storage
      precipitation: oil spills, drips
                                    Dry-treated
                                   Wood Storage
                                     (Ground)
Source:  Robert S. Kerr Environmental Research Laboratory
        Ada, Oklahoma
                                                              POTENTIAL CHEMICAL
                                                                   RELEASES
DRIPS, SPILLS.....to ground
                 •  AEROSOLS, VAPORS	to air

                 •  SPILLS	to ground
                 •  AEROSOLS, VAPORS	to air




                 •  SLUDQES.....to disposal



                 o  AEROSOLS, VAPORS.....to air
                 •  CONDENSER COOLING WATER	
                               to sewer

                 •  TREATED EFFLUENT.....to sewer
                 .  SLUDGES
                 •  SPENT CARBON	to regeneration

                 •  VAPORS	to air

                 •  CONCENTRATED LIQUID.....to reuse



                 ป  SLUDGES	to disposal
                                                            •  DRIPS.....to ground
                                                            •  TRACKING.....IO ground
                                                            •  DUST.....to air
                  •  DRIPS.....to ground
                  •  DUST-^.to air
Figure 3.   Possible Sources of Pollution from Oflborne Preservative
              Treatment Processes

-------

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-------
   Cincinnati  OH, and Waste Management Division,
   Office of Solid Waste and Emergency Response,
   Washington, DC.

Kitsch, F. William and J. Clifford Maginn, Jr.  1992.
   Waste Minimization Assessment for a Manufacturer
   Producing  Treated Wood Products.  U.S. Environ-
   mental Protection  Agency, Risk Reduction Engi-
   neering Laboratory, Office of Research and Devel-
   opment, Cincinnati, OH.

Midgette, Robert  W. and Kevin R.  Boyer.   1992.
   "Wood Preserving Industry Treated to New RCRA
   Requirements." The National Environmental Jour-
   nal. November/December, p. 21.

USEPA.  1993.  Quality Assurance Project Plan for
   Evaluating ACQ as an Alternative Wood Preserva-
   tive to CCA.  Prepared  by Battelle for the U.S.
   Environmental Protection Agency.
                                                 16

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                                          SECTION 4
           WASTE MINIMIZATION ASSESSMENT WORKSHEETS
   The  worksheets  provided  in  this  section  are
intended  to  assist the wood  preserving industry in
systematically evaluating waste generating processes
and in identifying waste minimization opportunities.
These worksheets include only the assessment phase
of the procedure described in the EPA Waste Minimi-
zation Opportunity Assessment Manual and the EPA
Facility  Pollution Prevention  Guide..  A comprehen-
sive waste minimization assessment includes planning
and organization, gathering background information, a
feasibility   study  on  specific  waste  minimization
options, and  an implementation phase.  For  a full
description  of waste minimization assessment  proce-
dures, refer to the Facility Pollution Prevention  Guide.
   Table 4  lists  the worksheets  that are provided in
this  section.   After completing the worksheets, the
assessment  team should evaluate the applicable waste
minimization  options and develop an  implementation
plan.
                Table 4. List of Waste Minimization Assessment Worksheets
  Number                     Title
     1.      Waste Sources
     2.      Waste Minimization: Treatment Plant Design

     3.      Option Generation: Treatment Plant Design
     4.      Waste Minimization: Treatment Practices

     5.      Option Generation: Treatment Practices
     6.      Waste Minimization: Housekeeping Practices
     7.      Option Generation: Housekeeping Practices
     8.      Waste Minimization: Storage and Disposal
             Practices
     9.      Option Generation: Storage and Disposal
             Practices
                    Description
   Form for listing potential sources of waste
   Questionnaire on design of overall treatment
    facility
   Options for improving plant design
   Questionnaire on pretreatment, treatment, and
    posttreatment of wood
   Options for minimizing treatment waste
   Questionnaire on housekeeping practices
   Options for housekeeping improvements
   Questionnaire on storing and disposing wood
    preservatives
   Options for storing and disposing preservatives
                                                 17

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Plant
Date

WORKSHEET
1A
Waste Minimization Assessment Prepared by
Chec
Proi. No. Shee


WASTE SOURCES

Waste Source: Plant Design
Poorly Designed Treatment Buildings
Inadequate Drip Pads
Inadequate Containment
Inadequate Floor Sumps/Pits
Inefficient Lumber Handling System
Decentralized Storage of Concentrate and Working Solution
Inefficient/Inadequate Preservative Mixing System
Inadequate Spill Monitoring
Improperly Unloading Perservative Concentrates
Unloading Preservative Concentrate in Uncontrolled Areas
Other


Waste Source: Treatment
Inadequate Quality Control Practices
Damaged or Failed Lumber
Wood that Is not Properly Conditioned
Treatment Practices that Permit Excessive Dripping
Inadequately Monitoring Treatment Process
Other


Waste Source:
Housekeeping
Leaks, Spills, and Drips
Dirt and Sludge
Wood Chips and Debris
Runoff Water
Dirty Floors and Drip Pads
Careless Lumber Handling
Other



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Plant Waste Minimization As^smAnt Prepared by
Checked bv
Date Proj. No. Sheet

WORKSHEET WASTE SOURCES
"| B (Continued)

Waste Source: Storage and Disposal
Poorly Designed Storage Facilities
Ineffective Containment Measures
Defective Waste Drums
Improper Storage and Mixing Practices
Inadequate Inventory Control
Lack of Containment in Storage Areas
Other :













'

[


.







of Paqe of
•
Significance
Low

































Medium





























t



High


































19

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Plant
Date
                                   Waste Minimization Assessment
Proj. No.
Prepared by _
Checked by _
Sheet	of
.Page.
of
  WORKSHEET
     2A
WASTE MINIMIZATION:
Treatment Plant Design
A. Treatment Building
   Are treatment facilities enclosed?
   What kind of floors are in the treatment area?
                                                 D Yes   D No
   What type of containment is provided?_
   Does the containment have a total capacity equivalent to 150 percent of the volume of the
   largest chemical tank?
   Do treatment facilities have a spill monitoring system?
B. Drip Pads
   Are elevated drip pans used?
   Do drip pads have liners and/or surface coatings?
   Are drip pads cracked or deteriorated?
   Are areas adjacent to drip pads paved?
   Are chemicals tracked from the drip pad to surrounding areas?
   Is there a dedicated forklift on drip pads?
C. Lumber Handling
   How is wood moved into and out of treatment cylinders?
     Automatic conveying system   D
     Forklift                     D
     Rail and tram                Q
                                                 QYes
                                                 DYes

                                                 DYes
                                                 DYes
                                                 QYes
                                                 DYes
                                                 QYes
                                                 QYes
                           DNo
                           DNo

                           DNo
                           QNo
                           DNo
                           DNo
                           QNo
                           DNo
                                               20

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Plant
Date
 Waste Minimization Assessment
Proj. No.
Prepared by _
Checked by _
Sheet     of
.Page.
                                                                                           of
  WORKSHEET
     2B
WASTE MINIMIZATION:
Treatment Plant Design
D. Preservative Mixing and Storage
   Are preservative concentrate and working solutions stored in a centralized area?             ,D Yes   D No
   Do mixing and storage areas have adequate containment?                .                D Yes   Q No
   Is preservative concentrate unloaded at a confined area with proper unloading devices?        D Yes   D No
   How are preservatives mixed?	'.	
   Would computer-controlled mixing systems reduce the amount of
   time workers need to be in the chemical storage area?
   Are workers properly trained to handle hazardous materials?
E. Ventilating
   How is the plant ventilated?	
                                                  DYes
                                                  DYes
                           DNo
                           QNo
   Is the plant designed to minimize emissions?
   Are concentrate tanks, work tanks, and mixing tanks ventilated?
                                                  DYes
                                                  DYes
                           QNo
                           QNo
                                                21

