WOOD PRESERVING RESOURCE
CONSERVATION AND RECOVERY ACT
         COMPLIANCE  GUIDE

    A GUIDE TO FEDERAL ENVIRONMENTAL
              REGULATION
                 JUNE 1996
              Office of Compliance
      Office of Enforcement and Compliance Assurance
         U.S. Environmental Protection Agency
           401 M Street, SW (MC 2221-A)
              Washington, DC 20460
               EPA-305-B-96-001

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                                                                 June 19,1996
                           IMPORTANT NOTICE*******

      This document attempts to explain in one place the sometimes  complex
Federal requirements that wood preserving facilities  are subject to under the
Resource  Conservation and Recovery Act  (RCRA).  This guidance document
should  not be  interpreted as providing changes to existing regulations.  It is
intended only as a clarification of existing regulations. Furthermore,  because the
Guide is designed to summarize, in plain English, the applicable regulations and
to provide additional information sources, it is not a substitute for regulations
published in the Code of Federal Regulations (CFR).  In order to further simplify
the additional  Federal regulations  that  apply to  these  facilities,  background
information on the industry and summaries of other environmental statutes
that effect this industry are included.

      This document was prepared by EPA contractor Booz-Allen  & Hamilton
Inc. in close consultation  with an ad hoc task force composed of EPA and State
inspectors. The document responds to questions raised by industry personnel
via the American  Wood  Preservers Institute.   It  has been  reviewed by the
Association  of State  and  Territorial  Solid   Waste  Management  Officials
(ASTSWMO) and industry representatives associated with the  American Wood
Preservers Institute.

      This Guide is an outgrowth of the U.S. EPA's Office of Compliance  Sector
Guide Project.  During the project, a series of  18 profiles  on  various  industry
sectors  (as' defined by two  digit Standard  Industrial Codes) was developed
containing information of general interest.  The EPA document numbers  of the
profiles range from EPA/310-R-95-001 to EPA/310-R-95-018. This Guide, which is
in extension of  the Profile of the Lumber and Wood  Products Industry (EPA/310-
R-95-006), contains detailed information on the Wood Preserving Industry (SIC
2491).  The goals of the Guide are to provide environmental  professionals with
useful information specific to the wood preserving industry, such as process
descriptions and the geographic distribution of the  industry, and to address in
plain-English many of the regulatory interpretation  questions  that arose out of
the RCRA drip  pad standards and hazardous waste listings.
Cover photo courtesy of Universal Forest Products, Inc.
Introduction                              ii

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                                                                           June 19, 1996
The document can be purchased from the Superintendent of Documents, U.S. Government Printing
Office.
All telephone orders should be directed to:

       Superintendent of Documents      (GPO Stock number: 055-000-00552-4)
       U.S. Government Printing Office
       Washington, DC 20402
       Phone (202) 512-1800
       Fax (202) 512-2250
       8:00 a.m. to 4:30 p.m., EST, M-F
All mail orders should be directed to:

       U.S. Government Printing Office
       P.O. Box 371954
       Pittsburgh, PA 15250-7954
(See order form on last page of this document)
Complimentary volumes are available to certain groups or subscribers, such as public and academic
libraries, Federal, State, local, and foreign governments, and the media.

Electronic versions of the Guide are available on the EPA Enviro$en$e Bulletin Board and via
Internet on the Enviro$en$e World Wide Web. Downloading procedures are described in Appendix
A of this document.

Comments or questions about this Guide should be addressed to;

U.S. Environmental Protection Agency
Wood Products Contact
Manufacturing Energy and Transportation Division (2223 A)
401 M Street S.W.
Washington, D.C. 20460
Phone (202) 564-2300
Introduction

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                                                                June 19,1996
U.S. EPA  would  like to  thank the many  individuals  from  industry  and
government and especially the participants on the EPA/State Wood Preserving
Task Force and the American Wood  Preservers Institute RCRA Task Force for
generously donating  their time  and expertise  reviewing this  Guide.  EPA
recognizes  that not all of those who reviewed the Guide  agree with all of its
content.

Wood Preserving Compliance Task Force Members
State Agency Representatives
Yen Bao
Penny Brown
Gary Calaba
Karen Gates
Martin Herrick
Vonnie Kallemeyen
Viki Leuba
Jim McNamara
Andy Slusarski
Virginia
West Virginia
Oregon
Florida
Wisconsin
South Dakota
Washington
Georgia
Maine
U.S. EPA Representatives
Anthony Carrell
Mike Fagan
Bart George
Bill Hamele
Seth Heminway
Bruce Long
Dan Patulski
Bill Rothenmeyer
Ron Shannon
Mike Silverman
Anna Torgrimson
Headquarters
Region X
Region II
Headquarters
Headquarters
Region X-Oregon
Region V
Region VIII
Region VI
Region X-Idaho
Region IV
Phone
(804) 698-4403
(304) 256-6850
(503) 229-6534
(904) 448-4320 ext. 368
(608) 266-5798
(605) 773-3153
(509) 625-5179
(404) 657-8657
(207) 287-2651
(703) 308-0458
(206) 553-6646
(206) 637-3192
(202) 564-4012
(202) 564-7017
(503) 326-3686
(312) 886-0656
(303) 312-6045
(214) 665-2282
(208) 334-9389
(207) 287-2651
Introduction
                                      IV

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                                                                 June 19,1996
Amercian Wood Preservers Institute Compliance Task Force
Gene Bartlow
President
American Wood Preservers Institute
1945 Old Gallows Rd. Suite 150
Vienna, VA 22182
(703) 893-4005
Scott Conklin
Director of Wood Preservation
Universal Forest Products
2801 East Beltline N.E.
Grand Rapids, MI 49505
(616) 365-1563
Nick Bock
Manager, Environmental Affairs and
Regulatory Compliance
Kerr-McGee Chemical Corp.
P.O. Box 25861
Oklahoma City, OK 73125
(405) 270-2394
Mr. Martin Rollins
President
H. Martin Rollins Company
P.O. Box 3471
Gulfport,MS 39505
(601) 832-1738
Steve Smith
Environmental Manager
Koppers Industries, Inc.
326 Seventh Ave.
Pittsburgh, PA 15219-1800
(412) 227- 2677
Ross Worsham
Senior Environmental Engineer
Atlantic Wood Industries Inc.
P.O. 1608
Savannah, GA 31402
(912) 964-1234
Introduction
                                       v

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                                                                          June 19,1996
                           Table  of  Contents
SECTION 1 - INTRODUCTION	1-1




  Intended Audience	1-2



  Scope of the Compliance Guide	,,	1-2



  Potential for Increased State Stringency	...	1-3



  Using this Guide	1-3



  References to Regulation	1-3





SECTION 2 - OVERVIEW OF THE WOOD PRESERVING INDUSTRY	2-1




  Industry Overview	2-1



  Surface Protection versus Wood Treatment	2-1



  Geographic Distribution of Wood Preserving	2-2



  Wood Preserving Process	2-4



  Oil-Borne Processes	2-5



  Water-Bome Processes	2-8



  Environmental Concerns Associated with Wood Preserving Wastes	2-10



  Health Concerns Associated with Wood Preserving Industry	2-10



  Health Precautions for Plant Personnel	2-12





SECTION 3 - GENERAL OVERVIEW OF RCRA	3-1




  Introduction	,	<	3-1



  Why the RCRA Program was Developed	3-1




  RCRA Program Goals	3-2



  RCRA Subtitle C	3-3



  Identification Of Hazardous Waste	3-3



  Hazardous Waste Under RCRA	'.	3-4



  Characteristic Wastes	3-4










Introduction                                 vi

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                                                                          June 19,1996
                   Table  of Contents  (Continued)
  Listed Wastes	.'.	:	3-5

  Hazardous Waste Mixtures	3-7

  Contaminated Media	3-8

  Derived-from Hazardous Waste	...3-8

  Acutely Hazardous Waste	3-9

  Generators Of Hazardous Waste	3-9

  Episodic Generation	3-11

  Hazardous Waste Counting	3-11

  General RCRA Requirements for Generators of Hazardous Waste	3-13

  EPA Identification Number	3-13

  Pre-Transport Requirements	3-14

  Accumulation Requirements	3-14

  Large Quantity Generators	3-14

  Treatment in Generator Accumulation Units	3-15

  RCRA Air Emission Standards	3-15

  Small Quantity Generators	3-15

  Conditionally Exempt Small Quantity Generators	3-16

  Satellite Accumulation	3-17

  Storage Requirements	3-18

  Combined Use of Drip Pads, Containers, and Tanks/Sumps at
  Wood Preserving Facilities	3-19

  Manifest Requirements	3-20

  Personnel Training	3-21

  Contingency Plans	3-21

  Recordkeeping and Reporting Requirements	3-22



Introduction                                  vii

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                                                                       June 19,1996
                  Table  of Contents (Continued)
  Land Disposal Restrictions	3-24




  Waste Subject to LDR Requirements	3-26




  RCRA Permitting	3-26




  Permit Exemptions	3-27




  Permitting Standards	3-27




  Permit Applications	3-28




  Wood Preserving Facilities and Permits	3-29




  Closure Requirements at Permitted Facilities	3-29




  Post-Closure Requirements	3-30




  Closure of Wood Preserving Facilities	3-30




  Underground Storage Tanks	3-31




  State Authorization	3-32





SECTION 4 - RCRA WASTE GENERATED BY WOOD PRESERVING	....4-1




  Introduction	4-1



  Health Concerns of Wood Preserving Wastes	4-1




  Wastewater	4-3




  Process Residuals	4-4




  Drippage and Process Residuals	4-5




  Contaminated Clothing and Other Materials	4-5




  Hazardous Wastes Generated by Wood Preserving Operations	4-6




  Exclusions from the Definition of Solid Waste	4-9




  Closed Loop Recycling	4-9




  Direct Use/Reuse	4-10




  Reclaimed Spent Wood Preserving Solutions	4-11







Introduction                                viii

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                                                                         June 19,1996
                   Table of Contents  (Continued)
  Wood Preserving State Authorization Issues	:	4-14




  Pollution Prevention Opportunities	4-17




  Pollution Prevention Case Study	4-19




  Frequently Asked Questions	4-20





SECTION 5 - DRIP PADS	5-1




  Introduction	5-1




  New vs. Existing Drip Pads	5-2




  Drip Pad Design Standards	5-2




  Sealed Drip Pads	5-6




  Drip Pad Liners	5-6




  Leak Detection Systems	5-7




  Liquid Collection Systems	5-7




  Run-on and Run-off Control	'.	5-8




  Drip Pad Operation	5-8




  Temporary Accumulation of Hazardous Waste on Drip Pads	5-9




  Assessment of Drip Pad Integrity	5-10




  Existing Drip Pads	5-10




  New Drip Pads	5-12




  Inspections	5-13




  The Operating Log	5-14




  Releases of Hazardous Waste from Drip Pads	5-15




  Contingency Plans	5-16




  Closure of Drip Pads	5-17




  Frequently Asked Questions	5-17








Introduction                                 ix

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                                                                    June 19,1996
                 Table of Contents  (Continued)
SECTION 6 - STORAGE YARDS	6-1




  Introduction	6-1



  Stormwater Run-off in Storage Yards	6-2





SECTION 7 - TANKS AND SUMPS	7-1




  Introduction	7-1



  New vs. Existing Tanks	7-2



  Assessment of Existing Tanks	7-2



  Assessment of New Tanks	7-3



  Corrosion Protection	7-3



  Leak Detection and Secondary Containment	7-4



  Leak Detection Systems	7-5



  Secondary Containment Devices	•	7-5



  Exemption from Secondary Containment Requirement	7-6



  Secondary Containment for Ancillary Equipment	7-6



  Operating and Maintenance Requirements	7-7




  Inspections	7-7



  Response to Releases..	7-8



  Closure	7-8



  Underground Storage Tanks	7-9





SECTION 8 - ADDITIONAL STATUTORY REQUIREMENTS	8-1




  Clean Water Act	.....8-1



  NPDES Program	8-1



   Stormwater Discharges	8-2



  Pretreatment Program	8-3








Introduction                               x

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                                                                       June 19, 1996
                   Table of Contents (Continued)
   Federal Insecticide, Fungicide, and Rodenticide Act	8-4



   Clean Air Act	             g_5




   Comprehensive Environmental Response, Compensation and Liability Act	8-8




   Emergency Planning and Community Right-to-Know Act	8-9



   Safe Drinking Water Act	8-11




   Hazardous Materials Transportation Act	8-12




   Pollution Prevention Act	,	8-13




   Toxic Substances Control Act	;	8-13
Introduction                                xi

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                                                                 June 19,1996
                          List  of Exhibits
Exhibit 1
Exhibit 2
Exhibit 3

Exhibit 4

Exhibit 5
Exhibit 6
Exhibit 7

Exhibit 8

Exhibit 9
Exhibit 10
Exhibit 11

Exhibit 12

Exhibit 13

Exhibit 14
Exhibit 15
Exhibit 16
Exhibit 17
 2-7
Geographic Distribution ,of Wood Preserving Facilities	2-2
Industry Facility Size Distribution - 1992	2-3
Wood Preserving Facility Process Schematic (oil-borne
preservative)	.	
Wood Preserving Facility Process Schematic (water-borne
preservative)	.'.*	2-9
Hazardous Waste Identification	3-7
Code of Hazardous Waste Counting	3-12
Requirements  for Wood Preserving Facilities
that are Generators of RCRA Hazardous Waste	3-23,24
Relationship Between State Authorization Status and
HSWA/Non-HSWA Rulemakings	3-34
Wood Preserving Process Inputs and Pollution Outputs	4-2
Hazardous Waste Generated at Wood Preserving Facilities	4-7
Wood Preserving Hazardous Waste Code
Identification Table	4-8
Codes of Hazardous Waste Identification for the Wood
Preserving Industry	
State Authorization/Delegation of RCRA Wood
Preserving Rules	4-15
Side View of Typical Drip Pad	5-5
Front View of Typical Drip Pad	5-5
Drip  Pad Construction and Certification Requirements	5-13
Responding to Drip Pad Cracks	5-14
.4-13
 Introduction
                                       Xll

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                                                              June 19,1996
Appendix A
Appendix B
Appendix C

Appendix D
Appendix E
Appendix F
                       List  of Appendices
Instructions on Electronic Access to this Guide
Contact Lists
Facility Checklist - RCRA Recordkeeping and Reporting
Requirements for Wood Preserving Facilities
Subpart W (Drip Pad) Checklist
Tank Systems Checklist for Generators (Subpart J)
Facility Checklist - Other Laws
Introduction
                                    Xlll

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                                                             June 19,1996
                       List  of  Acronyms
ACA
ACC
ACQ
ACZA
ARARs
ASTSWMO

AWPI
CAA
CAP
CBA
CC
CCA
ODDC
CERCLA


CFR
as
CWA
DOT
EHS
EPA
EPCRA

FIFRA
FR
HAPs
HSWA

LDR
LEPC
LOG
MSDS
Ammonical Copper Arsenate
Acid Copper Chromate
Ammonical Copper Quat
Ammonical Copper Zinc Arsenate
Applicable or Appropriate Requirements
Association of State and Territorial Solid Waste
Management Officials
American Wood Preservers Institute
Clean Air Act
Consumer Awareness. Program
Copper Azole
Ammonical Copper Citrate
Chromated Copper Arsenate
Copper Dimethyldithiocarbomate
Comprehensive Environmental Response,
Compensation, and Liability Act (commonly known
as Superfund)
Code of Federal Regulations
Consumer Information  Sheet
Clean Water Act
U.S. Department of Transportation
Extremely Hazardous Substance
U.S. Environmental Protection Agency
Emergency Planning and Community Right-to-
Know Act
Federal Insecticide, Fungicide, and Rodenticide Act
Federal Register
Hazardous Air Pollutants
Hazardous and Solid Waste Amendments (to
RCRA)
Land Disposal Restrictions
Local Emergency Planning Committee
Large Quantity Generator
Material Safety Data Sheet
Introduction
            XIV

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                                                                 June 29, 2996
 NESHAPs

 NFPA
 NIOSH

 NOI
 NPDES
 NPL
 NRC
 NSPS
 OSHA
 PE
 PEL
 POTW
 PPE
 RCRA
 RQ
 SARA
 SDWA
 SERC
 SIP
 SQG
 TCLP
 TPQ
 TSCA
 TSDF
 TRI
 UIC
 UST
 WAP
 National Emission Standards for Hazardous Air
 Pollutants
 National Fire Protection Association
 National Institute for Occupational Safety and
 Health
 Notice of Intent
 National Pollutant Discharge Elimination System
 National Priorities List
 National Response Center
 New Source Performance Standards
 Occupational Safety and Health Act/Administration
 Professional Engineer
 Permissible Exposure Limit
 Publicly-Owned Treatment Works
 Personal Protective Equipment
 Resource Conservation and Recovery Act
 Reportable Quantity
 Superfund Amendments and Reauthorization Act
 Safe Drinking Water Act
 State Emergency Response Commission
 State Implementation Plan
 Small Quantity Generator
 Toxicity Characteristic Leaching Procedure
 Threshold Planning Quantity
 Toxic Substances Control Act
 Treatment, Storage, and Disposal Facility
Toxic Release Inventory
Underground Injection Control
Underground Storage Tank
Waste Analysis Plan
Introduction
                                      xv

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 Introduction
                               Section  1
                            Introduction
 The United States Environmental  Protection Agency
 (EPA) has developed  this Wood  Preserving  RCRA
 Compliance Guide to provide summary information
 on  the  statutory  and   regulatory  requirements
 applicable to  wood  preserving   facilities.    The
 document was developed for facilities that use, or
 have used, wood preserving chemicals and have the
 potential  to  generate waste  that  is  considered
 hazardous under the Resource Conservation  and
 Recovery Act (RCRA).  After  numerous  inspections
 of wood preserving facilities, EPA has  found  that
 although many  plants do effectively control their
 wastes and comply with environmental regulations,
 some do not. The purpose of the Guide is to help
 bring non-compliant  facilities  into compliance  by
 providing  guidance  and  references  to  applicable
 Federal environmental regulations.  In addition,  it
 will serve as a  reference tool for those  facilities
 already in compliance  so that owners/operators may
 fine tune their understanding of these regulations.

 This Guide was developed by  a task force consisting
 of EPA  and State  inspectors, and was a collaborative
 effort   between    these   groups.     In   addition,
 representatives of the wood preserving industry were
 consulted about the questions that  frequently arise
 within the industry and the information that would
 be most useful for Guide readers.  The Guide  has
 been reviewed by  EPA and State inspectors as well as
 representatives  of the American  Wood  Preservers
 Institute (AWPI).  EPA would like to thank  all of
 those who participated in the review process.

Although  the   Guide focuses  on requirements
imposed   under   RCRA's    hazardous    waste
management  regulations,  it  also  provides  brief
summaries of other environmental  statutes that may
affect the wood preserving industry.  Explanations of
regulatory  requirements   should  help  to  build  a
common base upon which both  EPA inspectors and
Introduction
         Section 1-1

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                                                                 June 19,1996
Intended Audience
Scope of the
Compliance Guide
members  of the regulated community  can  form
consistent interpretations of the Federal regulations.

 The discussions  of the statutes and regulations in
this document are not intended to be exhaustive, but
have been designed to be  used for quick reference.
They are not meant  to  replace in-depth analysis of
statutes, regulations, or EPA guidance, and  should
not be considered a replacement for knowledge of the
regulations  contained  in  the  Code   of   Federal
Regulations (CFR).  This document does not change
or supersede existing regulations, but rather seeks to
clarify them.

This  document   has   been  prepared  for  wood
preserving  facilities  in  the  United  States.   It  is
intended to provide an easy to understand summary
of   the    Federal   environmental    compliance
requirements  under  RCRA   that  regulate wood
preserving facilities.  EPA hopes that this Guide will
assist facility personnel by providing the information
they need to achieve and maintain  compliance with
applicable  environmental  regulations.   EPA  also
anticipates that the information presented here will
be useful to Federal, State, and local  inspectors who
may not be familiar with wood preserving processes
and the various management practices  employed by
the industry.

The Guide provides a general overview of the wood
preserving  industry in  the  United  States  and the
Federal environmental  regulations  with which the
industry must comply.  It is written primarily  for
those   owners/operators  of   facilities   that   are
 generators of  RCRA hazardous waste, not  facilities
 that  have  RCRA permits,  are  operating under
 interim status (see permitting  discussion in Section
 3), or that  do not generate hazardous waste at all
 (some wood  preserving facilities use  chemicals  in
 their processes that do not generate hazardous waste).
 The  following  information  is contained  in this
 Guide:

 •   Size  and   geographic  distribution  of  wood
     preserving facilities in the United States
 •   General  overview  of RCRA requirements
 Introduction
                                    Section 1-2

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                                                                    June 19,1996
 Potential for Increased
 State Stringency
Using this Guide
References to
Regulation
 •    Types of wastes generated at wood preserving
      facilities
 •    Environmental  compliance concerns relating to
      drips pads, tanks and sumps, and storage yards at
      wood preserving facilities
 •    Additional relevant environmental statutes and
      regulatory schemes
 •    Answers   to   commonly   asked   questions
      concerning regulatory requirements
 •    Names and  phone  numbers  of  organizations
      that can provide additional information.

 It is important to note that State and local restrictions
 concerning wood preserving facilities may, in fact, be
 more stringent than  Federal regulations.  Individual
 State requirements are not discussed in this Guide,
 but may be applicable to facilities  within that State.
 Thus, it is imperative that owners/operators of wood
 preserving facilities  seek  additional  guidance in
 determining the applicability of more stringent State
 and local requirements. State authorization issues as
 they  directly apply to the wood preserving industry
 are discussed  in more  detail in  Section 4  of  this
 Guide.