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Plan* Waste Minimisation As
Date Pro). No.
sessment
(
Drepared by
Checked by
Sheet of Page of

WORKSHEET OPTION GENERATION:
3 Treatment Plant Design

Meeting Format (e.g., brainstorming, nominal group technique)
Meeting Coordinator •
Meeting Participants

Suggested Waste Minimization Options
A. Treatment Buildings
Enclose Treatment Buildings
Coat Concrete Floors with Impermeable Surface
Provide Sufficient Primary and Secondary Containment
Design Facilities so that Leaks and Spills are
Immediately Evident
B. Drip Pads
Use Elevated Drip Pads
Line Drip Pads
Curb and Slope Drip Pad Area
Pave Areas Adjacent to Drip Pads
Use Stationary Forkl'rfts at Drip Pads
Seal, Coat, or Cover Drip Pads
Add Leakage and Detection System
C. Lumber Handling
Use Automatic Lumber Handling System
Use Dedicated Forkl'rfts at Drip Pads
D. Preservative Mixing and Storage
Store Chemicals in a Centralized Area
Use Enclosed, Computer-Controlled Mixing Systems
Provide Containment Equivalent to 150 Percent of
Total Volume of the Largest Task
Provide Training Programs for Workers
E. Air Exchange/Venting
Use Air Exchange Systems
Vent Cylinders and Tanks
Currently
Done Y/N?
























Rationale/Remarks on Option
























22

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Plant Waste Minimi7a1
Date , Proj. No.

A.
B.

WORKSHEET WASTE Mi IS
4A Treatment

BEFORE TREATMENT
Is wood covered during shipment?
Is untreated wood inspected?
Where is wood stored prior to treatment?

Is wood for poles cleaned prior to treatment?
Is wood seasoned or conditioned prior to treatment?
If so, how?

DURING TREATMENT
What preservatives are used in the treatment process?
Describe the treatment process used.



ion Assessment Prepared by
Checked by
Sheet of Page of

IIM1ZATION:
Practices

D Yes D No
DYes QNo

QYes QNo
D Yes D No







Are strip pumps used to return residual chemical solution to work tanks? D Yes D No
Is chemical retention monitored for proper treatment? D Yes D No
How is the treatment process monitored?





23

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Plant
Date
 Waste Minimization Assessment
Proj. No..
Prepared by _

Checked by _
Sheet	of	Page	of _
  WORKSHEET
     4B
WASTE MINIMIZATION:
  Treatment Practices
C. AFTER TREATMENT

  How Is wood dried following treatment?.
  How is treated wood transferred from drip pads to storage yard?.
  Where is wood stored following treatment?_
  Is wood covered when stored in an open yard?
                                              D Yes   D No
                                            24

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Plant Waste Minimization Ass
Date Proi. No.
essment F
C
S
repared bv
Jhecked by
heet of Page of

1
WORKSHEET OPTION GENERATION:
5 Treatment Practices


Meeting Format (e.g., brainstorminq, nominal group technique)
Meeting Coordinator
Meeting Participants

Suggested Waste Minimization Options
A. Before Treatment
Inspect Untreated Wood
Cover Wood During Shipment
Clean Wood Prior to Treatment
Seaspn or Condition Wood Prior to Treatment
B. During Treatment
Use Treatment Process That Minimizes Dripping
Monitor Chemical Retention
Use Strip Pumps
Avoid Excess Pressure During Treatment
Use Dedicated Forklifts at Drip Pads
Wash Tires of Nondedicated Forklifts Before
Leaving the Drip Pad
Pave Area Adjacent to Drip Pads
C. After Treatment
Keep Wood on Drip Pad Until Dripping Ceases
Cover Wood in Open Storage Yards
Store Wood in Enclosed Areas if Possible
Avoid Tracking Preservative Out of Controlled Areas






Currently
Done Y/N?
























Rationale/Remarks on Option
























25

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Plant Waste Minimizal
Di

lie Proj. No.


WORKSHEET WASTE M1N
3 Housekeeph

inn ARRftRRment Prepared bv
Checked by
Sheet of Page of


IIMIZATION:
ig Practices

How is lumber stored?



How often are sump pits and drip pads cleaned?



How often are floors cleaned?



How often are filters cleaned?



How often are tanks checked for leaks?



How are leaks and spills handled?


Is chemical dripping intercepted?
Are recycling bins and containers clearly marked?
Are tanks kept clean?
How are empty preservative containers cleaned?

Is

rinsewater reused?

D Yes D No
D Yes D No
D Yes D No

D Yes D No
26

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Plant Waste Minimization Assessment Prepared by
Checked by
Date Proj. No.
Sheet of Page of


WORKSHEET OPTION GENERATION:
7 Housekeeping Practices


Meeting Format (e.g., brainstorm ing, nominal group technigue)
Meeting Coordinator
Meeting Participants

Suggested Waste Minimization Options
Stack Treated and Untreated Lumber Neatly
Wash Down Sump Pits, Drip Pads, and Areas
_ Around Cylinder Doors Regularly
Clean Floors Regularly
Clean Filters and Tanks Regularly
Inspect Tanks, Drip Pads, and Treating Cylinders
for Leaks Regularly
Intercept All Chemical Drips and Leaks
Mark Bins and Containers Ciearly
Use Filtration to Keep Tanks Clean
Triple Rinse Empty Waterborne Preservative Containers
Reuse Rinsewater as Process Water Diluent












Currently
Done Y/N?






















Rationale/Remarks on Option






















27

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Plant
Date

WORKSHEET
8A

How are preservatives stored?

Are chemicals stored in a way tha
How are other materials (wax, mo
How far are preservative storage
Waste Minimization Assessment P
C
Proi. No. S

WASTE MINIMIZATION:
Storage and Disposal
Practices



t minimizes leaks and spills?
Id nhibitors) stored?

areas from the property line?

Are hazardous chemicals stored separately from nonhazardous chemicals?
Are preservative storage areas isolated as much as possible?
Are chemicals protected from the weather?
How often are chemical inventories performed?

What is the total capacity of conta
Do storage areas have teak detec
Are storage areas inspected for le
How often are storage areas nsp
How are spills handled?

How is liquid waste stored?


inment?

tion systems?
aks and spills?
acted?





repared by
hecked by
heet of Paqe of





D Yes D No



D Yes D No
D Yes D No
D Yes D No



D Yes D No
D Yes D No





How is solid waste stored?


28

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Plant
Date
Waste Minimization Assessment
Proj. No.
Prepared by	

Checked by	

Sheet	of	Page.
of
  WORKSHEET
     8B
WASTE MINIMIZATION:
 Storage and Disposal
        Practices
  How are obsolete chemicals disposed?
  How is liquid waste disposed?.
  How is solid waste disposed?.
   Do storage areas have concrete floors?
                                             D Yes   D No
                       Waste Type?
                                            29

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Plant Waste Minimization Assessment Prepared bv
Checked by
Date Proi. No.
Sheet of Page of

WORKSHEET OPTION GENERATION:
9 Storage and Disposal
Practices

Meetinq Format (e.q.. brainstorming. nominal arouo technique)
Meeting Coordinator
Meeting Participants

Suggested Waste Minimization Options
Locate Storage Facilities at Least 50 Feet
From the Property Line
Cover, Lock, Label, and Fence Storage Areas
Keep Containers Closed
Place Containers In a Base to Contain Leaks and Spills
Store Hazardous Chemicals Separately from
Nonhazardous Chemicals
Install Concrete Floors
Provide Containment Equivalent to 150 Percent of the
Amount of Liquid Stored in the Largest Tank
Inspect Storage Areas Routinely for Leaks and Spills
Clean Up Spills Immediately
Wash Liquid Spills into Sumps and Reuse
Drum Untreated Wood Scraps Separately from
Treatment Waste
Elevate Storage Containers
Build a Dike Around the Storage Area
Do not Accumulate Large Volumes of Waste
Properly Package and Label Solid Waste for Disposal









Currently
Done Y/N?
























Rationale/Remarks on Option






















30

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                                        Appendix A
                         WOOD PRESERVING INDUSTRY
                     FIELD ASSESSMENTS:  CASE STUDIES
   In 1993, the EPA published a waste minimization
study (prepared by Battelle under contract to the EPA)
entitled Waste Minimization  Practices at Two CCA
Wood-Treatment Plants (Chen and Olfenbuttel 1993).
The objectives of the study were to

   •  Estimate the amount of hazardous waste that a
     well-designed  and well-maintained CCA treat-
     ment plant would generate

   •  Examine  the  possibility  of using CCA more
     efficiently.

   This appendix presents summaries of the results of
the field assessments performed by Battelle, as well as
an assessment published in 1992 by the EPA (Kirsch
and Maginn 1992).  The summaries presented should
not be taken as  recommendations or endorsement by
the EPA; they are provided as examples only.
   These  field assessments focus on waste manage-
ment  within the context of existing practices  and
equipment.  The plants described are not necessarily
typical, but they  provide valuable insight into possible
techniques to reduce waste with minimum departure
from current practices.

References

Chen, Abraham S.  C. and  Robert F.  Olfenbuttel.
   1993.  Waste Minimization Practices at Two CCA
   Wood-Treatment Plants.  Report to U.S. Environ-
   mental Protection Agency,  Risk Reduction Engi-
   neering Laboratory, Office of Research and Devel-
   opment, Cincinnati, OH.

Kirsch, F. William and J.  Clifford Maginn, Jr.  1992.
   Waste Minimization Assessment for a Manufacturer
   Producing Treated Wood Products.  U.S. Environ-
   mental Protection Agency,  Risk Reduction Engi-
   neering Laboratory, Office of Research and Devel-
   opment, Cincinnati, OH.
                                               31

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                                            PLANT A
                      WASTE  MINIMIZATION ASSESSMENT
   Plant A  has been in continuous operation at the
same location  since 1959.   The plant is located on a
75-acre lot in a rural  area.  The original thrust of
Plant A's  business was  supplying  pressure-treated
agricultural fencing.  Its main product  is now CCA-
treated lumber. The company has 65 employees.  In
1992, 50 million board feet of wood were treated.

   In 1991, Plant A built a new treatment plant.  The
company decided  not  to  upgrade  its   old  facilities
because they were  poorly designed for efficient mate-
rial handling  and because more stringent regulations
are pending.   Compliance with  these regulations by
retrofitting would cost more than building a new treat-
ment plant.  The  new plant is a single building that
covers  4-1/3 acres. The new facilities consist of three
parallel treatment cylinders, vacuum pumps, high-pres-
sure pumps, air compressors, and strip pumps.

   The overall design for  the new plant is based on
the concept of "containment, capturing,  recycling, and
prevention" and incorporates many safety features that
are not expected  to become  law for   several  more
years.

Process Description

   Lumber arrives  at Plant A by truck at the receiving
area located in an open yard just outside the treatment
plant.  The shipments are inspected to assure  that they
are undamaged and that they meet the required speci-
fications.  Plant A  requires that lumber  be covered by
tarpaulins during transit to reduce the amount of road
dust and grime reaching the lumber (which eliminates
3  to 4 drums  of hazardous waste a year).  If neces-
sary, the lumber is power-washed and debris  removed
before  it is forklifted into  the untreated-wood storage
area in the treatment plant.

   The  modified  full-cell  method is used for most
treatments; the full-cell method is  used for dense
materials and  timber.   Treatment conditions  are con-
trolled  by  a  computer programmed  to  achieve both
proper chemical retention and minimum drippage.
   Before treatment, lumber  is rebanded with plastic
strapping into lumber units  of the  appropriate size.
The  tagged  lumber units  are  then  forklifted to the
lumber-handling system where they are placed parallel
to the treating cylinders.  The  untreated lumber units
are moved into the cylinders  for treatment by an auto-
matic chain  conveying system.   After  treatment, the
lumber remains  on the conveying  system for  1 to
2 days before being forklifted to drying sheds,  to the
storage areas in  the treatment plant, or to the  open
yard.

Waste Generation

   Plant A  generated  9 55-gal drums  of hazardous
waste in  1991 and 6  in 1992.   Some  of  this  was a
result of shutting  down the old plant.   The  waste
volume projected for the new treatment plant in 1993
is 2 to 4  drums, or 0.5 to 1 drum every 90  days.  The
waste is  composed of sludge removed from the filter
bags, the pump screens, and under the cylinder door
traps; dust; tags;  and miscellaneous items.

Waste Minimization Practices

   Lumber is handled, treated, and dried, in  enclosed
structures at  Plant A,  which  protects  chemicals,
treating facilities, freshly treated wood,  and drip pads
from direct  exposure  to ambient weather  conditions,
thereby reducing the possibility of contaminating the
environment.

   A concrete floor covers the entire plant.  The con-
crete floor has an impermeable surface coating.  An
elevated  metal drip pan  on the  drip pad intercepts
chemicals dripping from the cylinder doors and from
freshly treated  lumber;  therefore, no  direct contact
between  the chemicals and the concrete floor occurs
unless there is a major chemical spill.  A  recessed
floor under both the drip pans and the  treating cylin-
ders functions as  a secondary  containment  to  retain
spills from the drip pad.

   The unique design of the  drip pan and the lumber-
conveying  system  at Plant A  eliminates  tracking
                                                  32

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chemicals  from  the  drip pan and the  drip  pad.
Plant A's  automatic  lumber  handling  system  and
power rollers transfer lumber units into and out of the
treating cylinders without forklifts  or rail trams.   The
treated  lumber units  remain  on the conveyer  until
dripping ceases.   This method of  lumber handling
eliminates  any  direct contact between people  and
chemicals and between equipment and chemicals.

   Drip pans  are hosed  down 3 to 4  times  a  year.
The  solution  is filtered  through a  10-pm filter bag
before being recycled as makeup water.  The recycled
solution  is metered and the volume recorded  so that
any problems  may be monitore3, controlled, or elimi-
nated.   The filter bags are cleaned daily; the solids
removed from the filter bags are disposed of  as haz-
ardous waste (about 2 drums per year).

   Plant A's tank farm has primary spill containment,
an elevated CCA concentrate tank, an enclosed chemi-
cal mixing system, and remote monitoring and control
capabilities.   The tank farm is in a heated building
adjacent to the  cylinder area  of the treatment plant.
The  building  is  completely surrounded by retaining
walls,  which  form the  primary, containment.   The
retaining .wall separating the tank farm and the neigh-
boring treating cylinder area has a weir to allow liquid
to overflow  from  the primary  containment  to the
secondary  containment during major chemical  spills
(such as tank rupture).