 In  addition to  a detailed  description  of  RCRA
 regulations  that  apply  to  the  wood  preserving
 industry, this Guide also contains a general summary
 of other aspects of the Federal RCRA program and its
 regulations. Readers  who have  extensive experience
 with  wood preserving facilities  may choose to skim
 over  Section  2   (overview  of  wood  preserving
 industry)  and  Section 3  (overview of  RCRA),  and
 focus on  Sections  4 through 7  (wood preserving
 wastes and regulations applicable to wood preserving
 facilities).

 The end of each section contains a shaded box with
regulatory citations  and  references to  information
discussed  in  that  section.   Please consult  these
regulations and other references for a more in-depth
discussion of applicable requirements.
Introduction
                                   Section 1-3

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                                  ^^^^^^^^•^^^•^^^^•i^^M
                                Section  2
      Overview  of the  Wood  Preserving  Industry
 Industry  Overview
 Surface Protection
 versus Wood
 Treatment
 Note: This section  has  been  included  to give  State
 and  EPA inspectors  at  wood preserving facilities  a
 brief  overview  of  the  industry.   Much   of the
 information   presented  in  this section  is common
 knowledge   to  members  of the   wood  preserving
 industry.

 The purpose of wood preserving, also  called wood
 treatment, is to provide long-term protection  from
 the damaging effects of fungi,  insects,  and  marine
 borers, thereby extending the  usable life of  wood
 products.    This  is  accomplished  through  the
 application  of  an  EPA  registered  preservative
 solution to timber. Wood treatment is different from
 surface protection processes in that surface protection
 is characterized by non-pressure applications to the
 surface of the  wood  that are designed  to  provide
 short-term cosmetic protection against mold  and sap
 stains.    Wood  preserving,  on  the other hand,
 involves  the penetration of preservative solutions
 into wood to  preserve  its structural integrity and
 improve  its resistance  to weathering,  water,  and
 ground contact. Wood surface protection and wood
 preserving  are often confused since,  historically,
 chlorophenolic  formulations were  used in   both
 processes.   Chlorophenolic  formulations  are  now
 only used in wood preserving.  In addition, while
 EPA has chosen to specifically identify wastes  from
 the    wood    preserving    industry   that   use
 chlorophenolic  formulations  as hazardous  wastes,
 the Agency also concluded  that  the regulation of
 chemicals that are now used in surface protection is
 not warranted on the Federal level.

 Almost all timber is processed in  some  way before
 being  sold.   The following  wood products  are
 normally  treated in a preservation  process  before
 commercial distribution: dimensional lumber  (i.e.,
 lumber that has been cut to a specific shape or size)
 that will endure prolonged exposure to the ground or
weather,  railroad  ties, telephone  poles,  telephone
Industry Overview
         Section 2-1

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                                                                      June 19,1996
  Geographic
  Distribution of
  Wood Preserving
                           cross  arms,  bridge  beams,
                           doors, and pilings.
                                                      fencing,  window  sills,
                        Wood  preserving facilities  are located in  varying
                        numbers  in almost every State.   As indicated  in
                        Exhibit 1, the highest concentration of facilities is in
                        the Southeast and Northwest where there is a ready
                        supply of raw wood.  Exhibit 2 illustrates the size of
                        wood preserving operations in the industry.
                                    Exhibit 1
             Geographic Distribution of Wood Preserving Facilities
             figures were compiled through consultation with field personnel in each i
             live confirmation was not done on the number of facilities in all States, mt
Source:  These
Because exliaus
,.. Jtate or EP/	0—
these numbers should be
Industry Overview
                                   Section 2-2

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                                                                    June 19,1996
                                   Exhibit 2
                    Industry Facility Size Distribution -1992
Type of Facility
SIC 2491 - Wood
Preserving
Facilities
with 1 to 19
employees
307
Facilities
with 20 to 99
employees
168
Facilities with
100 or more
employees
11
Total
486
source: tsasea on
                                     Bureau of the Census Data.
                           According to 1992 census  data, of the  total of 486
                           wood preserving facilities, a large portion  of  them,
                           approximately 63 percent, employed between 1 and 19
                           people,  34 percent employed between 20 and  99
                           people, and 2 percent of the facilities employed over
                           100 people. The bulk of wood preserving facilities are
                           small operations,  that are  usually  supplied  with
                           preservative formulation  by several larger national
                           chemical  companies.     The  chemical   supply
                           companies frequently offer their clients training and
                           guidance  on   complying  with   environmental
                           regulations as well as professional  services such as
                           hazardous  waste  management  and  engineering.
                           There also appears to be  a trend  in  the  industry
                           toward  larger  companies  acquiring  independent
                           wood preserving companies  and operating them  as
                           subsidiaries.

                           Note: EPA has  not attempted to reconcile the Bureau
                           of the Census data with its own facility count.   This
                           data  is  mentioned    because  it  gives  a  valuable
                           indication  of the relative  size of wood preserving
                          facilities.
Industry Overview
          Section2-3

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                                                                  June 19,1996
Wood Preserving
Process
The  preservation  process  that  is  applied • to  a
particular bundle, or charge, of wood varies with the
type of wood being treated and any particular product
specifications  that the  wood treater may need to
consider (e.g., wood that is used for construction of
outdoor  structures  warrants a higher  degree of
protection due to prolonged exposure to  climatic
elements).    Wood  is porous  and  each  wood
preserving process takes  advantage  of this fact to
impregnate the wood with  preservative.   In most
cases,  the  process   begins   with  a  preliminary
conditioning step that assures a prescribed moisture
content in the wood.  Less  moisture  allows  more
preservative to penetrate  and remain in the wood,
providing increased protection.

To change the moisture content, a variety of steps can
be taken.  These include: air  or kiln drying; Boulton
drying, which consists of pulling  a vacuum on the
treating cylinder while the wood  is immersed  in a
heated oil-borne  solution;  or steam conditioning,
which  consists of heating the wood  in the  treating
cylinder with  steam for several hours  then rapidly
vacuuming the wood  to  remove moisture.    The
pressure   or   treatment    cylinder   where   the
preservative   is  actually  applied  to the  wood is
commonly called a retort.

After conditioning, preservative  solution is applied
to the wood. Most facilities use pressurized cylinders
(retorts) to apply  the preservative solution.   This
involves placing charges of wood into the retort and
applying the preservative  under  a pressure system
until sufficient  penetration  and  retention  of  the
preservative   into  the wood has occurred.    The
desired degree  of  penetration  and  retention is
determined by prescribed product specifications  and
will  dictate how long the pressure is applied. Excess
preservative  is drawn from the  wood  through  a
vacuum  system, and pumped back into the process
tank, where it  will be used again in the same process.

A small percentage of facilities  use non-pressurized
dip  tanks  to  treat  wood.   This  involves  simply
lowering  the  charges  into  a vat of  preservative,
usually an oil-borne preservative. The charge is then
Industry Overview
      Section 2-4

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                                                                    June 19,1996
Oil-Borne Processes
allowed to soak in the vat  until  a  predetermined
degree  of penetration is reached.   Penetration is
sometimes  aided by heating and then  cooling  the
preservative.

There are a number of common pressure processes
currently used by the wood  preserving industry to
treat  wood.  These include full-cell,  modified full-
cell, and empty-cell processes.   Also,  a variety  of
preservatives are used, which are either water- or  oil-
borne.  The different wood preserving processes and
solutions are discussed below.

Two primary types of pressure vacuum treatments,
empty-cell and full-cell, are used to apply oil-borne
preservatives.  Examples of oil-borne preservatives
include  creosote,   creosote  petroleum   mixtures,
copper napthenate, and pentachlorophenol. Creosote
is commonly used  to treat railroad ties, telephone
poles,   pilings,    and   bridge   beams,   while
pentachlorophenol is most often mixed into solution
with oil to treat telephone poles.

The most widely used process is called empty-cell.  In
this process, the cells of the wood are merely coated
with  preservative.   The  empty-cell process  obtains
deep  penetration  of preservative  and  attempts  to
leave the  cell walls  of  the  wood  treated, while
leaving a minimum  of excess preservative  in  the
void spaces of the cells. Because a smaller amount of
preservative  is  used  compared  to  the   full-cell
processes, the product is lighter and  easier to ship.
The empty-cell process also results in  less expensive
treatment costs for the facility since  less  preservative
remains in the wood.

One type of empty-cell process is  the Lowry  process,
which entails filling  the  retort  with  preservative
while maintaining atmospheric pressure. When  the
retort is filled with preservative, pressure is applied,
forcing preservative into the wood.  This compresses
the air contained in the cells of the wood, allowing
preservative to fill  the balance of the cell.  Once  the
desired  amount of preservative  has  been injected,
usually over the course of several hours, the retort is
drained and  a final vacuum is applied.  During this
Industry Overview
      Section 2-5

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                                                                   June 19,1996
                          last step, much  of the preservative  in the cells  is
                          forced out by the  remaining air in the cells of the
                          wood, which expands as it is subjected to the vacuum
                          and  then  returned  to ambient  pressure.    This
                          vacuum also minimizes drippage after the  charge  is
                          removed from the retort and is placed onto the drip
                          pad.

                          The  most  widely  used empty-cell  process  is  the
                          Rueping process in which air pressure is applied and
                          maintained  in  the retort prior to filling the  retort
                          with preservative.   When  the retort is  completely
                          filled with preservative, pressure is applied to force
                          the solution into  the wood.   Once the pressure  is
                          released, the retort is drained and the final vacuum is
                          applied. As a result of internal pressure, even more
                          preservative is forced out of the wood than in the
                          Lowry process.

                          The second  type of wood preserving process is called
                          the full-cell  (or Bethell) process because it results in a
                          higher retention level by nearly filling the wood cells
                          with preservative.  In this process, most of the air in
                          the retort is pumped out, creating a strong vacuum
                          which is then held to draw most of the  air out of the
                          wood. The  retort is then  filled  with preservative
                          without breaking the vacuum,  forcing preservative
                          into  the  cell spaces that have  been created  by the
                          evacuated air.  When  the retort is completely filled
                          with preservative,  pressure  is applied to force the
                          solution  into  the wood.   Once the  pressure   is
                          released, the preservative is pumped out of the retort
                          and  a final vacuum  is drawn  to force out  excess
                          preservative. When  the vacuum is released, much
                          of the remaining surface preservative is drawn back
                          into the wood, reducing the amount of drippage once
                          the charge  is taken  out of the  retort.   Exhibit 3
                          illustrates the oil-borne wood preserving process.
Industry Overview
Section 2-6

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                                                                                    June 19,1996
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Industry Overview-
Section 2-7

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                                                                   June 19,1996
Water-borne Processes
Full-cell  and modified full-cell processes are used to
apply  water-borne  preservatives.    The   full-cell
process utilized  at water-borne  facilities   is  very
similar to that used for oil-borne preservatives. The
modified full-cell process applies a weaker, or lower,
initial vacuum to retain more  air in the cells of the
wood.    Once the pressure  treatment  phase  is
complete, the remaining air (now expanding because
pressure has stopped)  displaces the  preservative
which is, in turn, forced out of the wood. By forcing
more  preservative  out  of  the  wood, weight  is
minimized   and  subsequent   shipping costs  are
reduced. Exhibit 4  illustrates the  water-borne  wood
preserving processes.
                          Water-borne preservatives contain active ingredients
                          that  are  inorganic metal oxides, or  less frequently
                          salts, and are commonly used to treat dimensional
                          lumber  and  telephone  poles.     This   type  of
                          preservative  includes   oxine  copper,  ammonical
                          copper  citrate  (CC), copper  azole  (CBA),  copper
                          dimethyldithiocarbomate (CDDC), chromated copper
                          arsenate  (CCA),  ammonical copper arsenate  (ACA),
                          acid  copper chromate (ACC), ammonical copper zinc
                          arsenate  (ACZA), and ammonical copper quat (ACQ).
                          As this Guide will discuss, wastes that are generated
                          by wood preserving  facilities,  especially those using
                          creosote,    chlorophenolic,    or    arsenical-based
                          preservatives, have  the potential to be considered
                          hazardous waste under  RCRA.  Wastes  commonly
                          generated in  the wood  preserving  industry  are
                          discussed in more detail in Section 6 of this Guide.
Industry Overview
      Section 2-8

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                                                                             June 19,1996
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Industry Overview
Section 2-9

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                                                                 June 19,1996
Environmental
Concerns Associated
with Wood
Preserving Wastes
Health Concerns
Associated with Wood
Preserving Industry
Past mismanagement  of  toxic chemicals  at  wood
preserving   facilities   has   caused   significant
contamination of soil and ground water at some sites.
As of May 1996, more than 45 wood preserving sites
had been  placed on Superfund's National  Priorities
List  (NPL) for priority cleanup of  contamination.
The  majority  of contamination  has been  found at
older facilities  that operated for many  years before
current environmental  regulations  and  disposal
options existed.    Along  with .other  poor  waste
management  practices, contamination  is  generally
caused by excess preservative, called kickback, that
has been  allowed to  drip  onto  the ground from
treated charges of wood.

A growing concern over the presence of dioxins  and
furans  in chlorophenolic   wastes  found  at  some
facilities,  coupled  with the  desire to  prevent  the
release of arsenic into the  groundwater,  has led EPA
to regulate the wood preserving  industry   under
RCRA.    In  1990,  the  first  RCRA   regulations
specifically addressing many wood preserving wastes
were published.  These standards require owners/
operators  of many wood preserving operations to
comply with RCRA.  Subsequently, EPA  promulgated
rules requiring tighter management of hazardous
waste generated by the wood preserving industry.  As
a result, many facilities in the industry have invested
heavily in cleaning up existing contamination  and
complying  with   regulatory standards  for  facility
construction and proper waste management.

The primary  reason  behind RCRA's  preservative
containment requirements  is to keep  preservative
chemicals  out of  ground  and  surface  waters.
Contamination of soil and groundwater is a  serious
problem because it can move considerable distances
as it is picked up by water moving  through the soil
and the water table.  Because there  are few, if  any,
naturally  occurring organisms in  the environment
that can readily break down these chemicals.   Once
the  contamination  enters  the  ground it has  the
potential  to linger  for long periods of time  and cause
extensive contamination to surrounding subsurface
environments.
 Industry Overview
      Section 2-10

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                                                                  June 19,1996
                          The  wood   preservatives  creosote,  pentachloro-
                          phenol,  and  inorganic   arsenicals  contain   toxic
                          constituents  that have the potential  to cause  skin,
                          eye, and respiratory irritation as well as more serious
                          ailments  in humans, if humans are overexposed to
                          them.    Some   of  these constituents  have   been
                          classified  as  carcinogens through  epidemiological
                          exposure studies on  animals.   Exposure  of aquatic
                          plant and animal life to these  toxic constituents has
                          also been found to have adverse effects.

                          Toxic constituents in wastes generated by the  wood
                          preserving industry have been found to have chronic
                          systemic  effects  on laboratory animals as  well as
                          humans and have been determined to be present in
                          sufficient concentrations to pose a substantial threat
                          to  human health  and  the  environment.     For
                          example,  previous studies  of pentachlorophenol
                          have shown  it  to be  highly  toxic to  humans.
                          Exposure  to  pentachlorophenol  can cause contact
                          dermatitis, damage to  vision,  and  upon  ingestion,
                          lung,  liver,   and kidney damage.   Inhalation  of
                          pentachlorophenol can result  in  acute  poisoning,
                          centering  on  the circulatory  system  with possible
                          accompanying heart  failure.    Other studies  have
                          shown pentachlorophenol to be a carcinogen.

                          One of  the most  commonly used preservatives in the
                          wood  preserving  industry  is  chromated  copper
                          arsenate,  or CCA. This formulation contains water,
                          arsenic   acid,  chromic   acid,  and   copper  oxide.
                          Overexposure   to  CCA  can   damage   mucous
                          membranes and tissues of the respiratory system and
                          cause chemical  burns  on the skin and  even  skin
                          lesions.   Ingestion of large amounts of CCA  may
                          have more serious effects.   Chronic exposure  to
                          significant doses  of the chemical components of CAA
                          can lead to mental confusion,  loss  of coordination,
                          and impaired  senses of touch, pain, and temperature.
                          CCA is  also considered a possible carcinogen.

                          From this data, it is clear that many of the  chemicals
                          used in  the  wood preserving industry  have  the
                          potential  to threaten human health when handled in
                          an unsafe manner.  As  a result, it is crucial  that plant
                          employees, and anyone else coming into contact  with
Industry Overview
Section 2-11

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                                                                      June 19,1996
Health Precautions for
Plant Personnel
preservative solutions containing these constituents,
be extremely cautious when handling the chemicals.
Some   recommended  precautions   are  discussed
below.

In order to minimize  exposure to wood preserving
chemicals, operators of wood treatment  equipment
should   closely  follow  company  policy  and  all
applicable  Federal,  State,  and  local  regulations
concerning use and management of those chemicals.
At a minimum, facility personnel should:

•    Use preservatives in accordance with  the EPA
     approved manufacturer's label.
•    Follow pesticide label and Occupational  Safety
     and   Health  Act  (OSHA)  requirements  for
     personal protective equipment.
•    Avoid direct  contact with  the  chemicals  by
     wearing  protective gloves and washing hands
     and  other   exposed skin before  eating,  using
     tobacco products, or using the rest room.
•    Enter the retort or other  confined space only in
     accordance with an OSHA confined space entry
     plan.
•    Wear a respirator in process areas at inorganic
     arsenial  wood treating  plants, unless PEL air
     monitoring has demonstrated that it is safe not
     to wear one.
Additional information is available on the subjects discussed above:
       For more information on the wood preserving process, consult The Preservation of Wood, A
       Self Study Manual for Wood Treatment. Revised by F. Thomas Milton, University of
       Minnesota, College of Natural Resources, Department of Forest Products, 1994.
       Preservative Treatment of Wood by Pressure Methods.  ID, McLean, USDA Agriculture
       handbook, No. 4D, December 1952 (Reprinted with corrections September 1960).
       Wood as an Engineering Material: Wood Handbook. Chapters 17-19. USDA Agriculture
       Handbook, No. 72, Revised 1974.
       Wood Deterioration and its Prevention by Preservative Treatment. Darrel D.. Nicholas,
       editor, with the assistance of Wesley E. Loos, Syracuse University Press, 1973 (two
	volumes).	
Industry Overview
      Section 2-12

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                              Section  3
                 General  Overview  of  RCRA
Introduction
Why the RCRA
Program was
Developed
This section of the Compliance Guide contains a basic
discussion  of  the requirements  imposed  on wood
preserving  facilities by RCRA.   This  section  will
cover the following general topics:

•    Why the RCRA program was developed
•    Identification of hazardous waste
•    Generators of hazardous waste
•    Hazardous waste management
•    Land disposal restrictions
•    RCRA permitting
•    Closure of hazardous  waste management units
•    Underground storage  tank requirements
•    State authorization.

Note: Readers who  are already  familiar  with  the
RCRA program may  not find  it  necessary  to read this
section of the Guide, but rather, should move directly
to Section 4.

RCRA, an  amendment to  the Solid Waste  Disposal
Act, was enacted in 1976 to  ensure the safe disposal  of
the huge volumes of municipal and industrial  solid
waste  generated  nationwide.     RCRA  has  been
amended   by  Congress   several   times,   most
significantly in November 1984, by the Hazardous
and Solid  Waste Amendments   (HSWA).   These
amendments  significantly  expanded the scope, and
requirements  of RCRA, resulting in the regulation  of
much of the  waste  generated in this country,  both
hazardous and non-hazardous.

Many of the wood preserving facilities in the United
States were in operation long before  the inception  of
the RCRA  program.   Although RCRA  creates  a
framework  for the proper management of hazardous
and non-hazardous waste, it does not directly address
the problems  of hazardous waste  associated  with
inactive or abandoned sites, or spills of chemicals
that may require emergency response.  Many wood
preserving sites, both inactive and operating, already
RCRA Overview
         Section 3-1

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                                                                June 19,1996
RCRA Program
Goals
                         contain    significant   soil   and    groundwater
                         contamination  as a result of years of chemical  use
                         prior to the enactment of environmental regulations.
                         RCRA's Corrective  Action  Program  plays a role in
                         requiring    the   cleanup   of   such   historically
                         contaminated  sites; however,  this type of problem
                         can  also  be addressed under  the Comprehensive
                         Environmental   Response,   Compensation    and
                         Liability Act'(CERCLA). CERCLA, commonly known
                         as Superfund, mandates  the cleanup of  historically
                         contaminated  sites.  In addition to such remedial
                         activities,  Superfund also requires owners/operators
                         of facilities to notify EPA in  the event of  a release of
                         certain hazardous substances into the environment.
                         See  Section  8  for   more  information  on  the
                         Superfund program.
The  RCRA program is based upon  three  distinct
goals aimed  at  creating  a  safe   and effective
hazardous waste management system. They are:
    •   Protection  of  human  health  and  the
        environment
    •   Reduction of waste  and conservation  of
        energy and natural resource
    •   Reduction or elimination of the generation
        of hazardous waste.
                         RCRA is divided into ten sections,  or subtitles, that
                         provide  EPA  with a framework to  achieve  these
                         goals.    For  example,  Subtitle  D  governs   the
                         management  of non-hazardous solid waste, while
                         Subtitle  I  creates  a  regulatory  program  for  the
                         management of underground storage tanks.  Subtitle
                         C, which addresses hazardous waste management, is
                         the subtitle which has  the  greatest impact on  the
                         regulation of wood preserving facilities.
RCRA Overview
        Section 3-2

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                                                                  June 19, 1996
 RCRA Subtitle C
Identification of
Hazardous Waste
 Subtitle C of RCRA establishes a "cradle-to-grave"
 management system for controlling hazardous waste
 from its point of generation to final  disposal.   The
 objective of Subtitle  C is  to ensure  that hazardous
 waste is handled in a manner protective of human
 health and the environment. Pursuant to Subtitle C,
 EPA has issued regulations regarding the generation,
 transportation, treatment, storage, and disposal of
 hazardous  waste.    Facilities  affected  by  these
 regulations  must  be maintained and operated in a
 manner that will minimize danger to human health
 and the environment.  Many of the regulations  that
 specifically  address the wood  preserving  industry
 concern   the    construction,   operation,    and
 maintenance of hazardous waste drip pads.  These
 drip  pad  requirements  are  found  in a specific
 subsection of Subtitle  C called  Subpart W. Those
 within  the wood preserving  industry  commonly
 refer  to the drip pad regulations as the "Subpart W
 standards" or  "RCRA Subpart W."