   The primary  containment hi the tank farm is  capa-
ble  of  containing chemical spills equivalent to the
volume of a  large CCA  work tank.  Overflow from
the primary containment can  be  spilled over to the
secondary  containment.   The total  capacity  of the
primary  and secondary containments is equivalent to
the total volume of the liquid  stored in  the tank farm,
thus eliminating any possibility of chemical spills over
the uncontrolled areas.  The concrete floor in the tank
farm has an impermeable coating and is lined  with an
underground liner.   The  lined area is  monitored for
chemical leakage by six detection systems.

   The  elevated CCA concentrate tank has  a  cone-
shaped bottom, which facilitates inspection and allows
visual reference in case of a leak.  The CCA  concen-
trate can be unloaded from a chemical tanker in the
tank farm  through an unloading point next to the
concentrate tank, thus preventing release of chemical
spills to the uncontrolled areas.
   Chemicals  are mixed  in  a  computer-controlled
enclosed system.  In addition, the tank farm has auto-
matic temperature, pressure,  and safety  switches for
remote monitoring and control.  This design eliminates
the need for workers to enter the tank farm on a regu-
lar basis, thus reducing worker exposure to the chemi-
cals.

   Plant A's  treatment building has  eight roof fans
that exchange air completely every 15 minutes.  The
tank farm is used  as a  single point source for  all
venting  from  the   cylinders  and  chemical  tanks.
Because the  plant design  minimizes  mist or droplet
emissions from the cylinders and work tanks, no addi-
tional air pollution control devices have been installed
in the tank farm.

   The  treatment processes at Plant A  are  carefully
controlled  to  ensure proper chemical retention  and
minimal dripping.   Several process control  methods
are used:

   •  Treatment  processes are  computer-controlled
      and monitored.

   •  Lightweight products that drip less  are produced
      using rapid cycle treatment.  Treating cylinders
      are fed with CCA work  solution at rates up  to
      8,000 gpm.   CCA  chemicals are  pushed  into
      wood cells in less than 4 minutes, allowing time
      for chemical fixation.

   •  High pressure  at 150 to 165 psi over a period of
      5  to 8 minutes is  applied, which eliminates
      excessive dripping.

   •  After the high-pressure  treatment,  a slow-pres-
      sure release follows immediately  and  lasts  for
      8 to 19 minutes, which  also  results  in  less
      dripping.

   •  Large  vacuum  pumps  pull  vacuum up   to
      27 niches Hg  within 1 to 2 minutes.  The final
      vacuum lasts up to 2 hours, which again reduces
      the  amount   of dripping  from   the  treated
      products.

   •  Oxides are  used to enhance chemical fixation in
      wood.
                                                   33

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   •  Strip pumps continuously return residual chemi-
      cal  solutions to  the  CCA  work tank.    This
      results in less dripping when opening the cylin-
      der  doors and  in  more exact  control of  final
      retention.

   •  Treating cylinders  are slightly tilted  toward the
      work tank to reduce dripping when opening the
      cylinder doors.

   •  Treated  products  are  analyzed  for chemical
      retention  using  an X-ray fluorescence analyzer.
      Proper chemical retention is monitored to ensure
      that treatment  specifications  are  met and that
      overtreatment does not occur.

   •  Research and development and operator training
      programs are provided for continuous improve-
      ment of treatment controls and skills.

   Plant A considers housekeeping  an integral part of
its waste minimization effort:

   •  The concrete floor in the  treatment  building is
      vacuum-swept daily and manually swept when-
      ever necessary.

   •  Plant A regularly  inspects  the concentrate tank,
      work tanks,  automatic chemical mixing system,
      treating  cylinders, drip  pan,  lumber-handling
      system,  and spill containments  for chemical
      leaks and spills.
   •  The unused mold inhibitor drums and wax totes
      are stacked neatly in  an open area in the tank
      farm.

   •  A plastic container is  hung under  the concen-
      trate   unloading   point  to   intercept chemical
      dripping.

   •  Lumber, treated  or untreated, is stacked neatly
      on the lumber-handling system,  in the treatment
      building, or in the open storage yard.

   •  All recycling bins, dumpsters, and containers are
      clearly marked and placed at  locations  away
      from frequent traffic.

   •  Wooden cross pieces are used to separate wood
      units and to avoid forklift damage.

   •  The lumber stacks in the open yard are covered
      with  paper to provide protection  from direct
      exposure to rain.  This reduces the amount of
      arsenic and chromium being leached into storm-
      water runoff.

   Plant A  is  a zero-discharge facility that recycles
chemical drips,  spills,  rinse  water,  and washdown
water as  a  process water. Plant A also recycles most
of  its  nonhazardous   solid   waste   and  chemical
containers.
                                                   34

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                                            PLANT B
                       WASTE MINIMIZATION ASSESSMENT
   Plant B  has been in business continuously  since
1988.  The plant operates two shifts and employs 35
people in the winter and 60 in the summer.   The
plant's 15-acre lot is located in a rural area Plant B
treats 55  million board feet of wood a year.

   The treatment  plant is composed  of a cylinder
room, a  conditioning building, and a process control
room.  The cylinder room contains one treating cylin-
der,  one rectangular combination  tank, one primary
work tank, pumps, pipes, and an underground pit.  A
rail/trench  system divides  thie  conditioning building
into  two  areas:  the lumber loading area and the drip
pad (or conditioning area).

   The  concrete  trench  dividing  the  conditioning
building  slopes toward the cylinder room.  Two rails
are on top_ of the trench.  Trams  loaded with untreated
or treated lumber are pulled into  or out of the cylinder
by a motor cable.  The control room includes a  set of
visible volume meters, a process control panel,  and a
small laboratory bench.

Process Description

   Untreated lumber arriving in bulk units by railroad
car is tagged and stored  in the unpaved open yard.
The  lumber  is restacked  by a  stacker,  banded with
plastic strapping, and left in the  open yard until treat-
ment.  Lumber units to be treated are forklifted  to the
treatment building and placed  parallel to the rail/
trench.  The units are then loaded onto trams by fork-
lift,  fastened with heavy-duty belts, and pulled into the
treating cylinder by a motor cable.   Treatment condi-
tions at Plant B are similar to those used by Plant A,
except that the pressure release after the high-pressure
treatment  lasts  for only  3 minutes  and the  final
vacuum lasts for 20 to 30 minutes.

   The modified full-cell method is used to treat most
wood at Plant B. Treated products are analyzed for
chemical retention using an  X-ray fluorescence ana-
lyzer. After treatment, the lumber units are pulled out
of the cylinder, forklifted to the  drip pad, and allowed
to drip on the drip pad for 1 to 3 days.  To facilitate
dripping, the lumber units are placed at a slight angle
on the drip pad.   The treated wood stacks  are then
transferred by forklift to one of the three drying sheds
or to the open yard.

  Both people and equipment operate in the condi-
tioning area at Plant B, where a significant amount of
chemicals accumulate.  As a result, chemicals may be
tracked  from  the  conditioning area to  surrounding
areas.

Waste Generation

  Plant B  generates 4 drums  per year  of hazardous
waste, or about one drum every 90 days.  The waste
is collected from the  bottom screen of a two-screen
setup and is  composed primarily of sludge  removed
from the trench and  from  under the  cylinder door
traps.   Wood" chips,  debris,  and other large items
collected on the top screen are disposed of as non-
hazardous waste.

Waste Minimization Practices

   Plant B  is  housed  in enclosed  structures, which
provide shelter for chemical storage and mixing, lum-
ber handling and treating, process control, and lumber
drying.  A  concrete floor covers the entire plant.  The
floor has an impermeable surface coating and liner.

   The conditioning area is  hosed down daily.  Chem-
icals  and washdown  water are directed toward  the
trench and  filtered through a wire screen at the end of
the trench.  The filtered solution flows  into an under-
ground  steel liner, which sits in an underground door
pit.  Wood chips, debris, and sludge are intercepted in
the  trench and  shoveled weekly to the two-screen
setup for air drying.  The air-dried solids collected on
the top  screen are disposed of as nonhazardous waste
in a dumpster; the finer solids  collected on the bottom
screen are disposed of as hazardous waste.

   The  treating cylinder and combination tank sit side-
by-side in  the cylinder room.  The cylinder  lies on
four steel  supports with a slight tilt away  from the
                                                  35

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cylinder door.  The combination tank sits on a con-
crete floor. Between the cylinder and the combination
tank is a narrow walkway.  The cylinder and the com-
bination tank are surrounded by retaining walls on the
north, south, and east sides. The opening on the west
side connects  the  cylinder room to the conditioning
building.   A  wooden deck  underneath  the  cylinder
separates the ground  level from  the  underground pit
and an underground primary work tank.

   The pit under the cylinder is concrete.  Underneath
the cylinder door is another concrete pit with a steel
liner and a steel spillover extension.  The pit is coated
with a sealer and lined with plastic.  The steel liner is
directly under the cylinder door,  and the overflow
from the liner is spilled into  the spillover extension.
Pumps at the  spillover  extension, the steel liner, and
the door pit transfer the liquid to  the primary  work
tank for reuse.

   The concrete pit is large enough to contain the total
volume of liquid in the combination tank and primary
work tank.  For minor spills, the three pumps associ-
ated with the underground pit transfer the liquid to the
primary or secondary work tank.

   The underground pit and primary work tank are not
readily seen from the ground level, making it difficult
to monitor chemical leaks.   However, Plant B does
have a remote monitoring and control system.

   Vents  from the cylinder,  combination tank,  and
primary work tank are directed to  the conditioning
building, which has electric  fans in the side walls for
ventilation.

   Plant B recycles chemical drips, spills, rinse water,
and washdown water as a process water, but disposes
of most of its chemical containers and the wood  trim
    strips from milling operations.
                                                   36

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                                            PLANTC
                       WASTE  MINIMIZATION ASSESSMENT
   Plant C produces treated wood products.  It oper-
ates  8,760 hours  a  year  to process approximately
1,700,000 cubic feet per year of wood.

Process Description

   The plant treats crossties and poles with creosote
and No. 6 oil in heated pressure cylinders.  Lumber is
treated  with 2 percent chromated copper  arsenate
(CCA) solution in a pressure cylinder.  The raw mate-
rials used are the wood products, creosote, No. 6 oil,
and  chromated copper arsenate.   Steam is used  to
clean the surface of the wood in  the creosote treat-
ment cylinders, and ozone is used  to destroy phenols
in the steam condensate.

   The following steps are  involved  in treating the
wood products:

   •  Crossties and poles are trimmed on the ends and
     stacked on rail trams, which are pushed into a
     pressure treatment cylinder.

   •  A heated mixture of 50 percent (v/v) creosote
     and No. 6  oil is  pumped into the  cylinder and
     pressurized to force the  liquids into the wood
     cells.

   •  The liquid is drained from the cylinder and held
     for reuse.

   •  The cylinder is  flooded with steam to clean
     excess creosote and oil from the surface of the
     wood.   A vacuum is drawn  on the cylinder  to
     enhance removal of the  liquid from the wood
     and the cylinder.

   •  Steam condensate drains to  a blowdown  tank.
     Residual creosote and  oil that drains  when the
     cylinder is opened is pumped to the blowdown
     tank.   The creosote is separated from the con-
     densate and held for reuse.
   Lumber is treated as follows:

   •  Lumber  is  stacked  on rail  trams, which are
     pushed into a pressure treatment cylinder.

   •  A closed-loop process with 2 percent CCA is
     used for treatment.  The cylinder is pressurized
     to 125 psig.

   •  Solution drained  from the  cylinder is  held for
     reuse.

   Steam  condensate   from  creosote  treatment  is
treated with a flocculant to settle contained creosote,
and the pH is adjusted to 3.6 to 4.0.    An  ozone
treatment is  used to break down phenols in the steam
condensate before it is discharged as industrial waste-
water.  Creosote wastes are also generated from peri-
odic steam cleaning of the treatment  cylinders.  No
steam  is  used in  cleaning  the  CCA  cylinders.
Accumulated waste containing CCA is disposed of as
hazardous  waste.

Waste Generation

   Residual  spent  CCA solution is  collected  when
cleaning the CCA  pressure  cylinder and disposed of as
hazardous  waste.   Steam  condensate  from  cleaning
creosote-treated crossties and poles to  remove excess
creosote is  treated with  a  flocculant, settled and
decanted,  treated  with  ozone and caustic  soda, and
discharged as industrial wastewater.

   Cleaning  the creosote treatment cylinders results in
a creosote sludge, part of which is shipped for use as
boiler fuel, and the remainder is disposed of as haz-
ardous  waste.   Chips,  bark, and wood trimmings are
stored  in  an  open  area  on  leased property before
disposal.
                                                  37

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Waste Minimization Practices

   •  Cylindrical  tanks  holding creosote and  CCA
     have been  fitted  with  conical  bottoms  for
     accumulation of sludge, minimizing the need for
     periodic cleaning.
The  pressure cylinder  does not require  steam
cleaning, lessening the quantity of contaminated
waste.

Storage tanks are  heated  to  maintain proper
viscosity and reduce sludge  formation.
                                                  38

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                                            Appendix B
                                 WHERE TO GET HELP:
         FURTHER INFORMATION  ON POLLUTION PREVENTION
   Additional information on source reduction, reuse
and  recycling approaches  to pollution  prevention is
available in EPA reports listed in this section,  and
through  state programs  and regional  EPA  offices
(listed below) that offer  technical and/or financial
assistance in the areas  of pollution  prevention  and
treatment.

   Waste exchanges  have been, established in some
areas of the United States to put waste generators in
contact with potential users of the waste. Twenty-four
exchanges operating in the United States and Canada
are listed.  Finally, relevant industry  associations are
listed.

U.S. EPA Reports on
Waste Minimization
Facility  Pollution  Prevention  Guide.
92/088.*
EPA/600/R-
Waste  Minimization Opportunity Assessment Manual.
EPA/625/7-88/003.*

Waste  Minimization Audit Report:  Case  Studies of
Corrosive and Heavy Metal Waste Minimization Audit
at a Specialty Steel Manufacturing Complex.   Execu-
tive Summary. EPA No. PB88-107180.**

Waste  Minimization Audit Report:  Case  Studies of
Minimization of Solvent Waste for  Parts Cleaning and
from Electronic  Capacitor Manufacturing  Operation.
Executive Summary. EPA No. PBS7-227013.**
Waste Minimization Audit Report:   Case Studies of
Minimization  of Cyanide Wastes from Electroplating
Operations.   Executive  Summary.  EPA No. PB87-
229662.**

Report to Congress:  Waste Minimization, Vols. I and
II.  EPA/530-SW-86-033 and -034 (Washington, D.C.:
U.S. EPA, 1986).***

Waste Minimization—Issues and Options, Vols. I-III.
EPA/530-SW-86-041 through  -043.    (Washington,
D.C.: U.S. EPA, 1986.)***

   The  Guides  to  Pollution  Prevention  manuals*
describe  waste  minimization  options   for  specific
industries.  This is a continuing series which currently
includes the following tides:

Guides to Pollution  Prevention:  Paint Manufacturing
Industry. EPA/625/7-90/005.