 Subtitle C is discussed in greater detail below.  Both
 the general requirements  of Subtitle C, as well as
 those specific  to the  wood preserving industry, are
 included.

 The  regulatory   framework   established   under
 Subtitle C of RCRA was designed to protect human
 health  and  the environment  from  the effects of
 improper management  of hazardous waste.  As a
 result, identifying whether a waste is hazardous is
 crucial  in  determining  the  applicability   of  the
 Subtitle C regulations.

Wastes   are  considered   hazardous   for   different
reasons, and the responsibility for  determining  if  a
particular waste is hazardous falls on the generator of
that waste (see the  discussion  of  hazardous waste
generators in Section 4).

In general, RCRA  defines hazardous waste as a solid
waste, which because of its quantity, concentration, or
physical or chemical characteristics may:

 •   Cause or  contribute  to  significant injury or
    death, or
RCRA Overview
         Sections-3

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                                                                  June 19,1996
Hazardous Waste
Under RCRA
Characteristic Wastes
•    Damage or pollute the land, air, or water.

A solid  waste, defined by RCRA as any material
including liquids, sludges, and contained gases that is
disposed, burned, or recycled in a certain manner, is
considered hazardous if it:
                               Exhibits  any one of  the characteristics  of a
                               hazardous waste
                               Has been specifically listed as a hazardous waste
                               in the regulations
                               Is a mixture containing a listed hazardous waste
                               and a non-hazardous waste
                               Is a waste derived from  the  treatment, storage,
                               or disposal of a listed hazardous waste.
Each of these four categories is discussed in greater
detail below.

Characteristic wastes, as defined  under  RCRA,  are
identified by a specific number, or  waste code, that
begins with the letter "D."  A waste is hazardous if it
exhibits one or more of the following characteristics:

•   Toxicity (D004-D043)—The toxicity characteristic
    identifies a list of constituents that, if present in
    concentrations greater than specified levels,  are
    considered a threat to  human  health  and  the
    environment.    A  test  called  the  Toxicity
    Characteristic   Leaching   Procedure   (TCLP)
    demonstrates whether a waste contains levels of
    hazardous    constituents   above    regulatory
    thresholds.    Wastes   exhibiting   the   toxicity
    characteristic are  given  specific  waste  codes
    depending on  the  hazardous  constituent of
    concern.  For example,  TCLP results indicating
    levels of arsenic or chromium  greater  than 5.0
    parts per million (ppm) in  a waste stream  are
    toxic for arsenic and chromium, and are given
    the waste codes "D004" and "D007," respectively.
    Wastes  generated  by  the  wood  preserving
    process are likely to exhibit the  characteristic of
    toxicity.
RCRA Overview
         Section 3-4

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                                                                   June 19, 1996
Listed Wastes
 •    Ignitability  (D001)—These  wastes  are  easily
     combustible  or   flammable.     Examples  of
     ignitable  wastes  include  spent  solvents  and
     discarded fuels.

 «    Corrosivity   (D002)—These  wastes   dissolve
     metals or other  materials,  or  burn  the skin.
     Common corrosive wastes include caustic soda
     and nitric acids.

 •    Reactivity (D003)—These wastes are unstable  or
     undergo  rapid or violent chemical reaction with
     water or other materials.  Cyanide- or  sulfide-
     bearing wastes typically exhibit the characteristic
     of reactivity.

In addition to the four  characteristic wastes, a waste is
also hazardous if it is specifically identified  on one of
four lists developed  by EPA.   A hazardous waste
listing is a narrative description of a specific type of
waste  that EPA  considers  dangerous  enough  to
warrant   regulation.     Hazardous  waste  listings
describe wastes from specific sectors of industry (e.g.,
the wood preserving industry), or specific chemical
formulations.

Before developing a listing, EPA thoroughly studies a
particular waste stream and the threat it can  pose  to
human health and the environment.   If  the waste
poses a great enough  threat to warrant regulation,
EPA includes  a precise description of that waste on
one  of the  hazardous waste lists.  Any waste that
meets the narrative listing description is considered
hazardous, regardless of its chemical composition  or
any other potential variable.  The three types of listed
wastes are:

•    F-listed   wastes—Wastes   from    nonspecific
     sources that  are  produced by a number   of
     manufacturing    and    industrial    processes.
     Examples  of   F-listed   wastes   commonly
     generated by  the  wood  preserving industry are
     wastes  generated  from   processes   that  use
     chlorophenolic  formulations  (F032),  creosote
     (F034), and inorganic preservatives containing
     arsenic or chromium (F035).
RCRA Overview
         Section 3-5

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                                                                  June 19,1996
                          •    K-listed   wastes—Specific    source    wastes
                               generated by particular  industries identified  by
                               EPA.  Wood preserving operations  are among
                               those  identified in the regulations.   As such,
                               many wood preserving facilities that employ
                               processes    that    use    creosote    and/or
                               pentachlorophenol   have   the   potential   to
                               generate K-listed waste, "K001."

                          Note:   Many   owners/operators    overlook     the
                          possibility  of a waste meeting  the  K001  description.
                          This listing is for  bottom sediment  sludge from  the
                          treatment  of  wastewaters  from  wood   preserving
                          processes      that      use      creosote      and/or
                          pentachlorophenol.   Also, it  should be  noted that any
                          waste   stream   meeting   the   K001  waste   code
                          description  cannot also be classified as one  of  the
                          F-listed wood  preserving wastes  (F032, F034, or F035).
                          These F listings specifically exclude K001 wastes.

                          •    P-listed   wastes—Specific   unused   or   off-
                               specification commercial chemical products that
                               are being discarded.    EPA  has   specifically
                               identified wastes on the P-list as being acutely
                               hazardous.

                          •    U-listed   wastes—Specific  unused   or   off-
                               specification commercial chemical products that
                               are being discarded.  An example of a potential
                               U-listed waste that may be of concern  to  the
                               wood preserving  industry  is  unused creosote
                               (U051).

                          Exhibit 5 outlines some of the questions  that should
                          be asked to determine whether  a waste is hazardous
                          under RCRA Subtitle C.
RCRA Overview
Section 3-6

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                                                                        June 2 9, 1996
                                     Exhibit 5
                         Hazardous Waste Determination
                    Is the Waste
                    Specifically
                      Listed?
                          No
              Does the Waste Exhibit a
                  Characteristic of
               Hazardous Waste (i.e.,
              Ignitability, Corrosivity,
               Reactivity, or Toxicity)?
                           Hazardous Waste |
                           Subject to RCRA
                              Subtitle C
                          No
                  Not Subject To
                 RCRA Subtitle CI
Note: This chart  assumes  that  a number of other  decisions  concerning  hazardous  waste
determination have  been made.  Specifically, the information in the chart assumes that  the waste
in question has already  been determined  to be a solid  waste under RCRA (§261.2),  and that the
waste is not otherwise  excluded from RCRA regulation in any  way (e.g.,  under §§260.30, 261.2, or
261.4).
Hazardous Waste
Mixtures
RCRA  also  regulates the waste resulting from  the
mixture of hazardous and nonhazardous wastes.  A
mixture involving characteristic wastes is hazardous
only  if  the  mixture  itself  exhibits  a characteristic.
Under the "mixture rule" for listed wastes, however,
a mixture made up of non-hazardous solid waste and
any amount  of a listed hazardous waste is, itself, a
listed hazardous  waste.  The  mixture will bear  the
same waste code and regulatory status as the original
listed  component  of the mixture.   This  principle
applies regardless of the percentage of listed waste in
the waste mixture, the  actual  threat  posed by  the
waste   mixture,    or   the   mixture's    chemical
composition.   The   mixture   rule  was  originally
created to prevent the dilution of listed  wastes as a
substitute for treatment activities.
RCRA Overview
          Section 3-7

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                                                                June 19,1996
Contaminated Media
Derived-front
Hazardous Waste
EPA's contained-in policy addresses environmental
media   (e.g.,  soil,   sediment,   and  groundwater)
contaminated  with  hazardous waste. According to
this policy, any media that  is contaminated  with a
listed  waste  must  be  managed   as  that  listed
hazardous waste.  To  determine whether a media
contains a hazardous waste, owners/operators must
have complete, accurate, and historical  information
pertaining to  past and present  waste management
operations at the facility.  If constituents of concern in
the soil cannot be linked to a process that generated a
listed hazardous waste, then the contained-in policy
will not apply. Unlike the  mixture rule  (described
above), however, any media  that  is contaminated
with a  listed waste  can  lose its status  and become
non-hazardous. This occurs  when it is demonstrated
that the contaminated media  no longer  "contains"
the listed hazardous waste.  This is accomplished by
bringing the  levels  of contamination   below  a
predetermined level established by the appropriate
implementing agency. Once this  demonstration is
made, the media is no longer considered  to "contain"
a listed waste and  is no  longer  regulated under
Subtitle C.

Similarly, any contaminated media that  exhibits a
characteristic of hazardous waste is also  considered
hazardous waste and subject to regulation. A media
that exhibits a characteristic of hazardous waste can
be  rendered  non-hazardous   by  removing   the
characteristic.

Any residue resulting from the treatment,  storage, or
disposal of a listed waste is considered  a  hazardous
waste.  Examples of derived-from wastes include: ash
resulting from the  combustion of hazardous waste,
and  sludges  generated   from  the  treatment  of
hazardous wastewaters.
RCRA Overview
         Section 3-8

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                                                                  Tune 19,1996
 Acutely Hazardous
 Waste
 Generators  Of
 Hazardous  Waste
 Some hazardous wastes are considered to be "acutely
 hazardous."    These  are  wastes  that  EPA   has
 determined to be so dangerous in small amounts that
 they are  regulated in  the same  manner  as large
 amounts   of  other  hazardous  wastes.   Acutely
 hazardous wastes include  certain  dioxin-containing
 wastes  and  those unused   commercial   chemical
 products  identified as P-listed wastes.   The listed
 wastes generated at wood preserving plants that  use
 or  formerly   used  chlorophenolic   preservative
 formulations are likely to contain dioxins.  EPA  has
 determined  that  pentachlorophenolic  wastes   are
 toxic, not  acutely hazardous.

 As  stated previously, RCRA  regulates  hazardous
 waste from the point of generation through final
 disposal.  Hazardous  waste generators are the  first
 link  in   this   cradle-to-grave  hazardous  waste
 management   system.     EPA   has   established
 comprehensive standards  for generators managing
 hazardous waste, including   standards  for on-site
 accumulation,     waste     tracking,      labeling,
 recordkeeping, and reporting  requirements.

Because  generators   produce  waste  in   different
quantities, EPA  has established three categories of
waste generators:

 •   Large quantity generators  (LQG) generate 1000
    kilograms  (kg) (approximately 2200 pounds or
    300 gallons)  or more  of hazardous waste  per
    calendar month or more than 1 kg (2.2 pounds)
    of acutely hazardous waste. Any generator that
    produces greater than 1 kg of acutely hazardous
    waste in a calendar month must comply with all
    of the large quantity generator requirements.  Of
    the three  classifications  of  hazardous  waste
    generators, large quantity generators are subject
    to the most comprehensive standards.

•   Small  quantity  generators  (SQG)  generate
    between  100 and 1000 kg of  hazardous  waste
    (between approximately 220 and 2200 pounds, or
    25 and 300 gallons) per calendar month.   Small
    quantity  generators  are  subject to  a limited
    portion of the regulations that apply  to large
RCRA Overview
         Section 3-9

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                                                                 June 19,1996
                              quantity generators.  Small  quantity generators
                              may not  accumulate  more than  6000  kg of
                              hazardous waste or 1 kg (2.2 pounds) of acutely
                              hazardous waste in a month on-site at any one
                              time.  Small quantity generators who exceed this
                              accumulation  limit  must  comply  with  the
                              regulations for large quantity generators.

                         •    Conditionally exempt small quantity generators
                              (CESQG) generate 100 kg or less of hazardous
                              waste (approximately 220 pounds or 25 gallons)
                              per calendar  month.    These  generators are
                              conditionally  exempt  from  many   of  the
                              regulations    governing    hazardous   waste
                              generators, provided they  do not  accumulate
                              more  than 1000 kg on-site at any one  time and
                              that any hazardous waste generated is sent to a
                              State- or Federally-approved facility.

                         Note:   Under   RCRA,  many   hazardous    process
                         wastewaters  that  are  either reclaimed  or  sent for
                         treatment  or disposal  must  be counted   toward  a
                         generator's monthly status.  As a result,  it is unlikely
                         that many  wood preserving facilities  will  meet this
                         WOkg/month    threshold   and   Toe   considered
                         conditionally   exempt  small  quantity  generators.
                         Only the smallest wood  preserving facilities  would
                         normally qualify for this category.

                         Some  State regulations may be more  stringent than
                         Federal regulations.  For example, a particular State
                         may set lower cut-off levels for generator  status, or
                         may eliminate one   of  the categories completely.
                         Some   States  do not recognize  the   conditionally
                         exempt generator  category.    Please  consult the
                         appropriate  State   implementing   agency  when
                         determining  the generator  status of  a  particular
                         facility. Owners/operators of facilities  that generate
                         hazardous  waste are  responsible  for  making the
                         correct generator status determination.
RCRA Overview
Section 3-10

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                                                                  June 19, 1996
 Episodic  Generation
Hazardous Waste
Counting
Facilities  that generate  hazardous  waste  may be
regulated under different rules at different  times,
depending on the amount of waste generated in any
given month.    For  example,  a small   quantity
generator that generates over 1000 kg of waste in a
particular  month  must  comply with the  more
extensive large quantity generator requirements  for
the amount of time that the  waste remains on  site.
This fluctuating hazardous waste generation pattern
is known as episodic generation.

In order to determine the extent to which a facility is
subject  to the RCRA  generator regulations,  each
generator must "count" the  amount  of hazardous
waste produced at the facility in  a calendar month
and  determine generator status  (i.e., large  quantity,
small quantity, or conditionally exempt).  Counting
involves adding up the weight of all quantities of
characteristic and listed hazardous wastes generated
at a  particular facility.   Wastes  should   only  be
counted once toward a generator's monthly  status
calculation.

Exhibit 6 may assist in  deciding when a hazardous
waste is to  be  counted  when making a generator's
quantity determination.  EPA requires that only those
wastes that are subject to "substantive regulation" be
counted.    Substantive   regulation  includes   any
regulation    directly   related   to    the   storage,
transportation, treatment,  or  disposal of hazardous
wastes.  Regulations which would not be considered
substantive  include  requirements  to  notify  and
obtain an EPA identification number  or to file  a
Biennial Report.
RCRA Overview
         Section 3-11

-------
                                                                             June 20,1996
                                        Exhibit 6  ,
                             Hazardous Waste Counting
              COUNTED
   Wastes accumulated on-site for any period
   of time prior to their subsequent
   management.

   Wastes packaged and transported off site.

   Wastes placed directly into a regulated
   on-site treatment, storage, or disposal
   unit.

   Wastes meeting the definition of F032,
   F034,orF035.

   Wastes removed from exempt units (e.g.,
   wastewater treatment units).

   Wastes generated as sludges and removed
   from product storage tanks.

   Examples:

       Process residuals, sludges.

       Wastewater that accumulates on the
       drip pad and in the collection system,
       e.g., drip pad sump.

       When discarded: metal banding
       (unless recycled), wood stickers,
       personal protective equipment.
              NOT COUNTED
       Hazardous waste removed from on-site
       storage.*
   •   Hazardous waste produced by on-site
       treatment (including reclamation) so long
       as the treated waste has already been
       counted once.

   •   Spent materials that are generated,
       reclaimed, and subsequently reused on
       site, so long as the spent material has
       already been counted once.

   •   Wastes excluded from the definition of
       solid waste under §261.2, i.e., wastewater
       discharged to a POTW or NPDES point
       source discharge.

   •   Wastes excluded from regulation under
       §261.4(a)-(f) (e.g., arsenical treated
       wood that is discarded off the drip pad
       (§261.4(b)(9).

   •   Recyclable materials under §261.6(a)(3).

   •   Wastes reclaimed on-site without prior
       storage or accumulation.

   •   Wastes managed in exempt units (e.g.,
       wastewater treatment units).

   •   Residues left in empty containers (empty
       as per §261.7).

   •   Universal wastes managed under
       Part 273.
* EPA's counting Guidelines are designed to account for those wastes that are subject to "substantive
regulation."  These wastes should only be counted once, and not double counted.  Therefore, in this
example,  because hazardous wastes  removed from hazardous  waste storage have already been
counted once, they need not be counted again (§261.5(d)).
RCRA Overview
Section 3-12

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                                                                   June 19, 1996
 General RCRA
 Requirements for
 Generators of
 Hazardous Waste
EPA Identification
Number
 Another discussion on hazardous waste counting as
 it pertains  to wastes specifically  generated in  the
 wood preserving  industry is found  in Section 4 of
 this Guide.

 Large and small  quantity generators are subject to
 several   specific    requirements   under   RCRA.
 Regulations require generators to:
                               Obtain an EPA identification number
                               Properly   prepare   hazardous   waste
                               tr ansp ortation
                               Follow accumulation and storage requirements
                               Manifest hazardous waste
                               Satisfy    recordkeeping
                               requirements
                               Provide personnel training
                               Develop contingency plans.
                                                for
                                 and     reporting
The specifics of the above requirements  will differ
depending upon a facility's generator status. Each of
the requirements  mentioned above is  discussed  in
more detail below.

Each EPA identification number consists of a series of
letters and digits.   The  digits represent the specific
facility, and the letters indicate in  which  State the
facility is located.   EPA identification numbers are
obtained by  filing Form  8700-12,  "Notification  of
Regulated Waste Activity," with the  appropriate EPA
Regional or State RCRA office.

Without an EPA identification  number, a generator
cannot treat, store, dispose of, transport, or offer for
transport any hazardous waste.  A' generator is  also
forbidden  from  offering   hazardous  waste  to  a
transporter or treatment, storage, or disposal facility
(TSDF)  that  does  not have  an EPA identification
number.  On the Federal level, conditionally exempt
small quantity generators are not required to obtain
EPA identification  numbers;  however,  State policy
may  require  conditionally  exempt  generators   to
obtain EPA identification numbers.
RCRA Overview
         Section 3-13

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                                                                 June 19,1996
Pre-Transport
Requirements
Accumulation
Requirements
Large Quantity
Generators
EPA has adopted the pre-transport regulations used
by the U.S. Department  of  Transportation  (DOT).
DOT regulations require proper packaging to prevent
leakage  of  hazardous   materials,   and  labeling,
marking, and placarding of these wastes to identify
characteristics and potential  dangers.   For more
information  on  DOT  prepackaging requirements,
consult the regulations in 49 CFR.

Although  storage  of hazardous  waste  generally
requires a RCRA permit, RCRA allows generators to
"accumulate"  hazardous  waste  on-site  without a
permit as long as they comply with specific limits and
standards set out for each generator category.

Large quantity generators may accumulate waste on-
site for up to 90 days without a RCRA permit as long
as:

•    The waste is properly stored
•    The facility  has an contingency plan in place
•    Facility personnel are trained in proper waste
     handling procedures.

Large  quantity  generators  may  only  accumulate
hazardous  waste in containers, tanks, containment
buildings, or on  drip pads. Each container  and tank
must be labeled with the words "hazardous  waste,"
and generators must mark the  accumulation start
date on each container.   Tanks need not  have  the
start  date  marked  on  them  because they   are
continually reused. Large quantity generators must,
however, be able to demonstrate through manifests
and other  records  that  the tank has been  emptied
within the  specified 90-day time frame.
RCRA Overview
         Section 3-14

-------
                                                                  June 19, 1996
 Treatment in
 Generator
 Accumulation Units
 RCRA Air Emission
 Standards
Small Quantity
Generators
 If a generator continues to store hazardous waste for
 longer than 90 days, the facility will be considered a
 hazardous waste storage facility and must  obtain a
 RCRA  permit  (see  discussion  of RCRA   permits
 below). Although some  States prohibit such action,
 under Federal regulations, generators may perform
 treatment  (except for thermal  treatment  such  as
 combustion and incineration) of hazardous  waste in
 accumulation units  under the  condition that  they
 continue  to  comply with the  general management
 standards discussed above and do not exceed the 90-
 day accumulation time limit.