Guides to Pollution Prevention:  The Pesticide For-
mulating Industry. EPA/625/7-90/004.

Guides  to  Pollution Prevention:   The  Commercial
Printing Industry.  EPA/625/7-90/008.

Guides  to  Pollution Prevention:   The Fabricated
Metal Industry.  EPA/625/7-90/006.

Guides to Pollution Prevention for Selected Hospital
Waste Streams.  EPA/625/7-90/009.

Guides to Pollution Prevention:  Research and Educa-
tional Institutions. EPA/625/7-90/010.
   Available from EPA CERI Publications Unit (513) 569-7562,
   26 West Martin Luther King Drive, Cincinnati, OH, .45268.

   Executive Summary available from EPA, CERI Publications
   Unit, (513) 569-7562, 26 West Martin Luther King Drive, Cin-
   cinnati,  OH, 45268; full report available from the National
   Technical Information -Service (NTIS),  U.S.  Department of
   Commerce, Springfield, VA, 22161.
                                                    Guides to Pollution Prevention:  The Printed Circuit
                                                    Board Manufacturing Industry.  EPA/625/7-90/007.
              ***  Available from the National Technical Information Service as
                  a five-volume set, NTIS No, PB-87-114-328.
                                                 39

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 Guides to Pollution Prevention:
 Industry. EPA/625/7-91/017.

 Guides to Pollution Prevention:
 Industry. EPA/625/7-91/012.
 The Pharmaceutical
The Photoprocessing
Guides to Pollution Prevention:  The Fiberglass Rein-
forced   and   Composite   Plastic  Industry.
EPA/628/7-91/014.

Guides to Pollution  Prevention:   The  Automotive
Repair Industry. EPA/625/7-91/013.

Guides to Pollution  Prevention:   The  Automotive
Reflnishins Industry.  EPA/625/7-91/016.

Guides to Pollution Prevention:  The Marine Mainte-
nance and Repair Industry.  EPA/625/7-91/015.

Guides to Pollution Prevention:  The Metal Casting
and Heat Treating Industry.  EPA/625/R-92/009.

Guides to Pollution Prevention:  Mechanical Equip-
ment  Repair Shops.  EPA/625/R-92/008.
 Guides to Pollution Prevention:
 Industry.  EPA/625/R-92/011.
The Metal Finishing
U.S. EPA Pollution Prevention Information Clearing-
house (PPIC):  Electronic Information Exchange Sys-
tem (EIES)—User  Guide,  Version  1.1.   EPA/600/
9-89/086.

Waste Reduction Technical/
Financial  Assistance Programs

   The EPA Pollution Prevention Information Clear-
inghouse (PPIC) was  established to encourage waste
reduction through technology transfer, education,  and
public awareness.   PPIC collects and  disseminates
technical and  other information about pollution pre-
vention through a telephone  hotline and an electronic
information  exchange  network.   Indexed bibliogra-
phies and abstracts  of reports, publications, and case
studies about pollution prevention are available. PPIC
also lists a calendar of pertinent conferences and semi-
nars, information about activities abroad, and a direc-
tory of  waste exchanges.   Its Pollution Prevention
Information   Exchange  System  (PPIES)  can   be
accessed electronically 24 hours a day without fees.
   For more information contact:
PPIES Technical Assistance
Science Applications International Corp.
8400 Westpark Drive
McLean, VA  22102
(703)  821-4800
                         or
U.S. Environmental Protection Agency
401 M Street S.W.
Washington, D.C. 20460

   Myles E. Morse
   Office of Environmental Engineering and
    Technology Demonstration
   (202) 260-5748

   Priscilla Flattery
   Pollution Prevention Office
   (202) 260-8383

   The EPA's  Office of Solid Waste and Emergency
Response  has  a telephone call-in service to answer
questions regarding RCRA and Superfund (CERCLA).
The telephone numbers are:

   (800) 242-9346 (outside the District of Columbia)

   (202) 382-3000 (in the District of Columbia)

   The  following  programs  offer  technical  and/or
financial  assistance   for  waste  minimization  and
treatment.

Alabama
Hazardous Material Management and Resource
  Recovery Program
University of Alabama
P.O. Box 6373
Tuscaloosa, AL  35487-6373
(205) 348-8401

Department of Environmental Management
1751 Federal Drive
Montgomery, AL 36130
(205) 271-7914
                                                 40

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Alaska
Alaska Health Project
Waste Reduction Assistance Program
1818 West Northern Lights Boulevard
Anchorage, AK 99501
(907)276-2864

Arizona
Arizona Department of Economic Planning and
 Development
1645 West Jefferson Street
Phoenix, AZ 85007
(602) 255-5705

Arkansas
Arkansas Industrial Development Commission
One State Capitol Mall
Little Rock, AR 72201
(501) 371-1370

California
Pollution Prevention, Public and Regulatory
 Assistance Program
Department of Toxic Substances Control
California State Department of Health Services
P.O. Box 806
Sacramento, CA  95812-0806
(916) 322-3670

Pollution Prevention Program
San Diego County Department of Health Services
Hazardous Materials Management Division
P.O. Box 85261
San Diego, CA 92186-5261
(619) 338-2215

Colorado
Division of Commerce and Development Commission
500 State Centennial Building
Denver, CO 80203
(303) 866-2205

Connecticut
Connecticut Hazardous Waste Management Service
Suite 360
900 Asylum Avenue
Hartford, CT  06105
(203) 244-2007
Connecticut Department of Economic Development
210 Washington Street
Hartford, CT  06106
(203) 566-7196

Delaware
Delaware Department of Community Affairs &
  Economic Development
630 State College Road
Dover, DE 19901
(302) 736-4201

District of Columbia
U.S. Department of Energy
Conservation and Renewable Energy
Office of Industrial Technologies
Office of Waste Reduction, Waste Material
  Management Division
Bruce Cranford CE-222
Washington, DC 20585
(202) 586-9496

Pollution Control Financing  Staff
Small Business Administration
1441 "L" Street,  N.W., Room 808
Washington, DC 20416
(202) 653-2548

Florida
Waste Reduction Assistance Program
Florida Department of Environmental Regulation
2600 Blair Stone Road
Tallahassee, FL  32399-2400
(904) 488-0300

Georgia
Hazardous Waste Technical  Assistance Program
Georgia Institute of Technology
Georgia Technical Research Institute
Environmental Health and Safety Division
O'Keefe Building, Room 027
Atlanta, GA 30332
(404)894-3806

Environmental Protection Division
-Georgia Department of Natural Resources
205 Butler Street, S.E., Suite 1154
Atlanta, GA 30334
(404) 656-2833
                                                 41

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Guam
Solid and Hazardous Waste Management Program
Guam Environmental Protection Agency
IT&E Harmon Plaza, Complex Unit D-107
130 Rojas Street
Harmon, Guam  96911
(671) 646-8863-5

Hawaii
Department of Planning & Economic Development
Financial Management and Assistance Branch
P.O. Box 2359
Honolulu, HI 96813
(808) 548-4617

Idaho
IDHW-DEQ
Hazardous Materials Bureau
450 West State Street, 3rd Floor
Boise, ID  83720
(208) 334-5879

Illinois
Illinois EPA
Office of Pollution Prevention
2200  Churchill Road
P.O. Box 19276
Springfield, IL 62794-9276
(217) 782-8700