 On December 6,1994, EPA finalized its air emission
 standards under RCRA to reduce volatile organic air
 emissions  from waste   management  operations.
 These   standards, known  as  Subpart CC,  affect
 owners/operators managing hazardous waste with a
 certain  volatile  organic  concentration  in  tanks,
 surface  impoundments,  and   containers.    Large
 quantity  generators   must   comply   with   these
 regulations in order to maintain their permit-exempt
 status.  The  Subpart  CC standards are in the final
 stages of development and are expected to become
 effective October 6, 1996.  The Subpart CC standards
 do not  apply  to process  tanks or to  wastewater
 treatment units at wood preserving facilities.  Oil-
borne facilities using  large tanks to store hazardous
waste need to carefully consider  the applicability  of
 Subpart CC.

 Small quantity generators may accumulate waste on-
site for up to 180 days as long as:

 •   The on-site quantity does not exceed 6000 kg at
    any time
 •   At  least one employee who is responsible for
    coordinating emergency responses is either  at
    the facility or on-call at all times
 •   The  facility  has  basic  safety  information,
    including the name  and telephone number of
    the designated emergency  coordinator,  location
    of fire extinguishers, spill control materials,  and
    the fire department phone  number posted next
    to the telephone
RCRA Overview
        Section 3-15

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                                                                  June 19,1996
Conditionally Exempt
Small Quantity
Generators
•    Personnel  are  familiar  with  the  emergency
     procedures to be followed in the event of a spill
     or accident.

Note: As an exception  to  the 180-day accumulation
time period, small quantity generators may only store
hazardous  waste  on drip  pads for 90 days, but may
continue   to  store hazardous  waste  in  drums  and
tanks for  up  to 180  days (accumulation   time   is
extended  to 270 days if the generator  must  transport
the  hazardous   waste  over  200  miles  for  off-site
treatment, storage, or disposal).

If waste is stored in drums for longer than 180 days,
the facility will be  considered a storage facility and
must obtain a RCRA permit (see discussion of RCRA
permits below). Small quantity generators may also
treat hazardous  waste   in   accumulation  units
provided they comply with the general management
and time limit restrictions discussed above.

Conditionally exempt small quantity generators may
accumulate hazardous waste on-site as long as they
do not have on-site, at any one time, more than 1000
kg of hazardous waste, or  1 kg of acutely  hazardous
waste.     At   the  Federal  level,  there   are   no
accumulation time  limits for conditionally  exempt
small  quantity generators, and no recordkeeping,
personnel   training,  or   emergency  planning   is
required. However, regulations require conditionally
exempt generators to send their wastes to one of five
types  of facilities   (either a  State-  or  Federally-
approved municipal or hazardous waste landfill, or a
recycling facility).   Conditionally  exempt  generators
are  strongly encouraged  to check  with  their  State
hazardous waste agency to determine if the State has
adopted  more  stringent standards for generators  of
less than 100 kg.                       '     .
RCRA Overview
                                   Section 3-16

-------
                                                                    June 19,1996
 Satellite
 Accumulation
 Many generators temporarily  store their hazardous
 waste in locations at or near the point of generation
 before taking the waste to a central accumulation area
 at the facility (i.e.,  the "90-day area").  This  satellite
 accumulation is permissible  under Federal  RCRA
 regulation,   provided   certain  criteria  are  met.
 Generators  may accumulate  up to  55  gallons  of
 hazardous waste, or one quart of acutely hazardous
 waste, at or near the point  of  generation  in  satellite
 accumulation   areas    without   triggering    the
 generator's "90-day clock." For example, wastes that
 are temporarily  accumulated  right  outside of  the
 retort could qualify for the satellite accumulation
 provision.   The following  requirements apply  to
 satellite accumulation:

 •   Containers  must be labeled as "HAZARDOUS
     WASTE"  or with  other words that identify the
     contents of  the container.
 •   Once  the  55-gallon limit  is  reached  in  the
     satellite accumulation area, the containers must
     be removed within  72 hours  and  taken to a
     central accumulation area.
 •   The  90- or  180-day  facility accumulation limit
     begins  with respect to satellite  accumulation
     waste as soon as the waste is removed from the
     satellite accumulation area.
 •    When the 55-gallon limit  is  reached,  generators
     must mark the  container with the start date that
     excess waste started  to accumulate.   Generators
     then have three days to remove the hazardous
     waste to a central accumulation area where the
     90- or 180-  day accumulation  time will begin,
     depending on their generator status.

EPA   does  not   limit   the number   of  satellite
accumulation areas allowed  at a particular  facility,
nor does it specify the type or size of containers that
may be used. As long as the 55-gallon limit is not
exceeded, owners/operators may use a  variety  of
containers to accumulate  wastes  in  a satellite area.
Proper satellite   areas  should  be  designated   in
conjunction  with the appropriate  State  hazardous
waste agency.
RCRA Overview
         Section 3 -17

-------
                                                                 June 19,1996
Storage Requirements
Hazardous waste may be stored in 55-gallon drums,
tanks, or other units suitable for the  type  of waste
generated.

If hazardous waste is stored in containers:

•    The container must be clearly marked  with the
     words "HAZARDOUS  WASTE"  and with  the
     date the accumulation starts.
•    Containers  must be kept in good  condition and
     replaced if they begin to leak.
•    Containers must be kept closed and sealed except
     when being emptied or filled.
•    Containers  must  be inspected each  week for
     leaks or corrosion.
•    If  a  container  is used  to store ignitable  or
     reactive waste, it must be  placed  at least 50 feet
     (15 meters) from  the  facility property line to
     create a buffer zone.
•    Wastes  that can  react together must never  be
     stored together  to prevent dangerous  reactions
     upon contact.

Generators may also store hazardous waste in tanks,
provided  they  meet  certain standards.   All  large
quantity generators accumulating hazardous waste in
tanks must comply  with the standards discussed in
Section  7;  however,   small   quantity  generators
accumulating hazardous waste  in tanks are subject to
special standards.

If  small   quantity   generators  are  accumulating
hazardous waste in tanks:

 •   The tank must be kept covered or, if uncovered,
     there must be at least two feet of space between
     the top of the  tank and the waste being stored
     (unless the tank  is  equipped with secondary
     containment).
 •   If the tanks have  equipment that allows waste to
     flow into them continuously,  waste feed cut-off
     or bypass systems must be provided to stop the
     flow in case of  problems.
 •   Monitoring  or   gauging  systems   must  be
     inspected  each operating day and  the  tanks
 RCRA Overview
                                   Section 3-18

-------
                                                                  June 19,1996
Combined Use of Drip
Pads, Containers, and
Tanks/Sumps at
Wood Preserving
Facilities
     themselves  must  be inspected  each week for
     leaks or corrosion.
 •    For tanks containing ignitable or reactive wastes,
     a buffer zone must be established between the
     tank and the  facility  property line.    At  a
     minimum,  buffer zones must meet appropriate
     National Fire Protection Association  (NFPA)
     requirements. Owners/operators can obtain this
     information  from the local fire department.

It is possible for a wood preserving facility to use drip
pads, containers, and tanks to manage  hazardous
waste  in the same operation.   For example,  waste
may be generated and accumulated on a drip pad for
a short period of time, then drained to a collection
tank or sump.  In addition, many owners/opera tors
also keep a drum  located at the edge of the drip pad to
capture debris and residues that do not drain into the
collection unit and are picked up off the drip pad.

In combined  use  situations, it is important to  know
the regulatory status of all waste accumulation  units.
The  drip  pad  is   specifically  identified  as  an
accumulation unit in the RCRA  regulations.   The
RCRA drip pad standards require that all  tanks and
sumps used  as drip pad collection  units  meet  the
RCRA tank standards in Subpart J. As a result, these
tanks/sumps  will  also  be  subject  to  Subtitle  C
controls. Although it  is possible  for these tanks to be
fully regulated, collection  tanks can be a part of a
facility's  wastewater  treatment  system  and  thus
exempt from RCRA regulation.  RCRA provides an
exemption    from    regulations   for   wastewater
treatment units.  If this is the case, the tank or sump
would not be regulated under Subpart J, but would be
subject to regulation under the Clean Water Act.

To take advantage of  the wastewater treatment unit
exemption, the tank has to be part of a system that is
either  discharging to a publicly-owned   treatment
work (POTW)  or subject  to  a  National  Pollutant
Discharge  Elimination   System    (NPDES)   zero
discharge permit.  It is the responsibility of the
facility's  owner/operator to make  these  kinds of
determinations in conjunction with the appropriate
State authority.
RCRA Overview
         Section 3-19

-------
                                                                  June 19,1996.
Manifest
Requirements
Containers that are kept on the edges of drip pads to
collect materials  such as debris may be considered
satellite  accumulation  areas  under  RCRA.  RCRA
allows owners/operators to  accumulate  up  to  55
gallons of hazardous waste in areas at or near the
point of generation before it is transferred to a central
accumulation unit.

A  generator  who  transports,   or   offers  for
transportation,   hazardous   waste   for   off-site
treatment,  storage,  or  disposal  must  prepare  a
Uniform  Hazardous Waste  Manifest  (Form 8700-
22A).    Manifests   allow   generators,   as well  as
regulators, to  track the  movement of  hazardous
waste from its point of generation to  the point of
ultimate  treatment,  storage, or disposal.  Each party
that handles  the  waste must  sign the manifest and
retain a  copy.  Once the transport is complete, the
receiving facility  must  return a  signed copy of the
manifest to the generator (within 60 days for small
quantity  generators, and within 45 days  for large
quantity  generators).   If no copy  of the  signed
manifest is received by the generator,  an exception
report must be filed.

RCRA manifests contain the following  information:

•    Name and EPA identification number  of the
     generator, transporter, and the  designated TSDF
•    DOT description of the waste
•    Quantity of waste
•    Address of the designated  TSDF to which the
     waste is  being transported
•    Certification that the generator has in place  a
     program to  reduce the  volume  or  toxicity of
     waste and that the  treatment,   storage, and
     disposal method chosen by the generator is the
     most practical method currently available.
RCRA Overview
         Section 3-20

-------
                                                                   June 19,1996
Personnel Training
Contingency Plans
Large  and  small quantity generators  must  satisfy
certain personnel  training requirements.    These
requirements help to ensure that all  employees  in
contact with hazardous waste are knowledgeable  of
the dangers involved and educated on proper waste
handling procedures and precautions.  Large quantity
generators are subject to the same personnel training
requirements as permitted RCRA facilities.  To fulfill
these   requirements,   facility   personnel   must
successfully  complete   a  program  of  classroom
instruction  or on-the-job training that teaches them
to  perform  their  duties  in  a  safe  and effective
manner.  Employees must complete  the program
within six months after beginning their employment
and must take part in an annual review  of the initial
training. Small quantity generators are not required
to satisfy these requirements, but  are responsible for
ensuring  that  facility  personnel  are  instructed  in
proper  waste handling procedures.   Conditionally
exempt small quantity  generators are not subject  to
personnel training requirements.
Generators are required to have a contingency plan
in place  at  the  facility  that  outlines  the  proper
response procedures necessary to minimize hazards
posed by fires, explosions, or unplanned releases  of
hazardous waste from  the facility.    Similar   to
personnel  training  requirements,  large  quantity
generators are subject to the same contingency plan
requirements  as permitted facilities.  Details of the
precautionary measures that must be taken are found
in the  regulations.  Extensive plans are not required
for small  quantity generators; rather, small quantity
generators must construct a modified version of the
plan.      Conditionally   exempt   small  quantity
generators are not  required to  have  contingency
plans.

Note:  Although   small  quantity  generators   are
typically  subject  to  slightly  reduced   requirements
concerning  personnel   training   and   contingency
plans,   small   quantity   generators    accumulating
hazardous  waste on drip pads serve as an exception
to the  rule.   As  discussed  in  this section,  small
quantity  generators  must comply  with  the  large
RCRA. Overview
         Section 3-21

-------
                                                                  June 19,1996
Recordkeeping and
Reporting
Requirements
quantity  generator  standards,  including  those  for
personnel    training    and'   contingency    plans.
Therefore,  in the specific  instance  of  a generator
accumulating  on drip  pads, owners/operators   will.
not be able to take advantage of this reduced  burden.

Hazardous  waste generators  must  satisfy several
recordkeeping and reporting requirements.   Large
quantity  generators who  transport hazardous  waste
off-site must submit  a biennial  report  to the EPA
Regional Administrator (or State director if the State
is  authorized to implement the  hazardous  waste
program) by March 1 of  each  even-numbered  year.
This report details  the  generator's activities during
the previous calendar year, including the  quantity
and nature of the hazardous waste generated; and the
name, address,  and EPA identification  number of
each  TSDF  to  which  waste  was sent  and  each
transporter who  handled the waste  for  the facility.
The report must  also describe the facility's efforts to
reduce  the  volume   and  toxicity  of  the  wastes
generated and the  changes in volume  and toxicity
actually achieved compared to  previous  years  (waste
minimization  report).    Neither  small   quantity
generators nor conditionally exempt small  quantity
generators are required to submit a biennial report.

To  ensure   the  safe  and  efficient  transport  of
hazardous waste to off-site facilities,  RCRA  requires
facilities to return a signed copy of the manifest to the
generator within a  certain  time  frame.    Small
quantity  generators must receive  a copy within 60
days,  large  quantity  generators  within  45   days.
Owners/operators who  do not receive a copy  of the
manifest signed and dated by the  TSDF within the
appropriate time period  must submit an exception
report.   Although  there  is no  specific  form, the
contents  of the exception report  are specified  in the
regulations.  Conditionally exempt  small  quantity
generators are not required to prepare a manifest, and
thus  are not  subject  to the  exception reporting
requirements.

Generators must keep signed copies of manifests for
at least three years from the date waste was  accepted
by the initial transporter.  The generator must  also
RCRA Overview
         Section 3-22

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                                                                  1x01619,1996
                          retain a copy of each biennial  report for three  years
                          from  the due  date of the report.   In  addition, a
                          generator must keep records of any test results or
                          waste analyses for at least three years. The three-year
                          period for  retention  of  records  is  automatically
                          extended during an enforcement action.

                          Exhibit   7  summarizes  the   different   regulatory
                          requirements for large quantity, small quantity, and
                          conditionally exempt generators.
                                  Exhibit 7
             Requirements for Wood Preserving Facilities that are
                    Generators of RCRA Hazardous Waste
Hazardous Waste
Quantity Limits
(per calendar
month)
Waste
Determination
EPA ID Number
On-Site
Accumulation
Quantity Limits
Accumulation
Time
Storage
Requirements
Off-Site Waste
Management
Contingency Plan
Storage Yard
Cleanup Plan
Subpart W Drip
Pad Standards
Large Quantity
>1000 Kg hazardous
waste
or
> 1 Kg acute hazardous
waste
Yes
Yes
None
< 90 days
Comply with all Part 265
management standards
for tanks, containers, drip
pads, and containment
buildings
RCRA permitted or
interim status HW
facility
Full plan to minimize
hazards from fires, spills,
explosion
Yes
Yes
Small Quantity
Between 100-1000 Kg
hazardous waste
Yes
Yes
< 6000 Kg
< 180 days*
(< 270 days if travel to
waste management
facility is > 200 miles)
Comply with basic
technical requirements for
tanks and containers*
RCRA permitted or
interim status HW
facility
One person at the facility
at all times responsible
for coordinating
emergency responses
Yes
Yes
Conditionally Exempt
< 100 Kg
or
< 1 Kg acute hazardous
waste
Yes
No
< 1000 Kg
< 1 Kg acute hazardous
< 100 Kg spill residue from
acute HW
None
None
State approved or RCRA
permitted/interim status
facility or; recycling
facility
None
No
No**
RCRA Overview
Section 3-23

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                                                                           June 19,1996
                                       Exhibit 7
       Requirements for Wood Preserving Facilities that  are Generators of
                          RCRA Hazardous Waste (cont'd)
,
DOT Shipping
Requirements
Treatment on Site
without a RCRA
Permit
Manifest
Biennial Report
Recordkeeping
Personnel
Training
Large Quantity
Yes
Yes (except for thermal
treatment such as
combustion and
incineration)
Yes
Yes
Manifests
Biennial reports
Exception reports
Test results
Records of past
management practices
• Records of storage yard
cleanup
• Documentation if any
past decontamination
of equipment to
eliminate waste codes
Formal classroom training
with annual updates
Small Quantity
Yes
Yes (except for thermal
treatment such as
combustion and
incineration)
Yes
No
• Manifests
• Exception reports
• Test results
• Records of past
management practices
• Records of storage yard
cleanup
• Documentation if any
past decontamination
of equipment to
eliminate waste codes
Employees must be
familiar with waste
handling and emergency
procedures relevant to
their position
Conditionally Exempt
Yes
No, unless the CESQG is
also one of the types of
waste management
facilities specified above
No
No
None
None
'Generators of between 100-lOOOKg hazardous waste per calendar month (small quantity generators)
  who utilize drip  pads  must comply with  the standards  for large  quantity generators for the
  management  of wastes  on drip  pads.   This means  that  small  quantity  generators  can only
  accumulate hazardous waste for 90 days.  This  exception  does  not apply  to the management of
  drummed wastes, which are still subject to the 180-day accumulation time.
**Although  Federal  RCRA regulations  do  not specifically  require  conditionally  exempt  small
  quantity generators to comply with  the Subpart W drip pad standards, owners/operators  of these
  facilities should note that any hazardous waste that is allowed  to accumulate on the ground (i.e.,
  allowed to drip off of a  charge and  onto the ground in the  storage  yard) can be considered illegal
  disposal of hazardous waste and subject to enforcement action.   Therefore,  it is advisable  that
  conditionally  exempt generators  manage  their  process  in  a  manner  that  does  not  allow
  preservative or waste to contact the ground.
Land Disposal
Restrictions
The RCRA  Land Disposal Restrictions  (LDR) require
that hazardous waste must  meet specified treatment
levels in order to be disposed  of on the  land.  An
example of land disposal is the placement of wastes
into a landfill or lagoon. EPA has assigned each waste
code identified  under  RCRA   a specific  treatment
standard that must  be met before  land disposal can
occur.
RCRA Overview
          Section 3-24

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                                                                  June 19,1996
                          Treatment  standards can be expressed in two ways:
                          (1)  as  a  specific  technology  (e.g.,  combustion,
                          vitrification)  that must be applied to the waste in
                          order  to  meet  the  standard, or  (2)  as  specific
                          concentration  levels.    Facilities  managing wastes
                          with treatment standards expressed as concentration
                          levels  may perform any type  of  treatment  on the
                          waste stream to achieve the standard  (keep in mind
                          however, that a generator  cannot perform  thermal
                          treatment,  such  as incineration  or  combustion,
                          unless they obtain a RCRA permit).  EPA does not
                          allow the dilution  of hazardous waste to meet LDR
                          treatment standards.

                          Wastes  which  do  not meet  treatment standards
                          cannot be land disposed unless EPA has granted a
                          variance, extension, or exclusion for a particular
                          waste stream.  Also, certain newly identified wastes
                          (those identified on or after November 8, 1984) have
                          not yet been assigned treatment standards.   This  is
                          because EPA  needs time  to  determine  the  best
                          methods available  to treat these wastes  in order to
                          establish treatment standards.   Until  a treatment
                          standard has been developed, these wastes will not be
                          subject to LDR.  Certain  F-listed wastes from  the
                          wood preserving industry (i.e., F032, F034, and F035)
                          are  among  the wastes for which  EPA has not yet
                          identified treatment standards.  Until these treatment
                          standards are finalized, these wood preserving wastes
                          are  not subject to LDR  treatment  standards.  In
                          addition, other  wastes  generated  in  the  wood
                          preserving  industry, such  as  K001,  already have
                          treatment standards.  K001, which is described in the
                          listing as bottom sediment sludge from the treatment
                          of wastewaters from wood preserving processes that
                          use creosote and/or pentachlorophenol, does have
                          an established numerical treatment standard.

                          Generators  and TSDFs managing  hazardous wastes
                          that are subject to  LDR have  specific notification,
                          certification,  waste  analysis,  and   recordkeeping
                          requirements.    Similar  to  a  hazardous  waste
                          manifest,   LDR   notification    and   certification
                          paperwork helps hazardous waste handlers and EPA
                          ensure that wastes are being properly treated before
                          land disposal.
RCRA Overview
Section 3 - 25

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                                                                 June 19,1996
Waste Subject to LDR
Requirements
RCRA Permitting
Generators are responsible for determining whether
their waste is subject to LDR. This is accomplished by
either  testing the waste  or by  applying  generator
process knowledge.  If a waste is subject to LDR but
does not  meet the  applicable  treatment  standards,
generators must provide  written notification to the
TSDF to which the  waste is being sent.   Although
there is no specific LDR notification form,  EPA does
require specific information to  be included  in the
notice, including:

•    EPA hazardous waste code
•    Identification of the  waste as a wastewater or
     non-wastewater
•    Manifest number of the shipment
•    Waste analysis information (if  available)
•    For certain  specified  wastes, any  additional
     hazardous constituents present in the waste.

If  an  LDR waste does meet  applicable  treatment
standards, the generator must certify to the receiving
TSDF that the waste meets the  required  treatment
standards.   Generators must  keep  a  copy of  all
notifications and certifications for at least five years.

Generators may treat their waste on-site  to meet LDR
treatment  standards. To  do so,  they must  first
develop  a written waste analysis plan (WAP).  The
WAP must justify the frequency of testing based on a
detailed analysis of a representative  sampling of the
waste,  and contain information necessary for proper
treatment of the waste.  Generators who perform on-
site treatment of hazardous waste that is unrelated to
LDR treatment standards are not required to develop
a WAP.