Hazardous Waste Research and Information Center
Illinois Department of Energy and Natural Resources
One East Hazelwood Drive
Champaign, EL  61820
(217) 333-8940

Illinois Waste Elimination Research Center
Pritzker Department of Environmental Engineering
Alumni Memorial Hall, Room 103
Illinois Institute of Technology
3201 South Dearborn
Chicago, IL  60616
(312) 567-3535

Indiana
Environmental Management and Education Program
School of Civil Engineering
Purdue University
2129 Civil Engineering Building
West Lafayette,  IN  47907
(317) 494-5036
Indiana Department of Environmental Management
Office of Technical Assistance
P.O. Box 6015
105 South Meridian Street
Indianapolis, IN 46206-6015
(317)232-8172

Iowa
Center for Industrial Research and Service
Iowa State University
Suite 500, Building 1
2501 North Loop Drive
Ames, IA 50010-8286
(515) 294-3420

Iowa Department of Natural Resources
Air Quality and Solid Waste Protection Bureau
Wallace State Office Building
900 East Grand Avenue
Des Moines, IA 50319-0034
(515)281-8690  ,

Waste Management Authority
Iowa Department of Natural Resources
Henry A. Wallace Building
900 East Grand
Des Moines, IA 50319
(515) 281-8489

Iowa Waste Reduction Center
University of Northern Iowa
75 Biology Research Complex
Cedar Falls, IA  50614
(319)273-2079

Kansas
Bureau of Waste Management
Department of Health and Environment
Forbes Field, Building 730
Topeka, KS  66620
(913) 269-1607

Kentucky
Division of Waste Management
Natural Resources and Environmental Protection
 Cabinet
18 Reilly Road
Frankfort, KY 40601
(502) 564-6716
                                                42'

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 Kentucky Partners
 Room 312 Ernst Hall
 University of Louisville
 Speed Scientific School
 Louisville, KY  40292
 (502) 588-7260

 Louisiana
 Department of Environmental Quality
 Office of Solid  and Hazardous Waste
 P.O. Box 44307
 Baton Rouge, LA 70804
 (504) 342-1354

 Maine  ,
 State Planning Office
 184 State Street
 Augusta, ME 04333
 (207)289-3261

 Maryland
 Maryland Hazardous Waste Facilities Siting Board
 60 West Street,  Suite 200 A
 Annapolis, MD   21401
 (301) 974-3432

 Massachusetts
 Office of Technical Assistance
 Executive Office of Environmental Affaks
 100 Cambridge  Street, Room 1904
 Boston, MA 02202
 (617) 727-3260

 Source Reduction Program
 Massachusetts Department of Environmental
  Quality Engineering
 1 Winter Street
 Boston, MA 02108
 (617) 292-5982

 Michigan
 Resource; Recovery Section
 Department of Natural Resources
P.O. Box 30028
Lansing, MI 48909
 (517) 373-0540
 Minnesota
 Minnesota Pollution Control Agency
 Solid and Hazardous Waste Division
 520 Lafayette Road
 St. Paul, MN 55155
 (612) 296-6300

 Minnesota Technical Assistance Program
 1313  5th Street, S.E., Suite 207
 Minneapolis, MN 55414
 (612) 627-4646
 (800) 247-0015 (in Minnesota)

 Mississippi
 Waste Reduction & Minimization Program
 Bureau of Pollution Control
 Department of Environmental Quality
 P.O. Box 10385
 Jackson, MS  39289-0385
 (601) 961-5190

 Missouri
 State Environmental Improvement and Energy
  Resources Agency
 P.O. Box 744
 Jefferson City, MO  65102
 (314) 751-4919

 Waste Management Program
 Missouri Department of Natural Resources
 Jefferson Building, 13th Floorn
 P.O. Box 176
 Jefferson City, MO  65102
 (314)  751-3176

 Nebraska
 Land Quality Division
 Nebraska Department of Environmental Control
 Box 98922
 Slate House Station
 Lincoln, NE 68509-8922
 (402)  471-2186

 Hazardous Waste Section
 Nebraska Department of Environmental Control
P.O. Box 98922
Lincoln, NE 68509-8922
 (402) 471-2186
                                                 43

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New Jersey
New Jersey Hazardous Waste Facilities Siting
 Commission
Room 514
28 West State Street
Trenton, NJ  08625
(609) 292-1459
(609) 292-1026

Hazardous Waste Advisement Program
Bureau of Regulation and Classification
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ  08625
(609) 292-8341

Risk Reduction Unit
Office of Science and Research
New Jersey Department of Environmental Protection
401 East State Street
Trenton, NJ  08625
(609) 292-8341

New Mexico
Economic Development Department
Bataan Memorial Building
State Capitol Complex
Santa Fe, NM 87503
(505) 827-6207

New York
New York Environmental Facilities Corporation
50 Wolf Road
Albany, NY   12205
(518) 457-4222

North Carolina
Pollution Prevention Pays Program
Department of Natural Resources and Community
  Development
P.O. Box 27687
512 North Salisbury Street
Raleigh, NC  27611-7687
(919) 733-7015

Governor's Waste Management Board
P.O. Box 27687
325 North Salisbury Street
Raleigh, NC  27611-7687
(919) 733-9020
Technical Assistance Unit
Solid and Hazardous Waste Management Branch
North Carolina Department of Human Resources
P.O. Box 2091
306 North Wilmington Street
Raleigh, NC 27602
(919) 733-2178

North Dakota
North Dakota Economic Development Commission
Liberty Memorial Building
State Capitol Grounds
Bismarck, ND 58505
(701) 224-2810

Ohio
Division of Hazardous Waste Management
Division of Solid and Infectious Waste Management
Ohio Environmental Protection Agency
P.O. Box 0149
1800 Watermark Drive
Columbus, OH 43266-0149
(614)  644-2917

Oklahoma
Industrial Waste Elimination Program
Oklahoma State Department of Health
P.O. Box 53551
Oklahoma City, OK  73152
(405)  271-7353

Oregon
Oregon Hazardous Waste Reduction Program
Department of Environmental Quality
811 Southwest Sixth Avenue
Portland, OR 97204
(503) 229-5913
(800) 452-4011 (in Oregon)

Pennsylvania
Pennsylvania Technical Assistance Program
501 F. Orvis Keller Building
University Park, PA   16802
(814) 865-0427

Center of Hazardous Material Research
Subsidiary of the University of Pittsburgh Trust
320 William Pitt Way
Pittsburgh, PA 15238
(412) 826-5320
(800) 334-2467
                                                44

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 Puerto Rico
 Government of Puerto Rico
 Economic Development Administration
 Box 2350
 San Juan, PR  00936
 (809) 758-4747

 Rhode Island
 Hazardous Waste Reduction Section
 Office of Environmental Management
 83 Park Street
 Providence, RI 02903
 (401) 277-3434
 (800) 253-2674 (in Rhode Island)

 South Carolina
 Center for Waste Minimization
 Department of Health and Environmental Control
 2600 Bull Street
 Columbia, SC 29201
 (803) 734-4715

 South Dakota
 Department of State Development
 P.O. Box,6000
 Pierre, SD 57501
 (800) 843-8000

 Tennessee
 Center for Industrial Services
 University of Tennessee
 Building #401
 226 Capitol Boulevard
 Nashville, TN  37219-1804
 (615)  242-2456

 Bureau of Environment
 Tennessee Department of Health and Environment
 150 9th Avenue North
 Nashville, TN  37219-5404
 (615) 741-3657