Permits are an essential part of the  RCRA  Subtitle C
program.  RCRA requires facilities that treat, store, or
dispose of hazardous waste to obtain an  operating
permit.      A   permit    establishes   site-specific
administrative   and technical  hazardous   waste
management  standards  to  which a  TSDF  must
adhere.
RCRA. Overview
         Section 3-26

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                                                                  June 19,1996
Permit Exemptions
Permitting Standards
There  are  limited  circumstances  under  which; a
facility can treat, store, or dispose of hazardous waste
without a permit:

•    Large  quantity .generators  storing hazardous
     waste on site for less  than  90 days, and small
     quantity generators storing hazardous  waste on
     site for less than 180 days                    "'
•    Owners/operators of totally enclosed treatment
     facilities,  wastewater   treatment  units,   and
     elementary neutralization units
•    Persons  engaged  in   containment   activities
     during  an  emergency  response  (e.g.,  spills,
     accidents)    ..- I  1
•    Owners/operators^  of  solid   waste   disposal
     facilities  handling  only conditionally exempt
     small quantity generator wastes.

Any facility that does  not  qualify  for  a  permit
exemption  and  that_t  treats,  stores, or disposes... of
hazardous  waste must  obtain   a RCRA  permit.
Because  treatment,  storage, and -disposal  generally
involve several different types of units and multiple
activities,   the   permitting   regulations   impose
requirements far  more extensive than  those imposed
upon a generator. As  a result, many facilities in the
wood preserving  industry  have  made a concerted
effort to maintain generator status to avoid having to
apply for and adher^fo |he requirements of a permit.
In light of recent  w'aste minimization efforts, this has
become increasingly  easier to accomplish.

RCRA  permitting standards consist of both general
TSDF standards  as  well  as unit-specific standards.
The  general RCRA TSDF standards require facilities
to:                V

•    Conduct detailed chemical and physical analyses
     of waste managed, at the facility
•    Install  security measures  to  protect  human
     health, safety, and the  environment
•    Develop   and  ; conduct   a   written   facility
     inspection plan
•    Ensure  that  facility personnel  are trained to
     handle any  hazardous waste  with which they
     may come into contact
RCRA Overview
         Section 3 - 27

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                                                                  June 19,1996
Permit Applications
«    Properly  manage all  wastes to minimize  the
     chance of ignition, reaction, or explosion
•    Comply with standards prohibiting the siting of
     a facility  in areas prone to flooding or seismic
     activity
•    Develop    emergency    preparedness    and
     contingency plans
•    Comply     with     general     manifesting,
     recordkeeping, and reporting requirements.

All new facilities requiring  a RCRA permit must
apply for, and receive, a permit before constru'ction of
the facility can begin. Owners/operators of existing
facilities must operate under RCRA's interim status
standards while seeking a permit or awaiting  permit
approval  by EPA.   With  few exceptions, RCRA's
interim status standards  are  very similar  to  the
permitting standards.

RCRA  permit   applications   are  lengthy  and
comprehensive, consisting of two parts:  Part A and
Part B.  Both  parts of the application provide EPA
with  the  information  necessary to establish site-
specific requirements.  The Part  A application is
submitted  on Form  8700-23, and consists of basic
facility  information  such as  the  name, mailing
address, and  location of the facility.  The  Part B
application is the more complex, narrative part of the
permit application in which  the applicant describes,
in  great detail, the  types of  wastes that will  be
managed at the facility, precautionary measures that
will be taken to protect  human health  and  the
environment,   and  all   waste   analysis,   facility
inspection, and contingency plans that will be part of
everyday activities of the facility.

Once EPA receives this information,  the application
is reviewed, presented for  public  comment, then
approved or denied. All RCRA permits are effective
for a fixed term, not to exceed ten years. At that time,
the permit may be modified, reissued, or terminated.
RCRA Overview
         Section 3-28

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                                                                  June 19,1996
Wood Preserving
Facilities and Permits
Closure
Requirements at
Permitted Facilities
The process of obtaining a RCRA treatment, storage,
and  disposal  permit  is  difficult  and   lengthy,
sometimes taking two years  or more to complete.
Wood preserving facilities  can, and often do, avoid
the need  to obtain a RCRA permit  by maintaining
their permit-exempt  status as  a hazardous  waste
generator. To do this,  a facility must ensure  that any
waste generated at the  facility is removed  and sent to
a  permitted  or  interim status  TSDF within  the
appropriate time  frame (within  90  days for  large
quantity generators  and within 180 days for small
quantity generators). Because most wood preserving
facilities do not generate large volumes of waste, the
majority of facilities do not find it difficult to remain
exempt from permitting requirements.

All   hazardous   waste   management    facilities
eventually cease their  treatment, storage, or  disposal
activities.   When ceasing operation,  these  facilities
must be closed and maintained in a way that ensures
that they do not pose a future threat to 'human health
and the environment.

Closure regulations  can be divided  into two parts:
general closure standards and unit-specific standards.
General closure standards apply to all TSDFs entering
into  closure.   Unit-specific standards address  the
specific types of waste management  units regulated
under  RCRA.    Both  general  and unit-specific
standards  must  be satisfied  to  complete  closure
activities.   The maximum time allowed to complete
closure after the unit has received its final volume  of
waste is 180  days.  Extensions  to this 180-day  time
period may be granted  under certain circumstances by
the EPA Regional Administrator.  All TSDFs must
submit closure plans explaining, in detail, how the
facility will achieve the closure standards.  Permitted
facilities must  submit this  plan  with their Part B
permit  application.  Interim   status facilities must
have written closure plans  on-site six months  after
they become subject to  the RCRA TSDF standards..

Each closure plan must:

•    Describe   how    each    hazardous   waste
     management unit  at the facility will be closed
RCRA Overview
         Section 3 - 29

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                                                                  June 19,1996
Post-Closure
Requirements
Closure of Wood
Preserving Facilities
•    Estimate the maximum inventory of hazardous
     waste that will be on-site  during the  facility's
     operating  life
•    Describe closure methods necessary to  remove
     and manage waste present at the facility
•    Describe any  other steps necessary  to  achieve
     complete closure
•    Contain a schedule of closure dates, including
     the amount of time  each  closure activity will
     take
•    Contain an expected date of final closure.

Owners/operators who cannot "clean close" their
facility   by  removing   or  decontaminating   all
equipment, structures, and soils must also enter into
a period of post-closure care to prevent or control any
future releases  into the environment. Post-closure is
normally a 30-year period after closure during which
owners/operators    must    conduct   groundwater
monitoring and maintenance activities  to  prevent
releases.  Facilities entering into  post-closure must
obtain a post-closure permit, and must also submit a
post-closure plan to the EPA Regional Administrator
describing how these activities will be conducted.

Wood preserving  facilities that maintain generator
status under RCRA are  subject to limited  closure
requirements.  Large quantity generators  must close
their  accumulation   units  in  a  manner   that
minimizes  or   eliminates  post-closure  release  of
hazardous waste into  the environment,  and must
dispose  of or decontaminate  equipment, structures,
and soils at the  facility.

Small quantity generators are not subject to generic
closure   requirements;   instead,   small  quantity
generators must comply with applicable unit-specific
closure  requirements  contained  in  the  regulations.
For example, at closure, all accumulated hazardous
waste and residues must be removed from drip pads,
treatment    equipment,    discharge     equipment,
discharge   control   equipment,    and   discharge
confinement structures.   Small quantity generators
accumulating hazardous  waste in  tanks must also
comply    with   the  appropriate   tank   closure
requirements.
RCRA Overview
         Section 3-30

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                                                                  June 19,1996
Underground Storage
Tanks
 Note:   Small   quantity  generators   accumulating
 hazardous waste  on drip pads must comply with  the
 regulations  applicable  to large quantity generators.
 Thus,   they  are  subject  to  the  general   closure
 requirements  applicable to  large quantity  generators
 discussed above.

 Hazardous wastes  generated from closure activities
 must  be handled  according  to  applicable  RCRA
 regulations.  EPA has not established specific  Federal
 cleanup levels to verify "clean closure."  Many States,
 however, have established risk-based cleanup levels
 depending upon projected  land use  at the  facility.
 Thus,   facilities  must  work  closely  with  their
 implementing agency to determine specific levels of
 decontamination that will ensure the protection of
 human health and the environment.

 RCRA's Underground  Storage Tank (UST) program
 establishes a comprehensive  regulatory scheme  for
 the management of USTs  storing petroleum  and
 hazardous substances  as defined under  CERCLA.
 The regulations  establish minimum  standards  for
 new tanks and require owners/operators of existing
 tanks  to  either  upgrade,  replace, or  close them
 according to the regulations.

 The regulations are divided into two parts. The first
 part contains technical requirements  designed  to
 reduce the chances of releases from USTs, detect leaks
 and spills when they occur, and  secure  prompt
 cleanup in the event of a release.  The second part of
 the   UST   regulations    consists   of   financial
 responsibility requirements to  ensure  that,  in   the
 event of a spill  or  leak from  an UST, a facility will
 have the financial  resources to pay for  cleanup  and
 compensate  any third  parties  involved.    The
 financial responsibility requirements  apply only  to
 USTs containing petroleum.

 Most wood preserving facilities are not subject to  the
 UST regulations; in fact, the definition of "regulated
 substance"  as   it  applies  to  the  UST   program
 specifically excludes RCRA hazardous wastes.  This is
because RCRA  already has standards regulating  the
RCRA Overview
         Section 3-31

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                                                                 June 19,1996
State Authorization
management of tanks containing hazardous waste,
whether underground or above ground. As a result,
tanks  accumulating hazardous  waste at a  wood
preserving facility, even  if  underground,  are  not
subject to the UST regulations.  If, however, a wood
preserving facility does have an underground storage
tank (defined as a tank system whose  volume  is 10
percent or more below the surface of the ground) on-
site that contains petroleum or hazardous  substances
as defined under CERCLA, it may be subject to the
UST regulations.

Although there are no  Federal RCRA  standards for
the management of products  in  aboveground tanks,
States may have established such requirements.

The    RCRA   program   grants  certain  States
authorization to implement  the Federal  hazardous
waste regulations.  To receive authorization, States
must demonstrate to  EPA  that their  regulatory
program  is  equivalent   to   Federal   authority,
consistent with the Federal program, and  at least as
stringent as  the Federal regulations. Following  such
authorization, State regulations operate in  lieu of the
Federal program in that State.

State authorization can be divided into two major
categories:  the   "base  program"  and  "revisions."
Before States can implement  any part of the Federal
RCRA  regulations,  they  must  first   obtain  base
authorization, which allows a State to implement the
fundamental requirements of the RCRA program
(generally anything published prior to April 1, 1983),
such  as  generator  standards,  hazardous  waste
identification   standards,  and   basic permitting
provisions.  For those States  that do not  have  base
authorization  (currently  this  list includes  Iowa,
Hawaii, Alaska, and  some  U.S. territories),  EPA
implements  the entire hazardous waste management
program.

Once a State receives base authorization, it  must
continue  to revise  its  program  to incorporate
frequent revisions to the RCRA regulations to retain
its  authorized  status.   Because  revisions to  the
Federal  hazardous  waste management   program
RCRA Overview
         Section 3-32

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                                                                  June 19, 1996
                          consist of hundreds of individual rulemakings, EPA
                          has segmented the Federal  program into  different
                          groups, or clusters.   A State  may not incorporate
                          clusters of rules into its program until it receives base
                          authorization.

                          Note: Individual  States may incorporate  provisions
                          into their own programs that have no counterpart in
                          the Federal program.   These  additional elements  of a
                          State's program are not considered to loe part of the
                          Federal  RCRA program, and are  not  subject  to State
                          authorization  procedures.

                          Most  States are not  authorized  for all  clusters of
                          hazardous waste revisions.   Therefore, the status of
                          rulemakings that a State has not "picked up" (been
                          authorized for) depends on the statutory authority
                          upon  which  those  rulemakings  are  based.   For
                          example,  some   rulemakings   will  be  effective
                          immediately  in all States,  regardless of the  rules'
                          authorization   status  in   that  State.      Other
                          rulemakings, however, must  be picked up by  an
                          individual State before they can become effective in
                          that  State.  A discussion  of  this  aspect  of State
                          authorization is found below.

                          Within   the  State authorization  program,  it is
                          important to distinguish between those rulemakings
                          that are published as  a  result  of original  RCRA
                          language  (i.e., from statutory language  from  1976),
                          and those published pursuant to the Hazardous Solid
                          Waste Amendments  of 1984 (HSWA).   Prior to the
                          enactment of HSWA,  a State with final authorization
                          administered its hazardous waste program entirely in
                          lieu of the Federal program.  Federal requirements
                          no longer applied  in  the authorized  State, but were
                          incorporated into  the individual State's hazardous
                          waste  program.    When   new,  more  stringent
                          requirements were enacted, the State was obligated to
                          enact  equivalent   authority  within  specified time
                          frames.  New Federal requirements did not take effect
                          in an authorized  State until the State adopted the
                          requirements as State  law.  Some Federal rules are
                          still  issued  based  on  the  original  pre-HSWA
                          authority, and become effective  in authorized States
                          (those States which have been base authorized for
RCRA Overview
Section 3-33

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                                                                June 19,1996
                         rules published prior to April 1,1983) only when the
                         State adopts the provisions as State law.  These rules
                         are known as "non-HSWA"  rulemakings.

                         In contrast, HSWA of  1984 amended  RCRA  and
                         changed the State authorization regulations.  Under
                         the revised program, any  new  requirements  or
                         prohibitions   imposed   by  HSWA   take   effect
                         immediately in all States upon the effective date of
                         the standards, regardless of  a State's authorization
                         status.   In those States  that  do not  have  base
                         authorization,  EPA will implement  the  program
                         until  the State is granted  the authority  to  do so.
                         Rulemakings that are developed pursuant to HSWA
                         are called HSWA  rulemakings.  Exhibit 8 illustrates
                         the difference  between  HSWA   and  non-HSWA
                         rulemakings.   The difference between HSWA  and
                         non-HSWA   rulemakings    is    important    in
                         determining the status of wood preserving wastes in
                         a particular State.
                                 Exhibits
              Relationship Between State Authorization Status
                   and HSWA/Non-HSWA Rulemakings
State Authorization Status
Authorized State (authorized
for base RCRA program)
Unauthorized State (no
authorization for base RCRA
program)
Statutory Basis for RulemaMng
Non-HSWA
Effective date = Date when
State became authorized for
rule, implementation of rule
by State
Effective date = Date of rule,
implementation of rule by
EPA
HSWA
Effective date = Date of rule,
EPA implements until State
adopts rule
Effective date = Date of rule,
implementation of rule by
EPA
RCRA Overview
Section 3-34

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                                                                              June 19, 1996
Additional information is available on the subjects discussed above:
        •       For general information on RCRA, refer to EPA's RCRA Orientation Manual,
               1990 Edition, EPA/530-SW-90-036.
        •       For information on the specific regulations, consult the following sections of
               the Code of Federal Regulations:
                      Definition of Solid Waste — 40 CFR §261.2
                      Definition of Hazardous Waste — 40 CFR §262.11
                      Characteristic Waste — 40 CFR §§261.20-261.24
                      Listed Waste — 40 CFR §§261.31-261.33
                      Hazardous Waste Mixtures — 40 CFR §261.3(a)(l)(iv)
                      Derived-From Hazardous Waste — 40 CFR §261.3(c)(2)
                      Hazardous Waste Counting — 40 CFR §261.5
                      Generators of Hazardous Waste — 40 CFR Part 262
                      Accumulation Time/Storage Limits — 40 CFR §262.34
                      Satellite Accumulation — 40 CFR §262.34(c)
                      Conditionally Exempt Small Quantity Generators — 40 CFR §261.5
                      EPA Identification Numbers — 40 CFR §262.12
                      Pre-Transport Requirements — 40 CFR §§262.30-262.33; 49 CFR Parts 172,
                      173,178, and 179
                      Manifest Requirements — 40 CFR §262.20
                      Recordkeeping/Reporting Requirements — 40 CFR §§262.40-262.43
                      Hazardous Waste Under RCRA — 40 CFR Part 261
                      Permitting Under RCRA — 40 CFR Part 270
                      Exemptions From Permitting — 40 CFR §270.1(c)(3)
                      Exemptions from Definition of Solid Waste/Hazardous Waste — 40 CFR
                      §261.4
                      RCRA General TSDF Standards — 40 CFR Part 264/265, Subparts A-H
                      Permit Application Process  — 40 CFR Part 270, Subpart B
                      Land Disposal Restrictions — 40 CFR Part 268
                      LDR Notification Requirements — 40 CFR §268.7
                      Waste Analysis Plans — 40 CFR §268.7(a)(4)
           .    -       Closure and Post-Closure — 40 CFR Parts 264/265, Subpart G §262.34
                      (generator closure)
                      Underground Storage Tanks (USTs) — 40 CFR Part 280
                      State Authorization — 40 CFR Part 271.

        •       For more information on EPA's contained-in policy, consult the regulatory
               interpretive correspondence dated June 16,1989, written from Cannon to Jorling.
               This memorandum is also a part of the RCRA Permit Policy Compendium.
               #9441.1989(30).
        •       For more information on episodic generation and hazardous waste counting, consult
               the March 24,1986, Federal Register (51 FR 10146; March 24,1986).
        •       For more information on the Toxicity Characteristic Leaching Procedure (TCLP),
               consult the March 29,1990, Federal  Register (55 FR 11798; March 29,1990) and the
               Technical Assistance Document for Complying with the TC Rule and Implementing
               the Toxicity Characteristic Leaching Procedure (TCLP) (Revised May 1994) EPA,
               902-B-94-001.
RCRA Overview                          Section 3-35

-------

-------
                                  Section  4
      RCRA  Waste  Generated  by  Wood  Preserving
 Introduction
Health Concerns of
Wood Preserving
Wastes
 The wastes produced from the wood preserving processes
 discussed in Section 2 have been the subject of substantial
 regulatory action in recent years.  In 1990, EPA issued
 final regulations that specifically listed wood preserving
 wastes   from   facilities   that   use   chlorophenolic
 formulations,   creosote  formulations,   and  inorganic
 preservatives  containing arsenic  or  chromium.   The
 types of  wastes  identified  include  wood  preserving
 wastewaters,  process residuals, preservative  drippage,
 and spent preservatives.   In  addition to these specific
 identified wood  preserving  wastes,  wood  preserving
 facilities  can   also   generate  other   "listed"   and
 "characteristic"  wastes depending  on  the processes and
 chemicals used.   Listed  and characteristics wastes,  as
 defined under RCRA, are discussed in Section 3 of this
 Guide.

This  section of the Compliance Guide discusses  three
general  types of  hazardous  waste generated  by wood
preserving facilities:  wastewaters; process residuals; and
preservative  drippage.   It also discusses  some of  the
exclusions  from RCRA that may apply to these wastes at
various stages of the wood preserving.

Wastes   from  the   wood  preserving   industry  can  be
considered hazardous  because  they   are  listed  as  a
hazardous  waste  or  they  exhibit  a  characteristic  of
hazardous  waste.    EPA has  data demonstrating  that
constituents found  in wastes  generated by  the  wood
preserving process, such as chlorophenolics, creosote, and
inorganics  (i.e.,  arsenic   and  chromium)  are  systemic
toxicants  and/or  carcinogens.    Systemic toxicants  are
constituents that may have long-term chronic effects other
than cancer or  mutations.  Carcinogens are constituents
that have the  potential to cause cancer.  Some  of these
wastes may also contain high levels of  dioxins. Given the
high concentrations of these chemicals  typically present in
wastes produced by the  wood preserving industry,  the
potential for harmful exposure to human  if chemicals are
mishandled, can be significant.  Potential for exposure is
most likely to occur through  contact with contaminated
groundwater or chronic occupational exposure.
KC-KA Waste
         Section 4-1

-------
                                                                     June 19,1996
                         For example, previous studies of pentachlorophenol have
                         shown  it to be highly toxic to humans.   Exposure  to
                         pentachlorophenol can cause contact dermatitis, damage to
                         vision,  and upon  ingestion,  lung,  liver,  and  kidney
                         damage.  Inhalation  of pentachlorophenol  can result  in
                         acute poisoning, centering on the  circulatory system with
                         possible accompanying heart failure.  Other studies have
                         also shown pentachlorophenol to be a carcinogen.

                         One of the most commonly used preservatives in  the
                         wood preserving industry is chromated copper arsenate, or
                         CCA.   This formulation contains  water, arsenic acid,
                         chromic acid, and copper oxide.  Overexposure to CCA can
                         damage mucous membranes and tissues of the respiratory
                         system,, or  cause  chemical  burns on  the  skin or .skin
                         lesions.^ .Ingestion of large amounts of  CCA may |ifve
                         more?serious effects. Chronic exposure to significant cfo'ses
                         of CCA Ian lead to mental confusion,  loss of coordination,
                         and impaired senses of touch, pain, and temperature. CCA
                         is also considered a possible carcinogen.

                         Due to these and  other  health concerns, EPA found it
                         necessary to specifically identify wood preserving wastes as
                         hazardous under RCRA.

                         Exhibit 9 provides-an overview .of the material inputs, and
                         pollution outputs -from'the Wood          ""
                                   Exhibit 9
              Wood Preserving Process Inputs and Pollution Outputs
Material Input
Wood; water;
carrier oils;
creosote; inorganic
formulations of
arsenic, chromium,
copper, zinc;
penta-
chlorophenol;
borates; ammonium
compounds


Air Emissions
Boiler emissions,
air-borne arsenic,
poly cyclic
organics, penta-
chlorophenol,
volatile organic
compounds from
carrier oils and
creosote



Process Waste
Dripped
formulation mixed
with rainwater,
wash down water,
detergent, kiln
condensate, contact
cooling water





Other Waste
Sump and retort
sludges, process
residuals including
discarded clothing
and gloves,
banding, wood
stickers, saw dust
and splinters from
the drip pad,
contaminated soils
from storage yard
clean-up
RCRA Waste
                                  Section 4-2

-------
                                                                        June 19,1996
 Wastewater
 Wastewaters  produced  during  the  wood  preserving
 process that are regulated under RCRA can be generated
 during various stages of wood preserving operations.
 These  include  wastewater  generated  during  steam
 conditioning wood in treatment cylinders prior to applying
 preservative,   preservative   formulation  recovery  and
 generation  wastewater,  water  used  to  wash  excess
 preservative from  the surface  of preserved  wood while
 sitting on the drip pad, washdown water used to clean drip
 pads, and condensate from  kilns used to dry preserved
 wood.

 Other operations resulting in the generation of wastewater
 include the rinsing of drums, storage tanks, process areas,
 and equipment.  In addition, water, including rainwater,
 that accumulates on  drip pads  and in retort sumps, and
 rainwater falling on or in the treatment cylinder and work
 tank  secondary containment areas, is  also  classified  as
 hazardous waste.

 Most wastewater generated at wood preserving facilities is
 considered hazardous waste under RCRA either because it
 is mixed with  a listed  waste or  because  it exhibits a
 characteristic of hazardous waste. As a result, many of the
 tanks and other units in which  these wastes are collected,
 stored,  accumulated,  treated, and/or  disposed  will be
 subject to RCRA regulation (a more detailed explanation of
 regulations concerning management of hazardous waste in
 tanks is provided in Section 6 of this Guide).

 Note: Many tanks or sumps that are  used to accumulate or
 treat wastewaters from  wood  preserving  may, in fact, be
 excluded  from  RCRA  regulation.   Wastewater  treatment
 units  subject  to regulation under the Clean Water Act are
 exempt from RCRA  standards.    As a  result, tanks  and
 sumps used to  collect  wastewaters  may  not  be subject to
any standards.  Check with the appropriate State hazardous
 waste  agency  to   determine   the  applicability   of  this
 exemption.

Much  confusion exists as to which wastes generated  at
wood preserving facilities should be counted.   Whether
wastewater is counted toward a facility's generator  status
will depend on  a number of factors.  Specific hazardous
waste counting issues as they relate to the wood preserving
industry are discussed  elsewhere  in  this  section  (See
Exhibit 6, Hazardous Waste Counting).
RCRA Waste
         Section 4-3

-------
                                                                       11*1620,1996
Process Residuals
Note: Wastewater  that  does  not come  into  contact with
preservative  solutions  is  not  regulated  as  listed waste
under  RCRA.    Waste-waters  can,  however,   exhibit   a
characteristic   of  hazardous   waste   depending  on  the
hazardous constituents in  the wastewater.

Materials  such  as  sawdust,  wood  chips,   splinters,
equipment and parts, tags, labels, sand, dirt, and  stones,
that are  attached to wood when it enters the retort are
often washed off during  the  treatment  process.  These
materials can form a  residue in the retort and may settle
out of the preservative solution elsewhere in the process
(e.g., in work tanks, retorts, or sumps). They may also be
intentionally  filtered out of the preservative prior to reuse
in the treatment process.  Other process residuals include
discarded personal protective  equipment  (e.g.,  gloves,
clothing, tyvec suites, boots that have come  into  contact
with  preservative),   used banding  (that  is not  being
recycled), and wood  stickers.  All of these  wastes are
considered process residuals  and must  be handled  as
hazardous  waste under RCRA if  they have  contacted
listed wastes  or if they exhibit a characteristic of hazardous
waste.

Determining exactly  when these materials are generated
for purposes  of making a hazardous waste determination
and complying with  appropriate management  standards
can be  complicated   and  site-specific.  Where  process
residuals are  continually deposited at the bottom of a work
tank or sump, hazardous  waste is not generated until the
work tank/sump/pit is cleaned out  and the  sludge   is
removed.    At  the  time   the   sludge   is  removed,
owners/operators must determine  whether  the waste  is
hazardous.

The generation of  process residuals can  be significantly
reduced  by employing waste  minimization  practices   at
wood preserving facilities.  For example, by power washing
incoming lumber or  by accepting only clean,  high grade
lumber for treatment, owners/operators can minimize  the
amount of hazardous  process residuals generated.
 RCRA Waste
                                   Section 4-4

-------
                                                                         June 19,1996
Drippage and Process
Residuals
Contaminated
Clothing and Other
Materials
Preservative drippage and  process  residuals may  also
accumulate on drip pads, in pathways over which treated
wood is transported, and in treated  wood storage yards.
This category of waste includes drippage of  preservative
from treated wood,  preservative  that is  washed  off
treated  wood by rainwater, and residuals from collecting
and recycling preservative that drips off or is washed off
treated  wood.

Note:   Preservative  that is  washed  off treated  wood  in
storage  yards by rainwater is not specifically  identified as a
RCRA  listed waste, but it may exhibit a hazardous  waste
characteristic.  In addition,  although   the  Subpart  W drip
pad  standards  do  not  apply   to  storage yard  drippage,
drippage of excess preservative  that occurs in storage yards
may be  covered  by the hazardous  waste listings discussed
below if certain chemical formulations  are used,  and must
be cleaned  up immediately in accordance with  the facility's
contingency  plan for  storage  yard drippage (for  a  more
detailed  discussion of EPA's regulation of storage yards, see
Section  6).

Personnel  working at wood preserving facilities  often
produce contaminated personal protective  equipment
(PPE) such as disposable cover-alls, clothing,  gloves,
boots, and  other materials (e.g., trash).  These items  are
commonly sent for disposal or to a  laundering facility so
they can be cleaned and used again.

Contaminated materials that are sent for disposal must  be
handled as RCRA hazardous wastes and manifested to a
permitted or interim status TSDF.  Contaminated materials
that are sent to a laundering facility should be handled in a
safe and protective  manner. Owners/operators of  wood
preserving  facilities  should  ensure  that the  laundering
facility is instructed on safe handling procedures, that  it
segregates  contaminated  materials from others, and that
the  laundering   facility's   POTW   is   aware   of  the
contaminated items  and what kinds  of chemicals  they
contain.  This will enable the  operator of the laundering
facility to make all necessary  arrangements to comply with
Clean Water Act (CWA) requirements.
RCRA Waste
         Section 4-5

-------
                                                                        June 19,1996
Hazardous Wastes
Generated by Wood
Preserving Operations
There are several  EPA-classified hazardous wastes that
may be  generated during,, or  as a  result  of,  wood
preserving operations:

•    F027 — discarded unused pentachlorophenol.

•    F032 — wastewaters, process residuals, preservative
     drippage, and spent formulations  from  plants that
     use  or have  used chlorophenolic  formulations.
     This listing applies to those facilities using "penta"
                               lJ.ua Ilollllg etppucs UJ U.IUDC JLCU.J
                               wood preserving formulations.
                              F034 — wastewater, process residuals, preservative
                              drippage, and spent formulations from plants that use
                              creosote formulations.

                              F035 — wastewater, process residuals, preservative
                              drippage, and spent formulations from plants that use
                              inorganic   preservatives   containing   arsenic   or
                              chromium.
                          •   K001— bottom sediment sludge from the treatment of
                              wastewater from wood preserving processes that use
                              creosote or pentachlorophenol.

                          •   U051 — discarded unused creosote.

                          •   Characteristic Wastes—.constituents included in the
                              toxicity  characteristic that may be  generated  by the
                              wood preserving  industry  include  arsenic  (D004),
                              chromium  (D007),  lead  (D008),  pentachlorophenol
                              (D037), and  wastes containing cresols (D023, D024,
                              D025, D026).  Wastes generated at  wood preserving
                              facilities  may  also  exhibit  the  characteristic  of
                              corrosivity (D002).  This is not an exhaustive listing of
                              all   possible   waste   codes   that    may    apply.
                              Owners/operators must evaluate  their  specific waste
                              streams against the toxicity characteristic constituents.

                          •   K035  — wastewater treatment sludges generated in
                              the manufacturing  of creosote  (this listing does not
                              normally apply to wood preserving facilities).

                          Wastes that meet any one of the above  descriptions must
                          be handled,  stored, and disposed of according to RCRA
                          regulations.
RCRA Waste
         Section 4-6

-------
                               Note: Most wood preserving facilities maintain  tank farms
                               where preservative  is stored  before use.   Although  these
                               tanks  are  not holding hazardous  waste, leaks from  tanks
                               and  valves  have  the potential  to be classified  as listed  or
                               characteristic wastes under  RCRA.  For example,  unused
                               pentachlorophenol, when  leaked,  will  carry the waste code
                               F027,  while  unused creosote  will  carry  the waste code U051.
                               In addition,  any chemical  that is leaked  or  spilled at a tank
                              farm  may  exhibit  a characteristic of hazardous waste.

                               Exhibits 10 and 11  illustrate the types  of  wastes typically
                               generated by the wood preserving industry. This exhibit is
                             ,  intended to  give  owners/operators  of  wood  preserving
                               facilities a general idea of possible hazardous waste codes
                               being  generated  at a facility according  to  the type  of
                               preservative used.
                                          Exhibit 10
           Codes of Hazardous Waste Generated at Wood Preserving Facilities
       Preservative
F032 I  F034 | F035 | K001 | F027 |  U051 |     Toxicity         Not Considered
                                Characteristic(TC)* I Hazardous By US EPA*
WATER-BORNE FACILITIES
 Ammoniacal Copper Arsenate
         (ACA)
 Chromated Copper Arsenate
         (CCA)
      Oxine Copper
  Ammoniacal Copper Zinc
     Arsenate (ACZA)
 Acid Copper Chromate (ACC)
        Borates
  Ammoniacal Copper Quat
        (ACQ)
                               D004, D008
                                                       D004, D008, D007
Note: This chart contains only suggested hazardous waste codes under the toxicity characteristic All of these
presentations may contain other hazardous constituents that would cause it to exhibit the TC for another hazardous
constrtutent.

*   See 40 CFR §261.24 for a complete list of constituents identified under the toxicity characteristic
    Facility is required to make a hazardous waste determination prior to disposal as non-hazardous waste (§262.11).
RCRA Waste
                Section 4-7

-------
                                                                                     11311620,1996
                                          Exhibit 11
                 Wood Preserving Hazardous Waste Code Identification Table

LISTED HAZARDOUS WASTES
TOXICITY CHARACTERISTIC WASTES***
Note: This general guidance may not be accurate in all cases.
WASTE
F032
F034
F035
K001
F027
U051
D002
D004
D007
D008
D023
D024
Wastcwatcr Treatment Unit Sludge
penta
creosote
Door Sump Sludge
pcnta
creosote
inorganics*
Filler Sludge
penta

inorganics*
Waslewatcr
pcnta
creosote
inorganics*



X



X



X






X
X


X



X





















X


X





X


X



X











X


X


X



X











X


X


X



X





X



X



X

X


X



X



X


X


X



X



X

D025


X


X



X

-

X

Process Residuals** 	 J_, 	 ^ 	 , 	 ,
penta
creosote
Inorganics*
X



X



X











X


X


X


X

X


X

Storage Yard Clean-up Material
pcnta
creosote
inorganics*
X



X

Discarded Treated Wood End
User/Customer

creosote
inorganics*








X











X


X


X


X

X


X


X



X

D026


X


X



X



X



X



X

D037

X


X


'
X



X



X



X


Industry TC studies indicate that it falls below TC thresholds. It is'not an F listed waste? / <














X








X

X


X


X




Discarded Unused Preservative (concentrate)















X



X



X


X


X


X









Tank Clean-out Bottoms ..:.:._^- ;• , . ' '-,'-'•'•-,--'••• '•-.

creosote

X



X



X











X


X


X


X

X


X


X






X

X










* Inorganic formulation of arsenic and/or chromium
** See process residual for examples
Note: The Toxkity Characteristic waste code apply only to those wastes that are not already covered by an F, or V waste co
-------
                                                                    June 19,1996
 Exclusions from the
 Definition of Solid
 Waste
Closed Loop
Recycling
 In order for a material to be considered a hazardous
 waste under RCRA,  it must first be classified as  a
 solid waste. Several types of materials, however,  are
 expressly excluded from RCRA's  definition of solid
 waste.  Because they are not considered solid wastes,
 excluded wastes cannot  be  considered  hazardous
 waste  and  are  not  subject  to RCRA  regulation.
 Excluded wastes may include wood preserving wastes
 that are recycled or reused in a manner  consistent
 with normal product handling (e.g., directly returned
 to  the  treatment  process).  The  eligibility of  a
 particular material  for an  exclusion  will  depend
 upon  the  part  of the process from  which  it  is
 produced and the intended use of the material.

 Note:   When  evaluating  the RCRA  exclusions that
 may apply  to  the  reuse  of spent   wood  preserving
 solutions,   it  is   important   to  note   that   wood
 preservative that is directly returned from  the retort
 to  storage  and  mixture  tanks for  reuse,   is  not
 .considered a waste under  RCRA.  Any preservative
 that has  not been  absorbed  by the  wood may  be
 directly pumped   back into  the system  and  reused
 without  ever becoming  subject  to  regulation.   It is
 when   the   preservative   is   taken   out   of  this
 continuous  process loop,  either for  reclamation  or
 disposal,  that it  becomes  subject to regulation  as a
 RCRA hazardous  waste  (e.g., when  it is on the drip
 pad, which  is a hazardous  waste management  unit
 and is not considered  by EPA to be part of a closed
 loop). Owners/operators  are strongly  encouraged  to
 verify the status of a particular waste stream  with  the
 appropriate  State  hazardous waste agency.

 Closed  loop  recycling  involves   processes  where
 secondary materials are reclaimed  and returned  to
 the original process from which they were generated,
 provided a number of conditions are met.   This
 exclusion requires that only tank storage be used, and
 that the  entire  process,  through  completion   of
 reclamation,  be  closed  (e.g.,  there  must   be  no
potential for releases into the environment).

Wastes  generated in the wood preserving  industry
will not usually qualify for the  closed loop recycling
exclusion. This is because a large portion of the waste
RCRA Waste
         Section 4-9

-------
                                                                  June 19,1996
Direct Use/Reuse
generated during the treatment process is generated
when  excess preservative  and  process  residuals
accumulate on drip pads.  EPA has  determined that
drippage  and  residuals  that "escape"  the  wood
preserving process (i.e., wastes that accumulate  on
drip pads) are not eligible for this exclusion because
drip pads are not considered tank storage.

It is possible  that other wastes generated during the
wood preserving process  (e.g., wastes that are not
accumulated on drip pads) could  qualify  for  this
exclusion. For  example, wastes from the treatment
cylinder  that are pumped  back  into the  product
holding tank, but that need some  reclamation  before
being  returned  to  the  tank  (e.g.,  filtration  or
separation)  may meet this  exclusion.   This  is  an
important exclusion to consider if  excess preservative
that  is  removed   from  the  treatment   cylinder
following wood treatment must be  reclaimed in any
way before  reinsertion back  to  the  process  tank.
Normally, any  spent material, such as preservative
solution  that cannot be used further without  some
reprocessing, and which is reclaimed, is considered  a
solid waste and a hazardous waste under RCRA until
the point that it is  reclaimed  and can be used as  a
product again.   Owners/operators  who utilize  the
closed loop exemption will not have to classify these
materials as hazardous  waste, and  will not have to
"count"  these  wastes  each  month  toward their
generator status.

RCRA  also  contains  a specific exclusion  from  the
definition  of  solid waste  for  materials   that  are
recycled through direct use or reuse.  This  exclusion
involves the return  of a chemical to the original
process from which it was generated as a substitute
 for a raw material feedstock.   If the  material  is
 delivered to the process and does not  require or
 undergo any  reprocessing to make  it  suitable for
 reuse,  it may fit this exclusion. In other words, the
 material must  be able to  be directly reinserted back
 into   the   process   without   any   intermediate
 reclamation or  accumulation.  For wood  preservers,
 reclamation  can  include  simple  filtration.  This
 exclusion is different from the closed loop exemption
 in  that there can be no reclamation of  the material
RCRA Waste
                                   Section 4-10

-------
                                                                   June 19,1996
Reclaimed Spent
Wood Preserving
Solutions
prior  to  reinsertion   into  the  process  and  the
exclusion   does  not  require  a  closed  system.
Owners/operators are strongly encouraged to  verify
the  status  of a particular waste  stream with the
appropriate State agency.

To  encourage  the  sound recycling  of  reclaimed
products, EPA has exempted the following materials
from the definition of solid waste:

•    Spent  wood preservative solutions  that have
     been reclaimed and are reused for their intended
     purpose

•    Wastewaters from the wood preserving process
     that have been reclaimed and are reused to treat
     wood.

Under  this  exclusion,   spent  wood   preserving
solutions that have  been reclaimed and are  reused
for  their   original   intended   purpose  are   not
considered solid or hazardous  wastes under RCRA.
Thus,  preservative  that  is  reclaimed  and   then
pumped  from the retort back into  the holding tank
for  storage and reuse  as a  preservative  is  not
regulated under RCRA.  Similarly, wastewater from
the wood preserving process that is "reclaimed"  and
reused to treat wood is also exempt from regulation.

Note:  This exclusion   does  not  provide  a  blanket
exclusion  for  these  materials from their point  of
generation  through reclamation.  Up until the  time
the preservatives or wastewaters  are reclaimed,  the
materials are considereds,  and must be managed as,
solid and  hazardous wastes.

The  exclusions  discussed  above  are very complex.
Determining  whether  materials  generated  at  a
particular  facility are,  in  fact,  excluded  from  the
definition  of solid  waste is  dependent  upon  a
number of site-specific variables. When  determining
whether  one  of these  exclusions  may  apply  to  a
specific waste stream,  owners/operators  may  begin
the assessment by using the following general rule of
thumb. Materials that do not come into contact with
a hazardous waste drip pad, and that  are  directly
RCRA Waste
         Section 4-11

-------
                                                                  June 19,1996
                         reinserted back into the holding tank without being
                         reclaimed first, are not considered hazardous wastes
                         under RCRA, unless sent for disposal. Material that
                         is collected on the drip pad and sent for disposal is a
                         hazardous  waste.   Preservative  solution  that  is
                         collected on the drip pad and reclaimed before being
                         used as a wood preservative is a solid and hazardous
                         waste  up until  the point  it  is reclaimed.   Once
                         reclaimed,, these  materials are  no longer hazardous
                         waste under RCRA.

                         Owners/operators    should    refer    to     their
                         implementing hazardous  waste agency for case-by-
                         case analyses  of  difficult or questionable  regulatory
                         scenarios.    Exhibit  12  is  a  decision  tree for
                         identification of hazardous waste that can be used by
                         owners/operators  to  assist in  making hazardous
                         waste  determinations.
RCRA Waste
Section 4-12

-------
                                                                                           Jvme20,1996
                                              Exhibit 12
          Hazardous Waste Identification for the Wood Preserving Industry
Is Chlorophenolic
Formulation
(e.g., Penta)
Now Used?
No
Yes v
r
, Yes \\
\ 	
Is Waste Unused 1
Penta Formulation?* I No
\

k HrpnQntp 1
/|
V
r

              No
       Is Chromium/Arsenic
          Formulation
          Now Used?
              No
          Does Waste
            Exhibit a
         Characteristic?
              No
          Not a RCRA
       Hazardous Waste
                                                                                    Waste is F027
                                                                                    Waste is F032
>

Has Chlorophenolic
Formulation Ever
Been Used?
>
No
<
Is Creosote I
Now Used? L
L
Yes V Now Used?* |
No
Yes
f


Is Chromium/Arsenic
Formulation Now Used?*
No^
f
Does Waste Exhibit
a Characteristic?
(Toxicity, corrosivity,
reactivity, ignitability}







Yec V
— — 	 V Waste is F034


Yoe V 1 1
ml Waste is F035 1


1 Waste is 1
Yes V^ Characteristic 1
/| and F032** j

	 DIP 	 	 » WT-tn if rm?




                                                      Creosote?
                                                                        Yes
Yes
                Waste is F035
Yes
Waste is a RCRA**
  Characteristic
 Hazardous Waste
       *  Sludges from creosote and/or penta wastewater treatment units
          are K001 waste.
      **  Arsenical-treated wood that is discarded by end users and that
          exhibits only hazardous waste characteristics D004-17 is
          excluded from RCRA regulation.

   Note:  Possible F032 waste code deletion if equipment is cleaned
          according to procedures specified in §261.35.  Also see:
          57 Federal Register, December 24,1992, p61493 -
          Provisional Elimination of F032 Waste Code.
RCRA Waste
             Section 4-13

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                                                                  June 19,1996
Wood Preserving
State Authorization
Issues
As discussed in Section 4, the  status of a particular
rulemaking  in a  State  depends  on  the  State's
authorization status for that rule.  If a rulemaking is
promulgated  pursuant  to original RCRA   (non-
HSWA) language, the rule will not become effective
in a "base" authorized State until that State  adopts
the rule.   Rulemakings  promulgated  pursuant  to
HSWA   of   1984,  however,   will   be  effective
immediately in all States until  each  State adopts the
rule.   Until  States  are able   to  do so,  EPA will
implement  the  HSWA  provisions.    The   wood
preserving industry is a good example  of how both
HSWA  and non-HSWA  provisions  can  work  in
conjunction with one another.  For example, certain
portions of the final  wood preserving rule (55 FR
50450; December 6, 1990) were promulgated  under
HSWA  authority, while  others  were  promulgated
pursuant to non-HSWA authority. The implications
of this are discussed below.