Tennessee Hazardous Waste Minimization Program
Tennessee Department of Economic and Community
 Development
Division of Existing Industry Services
7th Floor, 320 6th Avenue, North
Nashville,, TN  37219
(615) 741-1888
 Texas
 Texas Economic Development Authority
 410 East Fifth Street
 Austin, TX  78701
 (512) 472-5059

 Utah
 Utah Division of Economic Development
 6150 State Office Building
 Salt Lake City, UT 84114
 (801)533-5325

 Vermont
 Economic Development Department
 Pavilion Office Building
 Montpelier, VT 05602
 (802) 828-3221

 Virginia
 Office of Policy and Planning
 Virginia Department of Waste Management
 llth Floor, Monroe Building
 101 North 14th Street
 Richmond, VA  23219
 (804) 225-2667

 Washington
 Hazardous Waste Section
 Mail Stop PV-11
 Washington Department of Ecology
 Olympia,WA  98504-8711
 (206)459-6322

 West Virginia
 Governor's Office of Economics and Community
  Development
 Building G, Room B-517
 Capitol Complex
 Charleston, WV 25305
 (304) 348-2234

Wisconsin
Bureau of Solid Waste Management
Wisconsin Department of Natural Resources
P.O. Box 7921
 101 South Webster Street
Madison, WI  53707
(608) 267-3763
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Wyoming
Solid Waste Management Program
Wyoming Department of Environmental Quality
Hersehler Building, 4th Floor, West Wing
122 West 25th Street
Cheyenne, WY 82002
(307) 777-7752

Waste Exchanges

Alberta Waste Materials Exchange
Mr. Jim Renick
303A Provincial Building
4920-51 Street
Red Deer, Alberta
CANADA T4N6KB
(403) 340-7980
FAX:   (403)340-7982

B.A.R.TJE.R. Waste Exchange
Mr. William Nynas
MPIRG
2512 Delaware Street SE
Minneapolis, MN 55414
(612) 627-6811

British Columbia Waste Exchange
Ms. Jill Gillett
1525 West 8th Avenue, Suite 102
Vancouver, B.C.
CANADA  V6J 1T5
(604) 731-7222 - General Information
(604) 732-9253 - Recycler Data Base

California Materials Exchange (CALMAX)
Mr. Dave Sparrow
Local Government Commission
909 12th St., Suite 205
Sacramento, CA  95814
(916)448-1198
FAX: (916) 448-8246
California Waste Exchange
Ms. Claudia Moore
Alternative Technology Division
Department of Toxic Substances Control
P.O. Box 806
Sacramento, CA 94212-0806
(916) 322-4742

Canadian Chemical Exchange*
Mr. Philippe LaRoche
P.O. Box 1135
Ste-Adele, Quebec
CANADA JOR 1LO
(514) 229-6511

Canadian Waste Materials Exchange
ORTECH International
Dr. Robert Laughlin
2395 Speakman Drive
Mississauga, Ontario
CANADA L5K IBS
(416) 822-4111 (Ext. 265)
FAX:  (416)823-1446

Indiana Waste Exchange
Mr. Jim Britt
Recyclers Trade Network
P.O. Box 454
Carmel, IN 46032
(317) 844-8764

Industrial Materials Exchange
Mr. Bill Lawrence
 172 20th Avenue
Seattle, WA 98122
(206) 296-4633
FAX:  (206)296-0188

Industrial Materials Exchange Service
Ms. Diane Shockey
P.O. Box 19276
Springfield, IL  62794-9276
 (217)782-0450
FAX:  (217)524-4193
 1 For-Profll Waste Information Exchange.
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Iowa Waste Reduction Center
By-product Waste Search Service
Ms. Susan Salterberg
75 BRC
University of Northern Iowa
Cedar Falls, IA  50614-0185
(800) 422-3109
(319) 273-2079
FAX: (319) 273-2893

Louisiana/Gulf Coast Waste Exchange
Ms. Rita Czek
1419 CEBA
Baton Rouge, LA 70803
(504) 388-8650
FAX: (504) 388-4945

Manitoba Waste Exchange
Ms. Beth Candlish
c/o Biomass Energy Institute, Inc.
1329 Niakwa Road
Winnipeg, Manitoba
CANADA R2J3T4
(204) 257-3891

Montana Industrial Waste Exchange
Manager
Montana Chamber of Commerce
P.O. Box 1730
Helena, MX 59624
(406) 442-2405

Northeast Industrial Waste Exchange, Inc.
Mr. Lewis Cutler
90 Presidential Plaza, Suite 122
Syracuse, NY  13202
(315) 422-6572
FAX:  (315)422-9051

Ontario Waste Exchange
ORTECH International
Ms. Mary Jane Hanley
2395 Speakman Drive
Mississauga, Ontario
CANADA L5K 1B3
(416) 822-4111 (Ext. 512)
FAX:  (416) 823-1446
Pacific Materials Exchange
Mr. Bob Smee
1522 North Washington, Suite 202
Spokane, WA 99205
(509) 325-0551
FAX:   (509)325-2086

Peel Regional Recycling Assistance
(Publishes  Directory of Local Recyclers)
Mr. Glen Milbury
Regional Municipality of Peel
10 Peel Center Drive
Brampton,  Ontario
CANADA L6T4B9
(416)791-9400

RENEW
Ms. Hope Castillo
Texas Water Commission
P.O. Box 13087
Austin, TX 78711-3087
(512) 463-7773
FAX:   (512)475-4599

Southeast Waste Exchange
Ms. Maxie May
Urban Institute
UNCC Station
Charlotte, NC 28223
(704) 547-2307

Southern Waste Information Exchange
Mr. Eugene B. Jones
P.O. Box 960
Tallahassee, FL 32302
(800) 441-SWIX (7949)
(904) 644-5516
FAX:  (904)574-6704

Wastelink,  Division of Tencon, Inc.
Ms. Mary E.  Malotke
140 Wooster Pike
Milford, OH  45150
(513) 248-0012
FAX:  (513)  248-1094
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U.S. EPA Regional Offices

Region 1 (VT, NH, ME, MA, CT, RT)
John F. Kennedy Federal Building
Boston, MA  02203
(617) 565-3715

Region 2 (NY, NJ)
26 Federal Plaza
New York, NY 10278
(212) 264-2525

Region 3 (PA, DE, MD, WV, VA)
841 Chestnut Street
Philadelphia, PA  19107
(215) 597-9800

Region 4 (KY, TN, NC, SC, GA, FL, AL, MS)
345 Courtland Street, N.E.
Atlanta, GA  30365
(404) 347-4727

Region 5 (WI, MM, MI, EL, IN, OH)
230 South Dearborn Street
Chicago, IL  60604
(312) 353-2000

Region 6 (NM, OK, AR, LA, TX)
1445 Ross Avenue
Dallas, TX  75202
(214) 655-6444
Region 7 (ME, KS, MO, IA)
756 Minnesota Avenue
Kansas City, KS 66101
(913) 236-2800

Region 8 (MT, ND, SD, WY, UT, CO)
999 18th Street
Denver, CO 80202-2405
(303) 293-1603

Region 9 (CA, NV, AZ, HI)
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305

Region 10 (AK, WA, OR, ID)
1200 Sixth Avenue
Seattle, WA 98101
(206) 442-5810

Industry & Trade Associations

American Wood-Preservers' Association
P.O. Box 286
Woodstock, MD 21163-0286
(410)465-3169

American Wood Preservers' Institute
1945 Old Gallows  Road, Suite 500
Vienna, VA 22182
(703)893-4005
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                                                       •&U.S. GOVERNMENT PRINTING OFFICE: 1993 - 5SO-OOI/S03I3

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