Hazardous waste codes F032, F034,  and  F035 were
promulgated   pursuant   to    different    statutory
authorities.  The F032 listing is a HSWA  provision,
and is applicable in all States, regardless of whether
they are "base" authorized or not. Since the F034 and
F035  listings   are  non-HSWA  provisions,   these
listings  are only effective in those States that are not
authorized  for the "base" RCRA program, and  in
those States that have  incorporated  the listings into
their State programs and received EPA approval for
such revisions. On the other hand, the F034 and F035
listings  are  not applicable in base authorized  States
that  have not yet modified their State  programs to
include  these listings.  In order to become authorized
for  these  listings, a  State must  "pick  up"  the
rulemaking which promulgated the  listings. In this
particular  case, a  State  would  need  to become
authorized for the December 6,  1990,  Federal Register
which is  the  final rulemakings for these listings.
Exhibit  13 illustrates which States have "picked up"
the wood preserving rule, and which have not.
RCRA Waste
         Section 4-14

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                                                                                     June 19,1996
                                            Exhibit 13
            State Authorization/Delegation of RCRA Wood Preserving Rules
         Authorized for Wood Preserving Listing/Final Drip Pad Standards
         Adopted the December 6,1990, Federal Register, but not before obtaining final
         authorization for a particular rulemaking. Thus States must first adopt the
         regulations as part of that State's hazardous waste program. Once the State has
         adopted the standards, Federal authorization can be achieved.
      J  Possibly authorized for other rules, but not for 12/6/90 Federal Register
                                                                                     Subpart W
  I  I  .     fc/     	 "~ 		J ~' w -•-'"• '"f r** rrrm w , ff^^vfjv, n n, IIH-t^L/l H-M \JJ I t-MM-*./ t-/( (-C-/(-tO, J. I HO 11 IU.U U/ltl ffVO£
owners/operators a very good indication of which States are authorized for the rule. For information on other rulemakinss
pertaining to the wood preserving industry, please consult the appropriate State hazardous waste agency.
  RCRA Waste
Section 4-15

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                                                                    June 20,1996
                           Note:  It is important   to  remember   that  wood
                           preserving wastes may carry  waste  codes  other  than
                           F032,  F034,  and  F035.    For   example,   a  wood
                           preserving   waste   could   exhibit    the   toxicity
                           characteristic for lead (D008).  Exhibit  12 focuses  o n
                           the wood  preserving  rule  because it promulgates the
                           listings   most   commonly    generated    at   wood
                           preserving facilities, as well as  the drip pad standards
                           themselves.  Thus,  a State  that has been  authorized
                          for  this  rule  is authorized  for  both  the  wood
                           preserving listings and  the  Subpart  W  standards.  To
                           determine the  status  of  this  waste   stream   in  a
                           particular State,  an owner/operator must check to see
                           if that State  is, authorized  for  the rule  which
                           promulgated   the toxicity  characteristic (March  27,
                           1990,   Federal   Register.  The   same    type   of
                           determination   must  be   made  for  other  wastes
                           generated  at  the facility.

                           The  authorization status  of hazardous waste drip
                           pads is directly tied to  that  of the  wastes  being
                           accumulated on such drip pads. For  example, EPA
                           considers  the drip  pad  standards  to be HSWA
                           requirements when  used  in  conjunction  with the
                           F032 listing.   Thus,  the  Subpart W  provisions  for
                           F032 drip pads will be effective  on the same date as
                           the  F032  listing, and will be administered  by EPA
                           until the  State picks  up the rule. For  F034 and F035
                           drip pads, however, the Subpart W  standards are not
                           immediately effective in base authorized States  since
                           these requirements were not promulgated  pursuant
                           to HSWA authority.  Therefore, the permitted and
                           interim status standards for drip pads associated with
                           F034 and F035 Wastes will only become effective  in
                           base authorized  States when F034 and F035 become
                           hazardous wastes in those States,  and when  those
                           States are authorized  for the drip pad standards.

                           Note: Many wastes generated  on drip  pads may also
                           exhibit the  toxicity  characteristic  (TC).    The  TC,
                           promulgated   pursuant  to  HSWA   authority,   is
                           effective in all States  and implemented  by EPA  until
                           each  State is able to  adopt the  rule  and implement
                           the program.  As a result, drip pads  used  to manage
                           TC wastes must meet the  Subpart W standards.  This
RCRA Waste
Section 4-16

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                                                                   June 19,1996
Pollution
Prevention
Opportunites
is identical  to the authorization  scenario for F032
wastes.

State authorization  of wood preserving wastes and
Subpart W drip pads is a particularly difficult issue,
requiring an in-depth understanding of RCRA's State
authorization  program.   To  accurately  assess  the
status of a  waste  stream  in  a  particular State,
owners/operators must contact the  appropriate State
hazardous waste agency.

The best way to reduce pollution is to prevent it in the
first  place.    Some   companies  have  creatively
implemented  pollution prevention techniques  that
improve efficiency and increase profits while at the
same time minimizing environmental  impacts.  This
can be done in many ways such as  reducing material
inputs, re-engineering processes to reuse by-products,
improving  management  practices, and employing
substitution   of  toxic  chemicals.    Some  smaller
facilities  are  able to  actually  get  below  regulatory
thresholds through  aggressive pollution  prevention
policies.

In order  to encourage these  approaches, this section
provides both general company-specific descriptions
of some  pollution prevention advances  that have
been   implemented   within   the   wood preserves
industry.  While  the list is not exhaustive, it can be
used  as the starting point for  facilities interested in
beginning   pollution   prevention   projects.  The
activities described in this section do not necessarily
apply to all facilities.  Facility-specific conditions must
be carefully considered when  pollution prevention
options are evaluated,  and  facilities must examine
how  each  option  affects,  air,  land,  and  water
pollutant releases.

Water-borne  preservatives produce less waste than
oil-borne preservatives because process wastewater is
reused rather than  discharged.  In addition, well
designed treatment plants, good treatment practices,
effective  housekeeping, and  employee  training also
help reduce waste at the source.
RCRA Waste
         Section 4-17

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                                                                  June 19,1996
                          Well designed treatment plants may have enclosed
                          treatment buildings, covered drip pads with liners,
                          automatic lumber handling systems, centralized tank
                          farms with  spill  containment,  and air  ventilation
                          systems.  Facilities can reduce waste by using drip free
                          trams and dedicated drip pad fork  lifts that  do not
                          track debris into the drip pad. Some facility operators
                          prevent significant spills from incomplete door seals
                          by using  a remote TV  monitor to  quickly discover
                          and correct door leaks. Plants can also be designed to
                          minimize mist or droplet emissions  from cylinders
                          and work tanks  through the  use  of air  exchange
                          systems and cylinder and tank venting.

                          Treatment   practices  are   also  important    for
                          preventing pollution.  Ensuring that wood stock is
                          clean prior to treatment will prevent  dirt, sawdust,
                          and other debris from accumulating in the treatment
                          system.   To  prevent debris buildup,  wood  can be
                          covered  during   shipment   and/or  power-washed
                          before it  enters the  treatment  plant.  Strip  pumps
                          may be  installed  to continuously return residual
                          chemical  solutions to the work tank, resulting, in less
                          dripping  when the  cylinder doors are opened.   If
                          treating cylinders  are tilted slightly away  from the
                          drip pad, there is also less spillage when cylinder
                          doors are opened.

                          CCA facility operators can  reduce the  amount of
                          preservative  that is washed off by rainwater in the
                          storage yard by ensuring that chemical fixation has
                          occured before a charge is moved off of the drip pad
                          or out from  under an enclosure.

                          Housekeeping ^is   an   integral   part   of   waste
                          minimization 'efforts.   All  tanks,  mixing systems,
                          treating cylinders,  drip pads, and spill containments
                          should be inspected regularly for leaks.  Drip pads
                          and collection areas should be kept clean.  Storage
                          yards should be inspected daily, and any drippage
                          should be cleaned up within 24 hours.

                          Several other preservatives have been proposed as
                          alternatives   to   traditional  preservatives.     For
                          example, wood can be treated with borates using both
                          pressure  and non-pressure  processes.    However,
RCRA Waste
Section 4-18

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                                                                  June 19,1996
Pollution Prevention
Case Study
because  they  are highly  susceptible  to  leaching,
berates cannot be used to preserve wood that will be
in contact with the ground or exposed to the weather
(e.g., decking).

Ammoniacal copper/quarternary ammonium (ACQ)
is another  proposed  alternative.    Initial  above-
ground field test data show that ACQ is effective for
softwood  and   hardwood   protection.     Other
alternative  preservatives  may  include  copper-8-
quinolinolate   (Cus),   copper  naphthanate,   zinc
naphthanate,  quarternary NH4 compounds (QAC),
and zinc  sulfate.

Treatment processes  may  vary  in  their  ability to
minimize waste. For example, the empty-cell process
uses less carrier  oil than the full-cell process for oil-
borne  preservatives.     The   modified    full-cell
treatment reduces the uptake of treating solution and
minimizes the amount of dripping from wood that
has been treated with water-borne preservatives.

Perry Builders, Inc. employs 20 people at its pressure
wood  preserving manufacturing  facility.    Perry
Builders  recognizes that each wood  treater  has  an
important responsibility in properly handling and
disposing of the wastes it produces, and is committed
to meeting this  challenge. Perry uses a water-borne
chemical preservative, chromated copper arsenate, to
treat lumber,  plywood, timbers, and  other wood
products for decks, fences,  and  other  outdoor uses.
Hazardous waste results when sawdust, wood chips,
and dirt comes in contact with the preservative.

Perry has successfully minimized its hazardous waste
generation  by 80 percent  in  two years  with  the
implementation  of a low-cost waste minimization
program.   In 1987, Perry generated  15 drums  of
hazardous waste with a disposal cost of $2,380.   By
1989 Perry reduced  its disposal cost to  $310  by-
generating only two drums.

This reduction  was  achieved  by  changing   both
equipment and processes to achieve a fully integrated
closed  system  in which  the  application,  receipt,
RCRA Waste
         Section 4 -19

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                                                                  June 19,1996
Frequently Asked
Questions
Question 1
Counting Hazardous
Waste
                          transfer, and storage of the preservative takes place in
                          a contained area.

                          The goal is  to  apply  the preservative to the wood
                          while minimizing the loss of the  preservative as a
                          waste.   By holding  the lumber in  the  treatment
                          chamber longer to allow drippage, and by using a
                          vacuum  pump to further  dry the  lumber,  the
                          treatment solution remains  in the chamber and does
                          not come into contact with scrap material and dirt. A
                          roof  over  the  area  housing  the  treated lumber
                          prevents runoff during rainfall.  As an incentive to
                          ensure adequate drying time, employ pay is based on
                          hourly wages rather  than  the amount  of lumber
                          treated.

                          Perry Builders estimates that the cost of the vacuum
                          pump, the roof,  and the increased drying time will be
                          recovered in five years through  reduced  disposal
                          costs.  There is also another economic benefit — since
                          the drier lumber weighs  less, more footage of lumber
                          can be shipped on each truck, reducing freight costs.
The   following   are   frequently  asked   questions
concerning regulatory scenarios encountered at wood
preserving facilities.  In every  case, it is imperative
that   owners/operators  consult- the   appropriate
RCRA-delegated   agency   for  final    regulatory
determinations. Responses to these questions assume
that the facility uses creosote, pentachlorophenol, or
inorganic arsenic or chromium, and  that it has the
potential to generate RCRA hazardous wastes.

•   At what point is drippage that is returned to the
    treatment chamber from the drip pad no longer
    considered a solid and hazardous waste?

    Assuming the  drippage is  sent for recycling
    before reinsertion, once drippage  passes through
    the  final  filter into  a holding or process tank
    (not a waste sump), the solution is no longer
    considered a hazardous waste provided it is to be
    used for its originally intended purpose (i.e., to
    treat wood).  However, the  quantity of waste that
    was returned to the  process must be "counted"
RCRA Waste
         Section 4-20

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                                                                  June 19,1996
Question 2
Rainfall
Question 3
Kiln Wastewater
Question 4
Liquid Separation
of Wastes
at least once as waste that was generated at the
facility, and must be applied toward determining
generator status.

Is it acceptable to use meteorological data (e.g.,
rainfall per year) to calculate the contribution of
rainfall  accumulating  on a drip pad toward a
facility's generation of hazardous waste?

Precipitation  hitting a Subpart  W drip pad is
considered    hazardous    waste.        Using
meteorological data to calculate the contribution
of rainfall to wastewater is acceptable, provided
the facility uses the appropriate equipment (e.g.,
a rain gauge)  and is able  to demonstrate  to
inspectors how the calculation was performed.

Does EPA  consider  wastewater  condensate
generated  from   kiln  drying  treated  wood
hazardous waste under RCRA?

Yes, any drippage, condensate, or  wastewater
generated as  a result  of kiln  drying after the
treatment of  wood  meets the  definition of a
listed  waste  under  RCRA   (57  FR  61498;
December 24, 1992).   The specific listing (i.e.,
F032, F034,  or F035)  will  depend  upon  the
chemical formulation  being used at the facility
(the material could also exhibit a characteristic of
hazardous  waste).   It is  important   to note,
however, that steam or condensate which does
not  come into contact with  treated wood or
preservative (i.e., condensate  from steam coils)
does  not  meet   the  definition  of   a  listed
hazardous waste.

A large  quantity  generator  employing water-
borne processes  is air  drying  residual  wood
preserving solution  prior  to the disposal  of
wood chips.    Is this considered "treatment"
under RCRA, and thus subject to permitting
under 40 CFR  Part 270?

Air  drying is  considered a form  of treatment
under RCRA.  According to Federal regulations,
however,  generators  may  treat   waste  in
RCRA Waste
    Section 4 - 21

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                                                                   June 19,1996
Question 5
Switching
Formulations to
Nonhazardous
Generating
Preservatives
accumulation units as long as they continue  to
comply  with   all  appropriate  management
standards described in 40 CFR §262.34  (i.e., the
chips are accumulated in tanks  or  containers
that meet the technical standards for such units
in part 265 of the RCRA  regulations).   As  a
result, no permit  is  required  for   air  drying
activities  unless the generator accumulates the
waste on  site for longer than the allowable 90-
day period provided to large quantity generators
(180 days for small quantity generators).

In addition, if the intent of the air drying process
is liquid or preservative recovery, this treatment
is considered  reclamation, and is exempt from
permitting  under  40 CFR  §261.6(c).   Any
materials  generated as a result  of  this  drying
(e.g., the wood chips  that are sent for  disposal)
are still considered a listed hazardous waste (via
the  derived-from  rule)  and  must be  handled
according to  RCRA  regulations  regardless  of
whether  the  drying  was for treatment  or  for
reclamation.   An exception is if the reclaimed
liquids are to be used again for wood treatment,
in which case it is no longer be considered  a
hazardous waste once reclamation is complete.

Process residuals can  be  placed on  screens  or
racks over  the sump  or  drip  pad to allow
separation  of liquid  from  solids.     Liquid
separation of  residuals  and sludge must  be
performed in a closed, labeled, mesh  box in  a
well-ventilated area. Special precautions should
be taken against the release of process residual
dust once the material has dried.

Does a wood treater (large  quantity  generator)
who  switches to  a  chemical  that  does  not
generate any RCRA hazardous waste  need to
close the facility's drip pad  before  switching
processes?

Yes, the  drip pad must be closed pursuant  to
applicable regulations if the wood treater  wishes
to stop managing  the drip pad as a hazardous
waste management unit  (i.e., complying with
RCRA Waste
    Section 4-22

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                                                                  June 19,1996
Question 6
Discarded Treated
Wood
Subpart W standards). Closure of a drip pad is
not required just  because the facility switches
chemicals.  However,  if an owner or operator
changes  chemicals  without  first performing
clean closure according to the RCRA drip pad
closure  requirements,  the   drip  pad  must
continue to be operated as a Subpart W drip pad
and all wastewater, preservative drippage, and
process residuals subsequently managed on the
drip  pad  must   continue  to  be  treated   as
hazardous waste.

To  operate the  drip  pad as  a  non-hazardous
waste management unit  (i.e., non-Subpart  W
drip pad),  the  large  quantity generator must
follow the general closure standards set forth in
40  CFR §265.111 and  §265.114.   This  self-
implementing performance standard  allows for
the   full  decontamination   of  equipment,
structures, and soils.  If decontamination cannot
be accomplished, the  drip pad must satisfy full
closure requirements under RCRA for landfills.
Finally, the decontamination process should be
fully documented.  Generators must also follow
the §262.34 accumulation  time  provisions  to
accommodate the safe disposal of any hazardous
wastes generated during closure activities.

The  F032, F034,  and F035   hazardous  waste
listings apply to spent formulations from wood
processing    generated   at    plants    using
pentachlorophenol,  creosote,  or  chromated
copper  arsenate.   Are scrap pieces of wood
treated  with  these   preservatives  considered
wastes when discarded?

Wood stickers, slabs, splinters, sawdust, or bark
that are generated as a result of the  treatment
process (i.e., particles  that fall off of wood into
the cylinder, door pit, or drip pad during the
treatment  process)   are   considered   process
residuals  and  thus  listed hazardous  wastes
under RCRA.  These  types  of  wastes are the
direct result of the treatment process  and are
considered part of the facility's waste generation.
Pieces that  are  cut  off  of finished products,
RCRA Waste
    Section 4-23

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                                                                   June 19,1996
Question 7
Refaroactivity of
Waste Listings
     however, or that result  from  damage to the
     finished product after it has been removed  from
     the drip pad, are not considered listed hazardous
     waste. However, waste scraps of wood may still
     exhibit a characteristic of hazardous  waste and
     thus be subject to regulation under Subtitle C of
     RCRA.

 Note:  Discarded wood products that fail the  toxicity
 characteristic for D004-D017 are not hazardous wastes
 due  to  an  existing  exclusion   under  RCRA for
 arsenical-treated wood in §261.4(b)(9).

     The post-consumer disposal of wood products
     that have been treated with chemicals normally
     considered  to  be  hazardous   waste  (when
     generated at wood preserving facilities),  are not
     considered listed  wastes under  RCRA.   For
     example,  creosote treated railroad ties  are not
     listed  hazardous   wastes   when  disposed;
     however, they may  exhibit  a characteristic of
     hazardous waste, in  which case they must be
     managed as hazardous waste.

•    During   remediation   activities   at   a  wood
     preserving facility, soil is excavated and sent for
     disposal.  Because of  limited records concerning
     past operations, the facility is having  difficulty
     determining the applicability of hazardous waste
     listings.   How  is  this  type of  waste usually
     characterized?

     Wastes released prior  to the development of the
     wood preserving listings in 1990 that meet the
     listing description  are not  hazardous  wastes
     unless/until  they are  "actively  managed."
     Active management has been defined by EPA to
     comprise    the    physical   disturbance    of
     accumulated  hazardous waste (57  FR 37284;
     August    18,  1992).     The   excavation  of
     contaminated soils is one example of an  activity
     that EPA considers to  be  active management.
     Once a  waste is actively managed,  hazardous
     waste listings retroactively apply (i.e., waste that
     is actively managed will be  tested against the
RCRA Waste
         Section 4-24

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                                                                 June 19, 1996
Question 8
Underground
Storage Tanks
Question 9
De minimis Wastes
                              current listing description regardless of when it
                              was disposed).

                              In determining whether the material in the soil
                              meets   a   hazardous   waste   listing,   an
                              owner/operator  must  gather enough evidence
                              of processes  employed  at the  facility  (both
                              present and past) to reach an accurate hazardous
                              waste determination.   EPA recognizes that soil
                              may contain  preservative  constituents due  to
                              rainwater  wash-off which does not  meet the
                              listing description  (i.e., wash-off from a storage
                              yard does not meet a listing but still contains trie
                              same constituents  as a listed hazardous waste).
                              Therefore, soils  may contain constituents and
                              not meet the  listing definition, but instead may
                              exhibit a characteristic of hazardous waste.
                              EPA has  made  a clear  distinction
                              drippage and rainwater wash-off:
                                     between
                              "...  The  term  'drippage'   refers  to  excess
                              preservative that is kicked back from the wood
                              following  treatment.    It  does  not  apply  to
                              precipitation that drips from a stack of  wood in
                              the  storage yard when it falls from wood that
                              has  ceased to drip on  the process area  drip pad
                              before being moved to the storage yard (55 PR
                              50452; December 6,1990)."
A wood treatment plant stores copper sulfate in
underground  storage  tanks  for  use   in   a
preservative process. Do the requirements of 40
CFR Part 280  concerning  underground storage
apply to these product tanks?

Yes, these types  of tanks  would be regulated
under 40 CFR Part 280.

What  constitutes "de minimis" drippage for
purposes of Subpart W compliance?

The term "de  minimis" is not used by EPA in
conjunction with wood preserving wastes or the
Subpart  W drip pad standards. De  minimis
RCRA Waste
    Section 4-25

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                                                                  June 19,1996
Question 10
Surface Protection
versus Wood
Treatment
drippage  refers  to  an  exempt  volume  of
drippage,  and  no  volume  of  drippage  of
hazardous   waste  is  exempt  in  the  wood
preserving  industry.   Instead,  EPA  refers  to
drippage from kickback in  the  storage yard as
"infrequent  and incidental drippage."  Kickback
refers to wood preservative  that is generated
from treated wood as the wood begins to return
to normal  pressure  after a  pressure  treating
process.

Facilities must  clean up  kickback within  24
hours  of  the  drippage hitting  the  ground  in
accordance with a facility contingency plan.   If
the release coincides with a holiday or weekend,
the incidental drippage must  be cleaned  up
within 72 hours.

What   is   the  difference   between  surface
protection and wood treatment?

If the purpose  of .the operation is to temporarily
protect  wood against  sap  stains  or  other
discoloration that may form  on the surface of
the wood after cutting, it is considered  by EPA
to
be a wood  surface  protection process.  Wastes
from surface protection operations are currently
not regulated as listed hazardous wastes by EPA.
Wood preserving, on the other  hand, involves
the application of  chemicals  to provide long-
term protection against structural problems in
wood as a result of ground contact, weathering,
or insect damage.
RCRA Waste
    Section 4-26

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                                                                              June 19,1996
Additional information is available on the subjects discussed above:
       •      For general information on RCRA, refer to EPA's RCRA Orientation Manual,
              1990 Edition, EPA/530-SW-90-036.
       •      For information,on the specific regulations, consult the following sections of
              the Code of Federal Regulations:
                      Hazardous Waste Under RCRA — 40 CFR Part 261
                      Definition of Solid Waste/Recycling Exemptions — 40 CFR 261.2
                      Equipment Cleaning Procedures — 40 CFR 261.35
                      Closed Loop Recycling — 40 CFR 261.4(a)(8)
                      Direct Use/Reuse — 40 CFR 261.2
                      Solid/Hazardous Waste Exclusions — 40 CFR 261.(4)(a)(8), (b)(9).
              For more information on hazardous waste counting, consult the May 11,1995,
              Federal Register (60 FR 25510).
              For more information on EPA's decision not to regulate wood surface protection
              wastes, please consult the January 4,1994, Federal Register (59 FR 458).
RCRA Waste                             Section 4 - 27

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Introduction
                              Section 5
                              Drip  Pads
Subpart  W   drip  pads   are   hazardous   waste
management units that are unique to the  wood
preserving   industry.     Drip  pads  are  used  to
accumulate  and  manage excess wood  preserving
formulations  following  the  treatment  of  virgin
timber.  In  many cases, excess formulation  dripping
from the treated wood is considered hazardous waste
under RCRA.

EPA has issued  specific regulations listing  wood
preserving  process wastes  as  hazardous.    These
hazardous  wastes  include  wastewaters,  process
residuals,    preservative   drippage,  and   spent
formulations  from  wood  preserving  operations
using chlorophenolic  formulations   (F032), creosote
formulations  (F034),  and  inorganic preservatives
containing arsenic or chromium (F035) (see Section 4
for a  discussion  of wastes  generated in the  wood
preserving industry).

Due to the nature of wood preserving wastes and the
manner in which they are generated (i.e., over a very
large  surface   area),   EPA  discovered   that   the
regulations governing  traditional RCRA hazardous
waste  management  units  were  not  particularly
useful.  To accommodate  this uniqueness and to
ensure proper  and consistent waste management, in
1990 EPA developed specific standards for the design,
installation,  operation,  and  closure  of  hazardous
waste drip pads by recognizing drip  pads as  a new
type of hazardous waste management  unit  under
RCRA.   This  section  of  the Compliance  Guide
discusses these standards, which  are referred  to as
RCRA Subpart W standards.

Note: Owners/operators of wood preserving  facilities
can use tanks  or  containers  instead  of drip pads to
accumulate  hazardous  wastes that are  generated  in
the wood preserving  industry,  but no drippage  may
occur outside the tank.  Due  to the unique manner in
which  wood preserving wastes are  generated  (e.g.,
Drip Pads
         Section 5-1

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                                                                    June 19,1996
New vs. Existing
Drip Pads
Drip Pad Design
Standards
over  a  very  large surface  area),  use of a  drip pad  is
often   the   most  feasible  way   to   contain   and
accumulate  hazardous  waste that is generated from
the treated wood.  Use of tank storage may Toe feasible
at facilities  using  dip tanks  instead of pressure
treatment.  Also, tanks  and containers  can, and often
are,  used elsewhere  at wood preserving  facilities  to
accumulate other types  of  hazardous waste generated
at other locations on site.

Regardless of  the  management   practice   used  at a
particular  facility,   drippage  that  meets   a  listing
description  or  exhibits  a characteristic  of hazardous
waste that is allowed to fall onto the ground or onto a
non-regulated  unit (e.g., a non-regulated  drip pad) is
considered illegal disposal of a hazardous   waste,  and
may  be subject  to  enforcement   action.   Incidental
drippage in storage yards from charges  of wood  that
remained on  drip pads until  all drippage ceased is  not
considered  a  listed  hazardous   waste.   However,
owners/operators  must maintain  contingency plans
for cleanup of this type of drippage.

Distinctions are made between new and existing drip
pads.    A  drip  pad is  considered  existing  if
construction was completed prior to December  6,
1990.  All other drip pads  are  considered new.   A
"new prime" drip pad is one that contains both a leak
detection and  leak collection system as specified  in
the regulations.  Owners/operators of new drip pads
must comply  with all of  the  standards  discussed
below.  Existing drip pads may need to be modified  or
"upgraded" to ensure adequate protection of human
health  and the  environment.   EPA's regulation  of
existing drip pads is also discussed below.

EPA has established specific drip pad design standards
to ensure that drip pads have  sufficient  structural
strength to prevent  failure of the drip pad under the
weight of wood and equipment.   To accomplish this,
all drip pads must:

•   Be constructed  of non-earthen materials (this
     excludes wood and  non-structurally supported
     asphalt); drip pads are typically constructed  of
     concrete or steel
Drip Pads
          Section 5-2

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                                                                   June 19,1996
                          •    Be sloped to ensure  that drippage, wastewater,
                               and other liquids flow to a collection system and
                               do not "puddle" on the drip pad surface
                          •    Have a curb or berm around  the perimeter  to
                               prevent run-on and run-off
                          •    Be  strong  enough   to   stand  up  to   daily
                               operational  activities, fork  lifts,  traffic, and
                               remain structurally sound and  crack-free.

                          One of  the  main  goals  of  the  drip  pad  design
                          standards is to prevent the flow of waste from the
                          drip pad to the surrounding environment.   Subpart
                          W requires owners/operators  to protect against the
                          migration of hazardous wastes and their  constituents
                          into the environment.  An owner/operator has two
                          design options.

                          The first option is to apply a sealant or coating to the
                          drip pad  surface  to   prevent  hazardous  wastes
                          generated on the drip pad from seeping through the
                          drip pad  and into  the surrounding  environment.
                          Sealants  penetrate the  surface of concrete  drip  pads
                          and  solidify  to  form  an impermeable   surface.
                          Coatings do not penetrate the surface of the drip pad,
                          but rather bond to the surface.

                          Because  concrete, the  most common  construction
                          material for drip pads, is inherently porous, Subpart
                          W dictates the following  performance standard for
                          any sealant or  coating:

                          •    Once a sealant or  coating is applied  to an
                               uncracked drip pad, the drip pad must meet the
                               hydraulic conductivity permeability  rating  of
                               1  x 10'7  cm/sec  (for  more   information see
                               Appendix B for contacts).

                          In general, sealants tend  to  hold  up  better  than
                          coatings under the stresses of vehicle traffic, but tend
                          to crack easily  in conjunction with cracking concrete
                          underneath.   Coatings do not  bond as  well to the
                          concrete, but tend to  flex and  protect the drip pad
                          against micro-cracks.

                          Although the regulations were established under the
                          assumption that concrete would be used  to construct
Drip Pads
Section 5-3

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                                                                  June 19,1996
                         the  drip pad, other  materials, such as  steel,  are
                         acceptable  provided  the   hydraulic  conductivity
                         permeability rating of 1 x 10'7 cm/sec is  achieved.
                         Because uncracked steel meets this  rating by itself, a
                         sealer or coating is not  necessary  to satisfy RCRA
                         requirements.

                         The second option is to install  a synthetic liner and
                         leak  detection system/leak  collection system below
                         the  drip pad to  prevent leakage into  the adjacent
                         subsurface soil, ground water, or surface water.

                         Owners/operators of both new and existing drip pads
                         must employ at least one of these methods to comply
                         with the Subpart W standards (drip  pads  that were
                         constructed between December 6,1990, and December
                         24,1992 do not have to install a leak collection system
                         with their  leak  detection  system).   EPA does  not
                         recommend one option over the other, but believes
                         that installation  of a liner and leak detection system
                         will require less  maintenance and be less costly than
                         repeated application of surface coatings or sealants.
                         Each of the design options for drip  pads is discussed
                         in more detail below.

                         Exhibits 14  and 15 provide a side and front view of a
                         typical drip pad.
Drip Pads
                                   Section 5-4

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                                                                   June 19,1996
                                  Exhibit 14
                        Side View of Typical Drip Pad
                 B
                     D
       H



^



o o

o 



     A   Curb or Berm
     B   Sealer/Coating
     C   Reinforced Concrete Pad: Design will be Determined by Wheel Load
     D   Drainfield of Graded Fill
     E   Perforated or Slotted Pipe Leading to Sump for Leak Detection System
     F   Synthetic Liner
     G   Base to Support Liner
     H   Existing Soil Substrate
                                 Exhibit 15
                       Front View of Typical Drip Pad
    Curb
Impermeable
  Surface/
  Coating
                                   Water Stops
Structurally
Reinforced
 Concrete
             00
                                                 O  0  0
                            LEAK DETECTION SYSTEM
                                W///////////2.
                               SOIL SUBSURFACE
Drip Pads
                       Section 5-5

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                                                                   June 19,1996
Sealed Drip Pads
Drip Pad Liners
Owners/operators  electing to  apply  a  coating or
sealant to a drip pad must cover the entire surface of
the drip pad.  The material used to seal the drip pad
must be compatible with  the  wood  preservatives
used by  the  facility and must meet the hydraulic
conductivity  requirement of 1 x 10"7 cm/sec specified
in the regulations. Additional factors that should be
considered to ensure  that  the coating selected  will
achieve its standard for a particular use:

     Chemical resistivity
     Physical compatibility with service
     Adhesion capacity to substrate
     Temperature resistance
     Flexibility
     Scrub ability
     Resistance to abrasion and impact
     Toxicity
     Drying and curing time
     Method and ease  of application.

In  addition  to selecting  a compatible  sealant or
coating, proper application of the product is crucial in
meeting  the  drip  pad  design  standards.   Proper
installation  not only ensures  that the hydraulic
conductivity standard will be achieved, but may also
prolong  the  effectiveness  of  a  particular  coating,
reducing the necessity  and frequency  of reapplication.
Coatings and  sealers should be chosen based on the
service they will see on  the drip pad.  For example,
forklifts  operating  on a common  area  have  been
known  to tear coatings,  while  sealers  have  been
found to better withstand this type of pressure.

Owners/operators who choose to install  a liner and
leak detection system must also follow  certain design
criteria.  Specifically, each liner must:

•    Prevent leakage during the active life of the drip
     pad
•    Resist absorption of waste
•    Be constructed of  material  that  is strong and
     thick enough to prevent failure of the system
•    Be placed  on  a foundation  or  base which  can
     support the liner
Drip Pads
          Section 5-6

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                                                                    June 19,1996
 Leak Detection
 Systems
Liquid Collection
Systems
 •   Cover all surfaces that could come in contact
     with waste or leakage.

 During construction or installation, each liner must
 be inspected for structural defects.  After construction,
 a registered,  independent,  professional   engineer
 must certify that the pad meets all requirements set
 forth in the Subpart W regulations.  This  certification
 must be kept in the facility's operating log.

 There are several specifications for the drip pad leak
 detection systems that are used in conjunction with
 the synthetic liner. Leak detection systems must be:

 •   Located immediately above the liner
 •   Constructed of materials which can chemically
     resist waste and physically resist pressure from
     above
 •   Designed to detect drip pad failure or the release
     of hazardous waste or accumulated liquid at the
     earliest practicable time
 •   Designed  and  operated to  function  without
     clogging.

Owners/operators of Subpart W drip pads installed
after December 24,1992 choosing to comply with the
synthetic liner  option must also equip  the drip pads
with  a leak collection  system to  remove  waste
accumulating on the liner.  If this collection system
involves the use  of a  tank or  sump to collect any
excess liquids, the tank or sump will be subject to the
management standards applicable to hazardous waste
tanks under RCRA Subpart J.

Tanks and  sumps   that  are   part  of  wastewater
treatment  units  may  be exempt   from  RCRA
regulation if they  are otherwise  subject to regulation
under the Clean Water Act (CWA). A discussion of
Subpart J is provided in Section 7.

Drip pad leak collection systems must be:

•   Located immediately above the liner
•   Designed, constructed, maintained, and operated
    so that leakage can be removed from below the
    drip pad
Drip Pads
         Section 5-7

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                                                                  June 19,1996
Run-on and Run-off
Control
Drip Pad Operation
•   Designed and  operated to  convey, drain,  and
    collect liquid in a way that prevents run-off
•   Emptied as necessary to ensure that the capacity
    of the system is maintained.

Note:  Leakage  collection  systems must  be :a collection
device  separate  from the  sump  or tank system used
to collect liquid flowing off of the drip pad.

Drip pads that  are not inside or otherwise covered
must be equipped with run-on  and run-off control
systems able to collect and control  the volume  of
rainwater from a 24-hour, 25-year storm. This system
must be designed and operated  to stop the flow of
water both onto and off of the drip pad. In addition,
any collection  units  associated  with  such systems
must be emptied as soon as possible after  storms to
maintain the system's  design capacity.

Note: Regardless  of whether a pad is covered,  a  curb
or berm  around  the  perimeter  of  the drip  pad is
required.
There  are  several  requirements
operation of drip pads.
concerning
            the
                              The entire  surface  of the drip pad must be
                              cleaned to allow  for  weekly inspection.   The
                              frequency  and method  of  cleaning  must be
                              documented in the operating log (residues from
                              drip pad cleaning are hazardous waste and must
                              be managed accordingly).
                              Drip pads must be maintained free of cracks that
                              would  otherwise  adversely  affect hydraulic
                              conductivity,  corrosion, or  deterioration  that
                              could result in leakage.
                              The drip pad must  be operated in a way that
                              minimizes the tracking of hazardous waste off
                              of the drip pad by  personnel and equipment.
                              This may  be accomplished  by  controlling
                              employee access and having  a dedicated forklift
                              on the drip pad.
                              After treatment, wood must remain on the drip
                              pad until all drippage has ceased. The operating
                              log must document that each charge has stopped
                              dripping before it is  removed from the pad.
 Drip Pads
          Section 5-8

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                                                                   June 19,1996
 Temporary
 Accumulation of
 Hazardous Waste on
 Drip Pads
 •   Collection systems and holding units for run-on
     and run-off control must be emptied as soon as
     possible after storms.

 As discussed in  Section 3 of this  Guide, generators
 may use drip pads as hazardous waste accumulation
 units  to temporarily  store  hazardous  waste.   A
 generator who  accumulates hazardous  waste  on a
 drip pad for 90 days or less is not required to obtain a
 RCRA storage permit as long as:

 •   The drip pad satisfies technical standards set out
     in the regulations
 •   The facility has  written  procedures to ensure
     that wastes are  removed  from  the  pad  and
     collection system at least every 90 days
 •   Records  are  kept  documenting   that  these
     procedures are followed,  the  date and time  of
     removal, and the quantity removed.

 This 90-day limit applies to both large quantity and
 small  quantity  generators.   While  small  quantity
 generators  may normally  accumulate  hazardous
 waste in accumulation units for up to  180 days, this is
 not   the  case  for  small   quantity  generators
 accumulating  waste  on  Subpart W   drip  pads.
 Owners/operators of wood preserving facilities who
 generate between 100-1000 kg of hazardous waste per
 calendar month  and who  accumulate the waste  on
 drip pads are not eligible for  the reduced standards
 normally provided for small  quantity  generators.
 Instead,  these generators must comply with all the
 management   requirements   for   large   quantity
 generators  accumulating  hazardous  waste  on  drip
 pads.

 Note:  Hazardous waste that is generated elsewhere  at
 the wood preserving  facility  and  accumulated  in
 tanks or containers  (i.e.,  not  accumulated   on  drip
pads) will remain subject to small quantity generator
standards.  Only  waste  that is  accumulated   on  drip
pads must  adhere  to  the  large  quantity  generator
standards.

 Conditionally exempt  small quantity generators are
not subject to the 90-day accumulation limit, nor are
Drip Pads
         Section 5-9

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                                                                  June 19,1996
Assessment of Drip
Pad Integrity
Existing Drip Pads
they required to accumulate  their hazardous wastes
in any particular type of unit, including drip  pads.
Allowing hazardous waste to fall onto the ground is
viewed as illegal disposal, and  may result in an
enforcement action if inspectors determine that such
disposal    threatens   human   health   or   the
environment.   As such, it is prudent for all wood
preserving facilities,  even  if conditionally exempt, to
ensure that they are operating  their drip pads in an
environmentally safe and responsible manner.

Many  wood preserving facilities  were  already  in
existence when the  drip pad standards were  first
issued. In fact, many facilities had been in operation
for a number  of years prior to development of the
standards,  and had  been  using drip pads to collect
drippage from treated wood. In light of the potential
cost to the existing  facilities to upgrade every drip
pad, EPA  developed  a certification  program  that
allows owners/operators  to  assess and  certify the
integrity of existing drip  pads until  all repairs  or
upgrades have  been made. By upgrade, EPA means
the installation of a leak detection and leak collection
system, not the application of a sealant or coating.
Although  owners/operators  may still select which
compliance option  to implement,  only  a drip pad
that has  a leak detection/leak collection system will
be considered  "upgraded" for  purposes of  these
standards.

Until a drip pad has  been upgraded to include a liner
and   leak   detection/leak    collection   system,
owners/operators must evaluate  each existing drip
pad to determine the extent to  which  it meets  all
Subpart  W design and operating  requirements.  A
written assessment  of the drip pad,  attesting to the
results of  the  evaluation, must  be certified by  an
independent,    qualified,  registered   professional
engineer and  kept  on file   at  the  facility.    This
assessment must be  renewed, updated, and recertified
annually until all upgrades have been made.

Although  owners/operators  may choose to apply a
sealant and not install a liner in order to comply with
applicable requirements,  only those  who  install a
liner and  leak detection/leak collection system are
 Drip Pads
                                   Section 5-10

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                                                                    June 20,1996
                           relieved  of the responsibility to conduct an  annual
                           assessment of the  drip pad's integrity.   Even  if a
                           facility installs a new drip pad and chooses to apply a
                           coating or sealant instead of  a liner  system, the
                           Subpart W standards still require an annual drip pad
                           assessment.  Thus, when determining which upgrade
                           option  is  most  suitable to  a particular  facility,
                           owners/operators   should  compare  the  cost  of
                           performing  annual  assessments  to  the  cost  of
                           installing a liner system.

                           Note:    Existing   drip   pads   constructed  between
                           December 6, 1990, and  December 24,  1992, that are
                           being  upgraded only require the  installation  of a leak
                           detection  system, and  not a leak collection  system as
                           well.  Any drip pad constructed  after  December 24,
                           1992, must include  both  a leak  detection  and leak
                           collection  system  to  be  considered  "upgraded"  for
                           purposes  of Subpart  .W.   EPA does  recommend
                           installation of both  to ensure  protection  of human
                           health  and the environment.    See  Exhibit  16 for
                           design  and certification requirements.

                          .Although there  is  no  specified date  by which all
                           facilities  operating Subpart   W  drip  pads  must
                           demonstrate that  existing drip pads meet upgrade
                           requirements,  EPA feels that  most  facilities. will
                           choose to upgrade their  drip pads with a liner and
                           leak detection/leak collection system in light of long-
                           term cost savings  to the  facility.  Once a facility has
                           upgraded  its  drip pads to comply with  the  leak
                           detection/leak  collection  system and  has obtained
                           proper certification,  no further annual  assessment is
                           required.
Drip Pads
Section 5-11

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                                                                   June 19,1996
New Drip Pads
New  drip  pads  must  be  assessed  upon  initial
construction. • During construction or installation, all
liners  and  cover systems must be  evaluated  for
uniformity, damage, and  imperfections  (e.g., holes,
cracks, spots) that could potentially affect  the  drip
pad's ability to protect against preservative leakage to
the surrounding environment.  Once construction is
complete,  the  drip  pad must be  inspected  by an
independent,    qualified,   registered   professional
engineer to ensure that it meets  all  applicable design
requirements.  All certifications must be kept as part
of the facility's  operating  log.   Unlike existing drip
pads that have  not yet been fully upgraded,  there are
no annual recertification requirements for new drip
pads that have  been constructed with a liner and leak
detection/leak  collection system.  Exhibit 16 contains
a  summary of  the  drip  pad construction  and
certification requirements.

Note:   EPA strongly encourages  the' use of  both a
liner system and application of a  coating or sealant to
the ' drip  pad   to  ensure  safe  hazardous   waste
management.   This  will help to  prevent  present and
future   threats   to   human    health   and   the
environment  posed  by accidents,   leaks,  or general
wear  and tear.
 Drip Pads
                                    Section 5-12

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                                                                    June 19,1996
                                   Exhibit 16
              Drip Pad Construction and Certification Requirements

Type of Drip Pad
Existing Drip Pad
(Constructed* Before
December 6, 1990)

New Drip Pad
(Constructed* Between
December 6, 1990)
and
December 24, 1992)

New Drip Pad
(Constructed* After
December 24, 1992)

— *
— *>
-

-*
Construction Options
Apply Impermeable
Sealant or Coating
OR
Upgrade Drip Pad to Install
Liner and Leak Detection/
Collecting System

Sealant or Coating that
meets lxlO-7cm/sec
OR
Install Liner and Leak
Detection System

Sealant or Coating that
meets lxlO-7cm/sec
OR
Upgrade Drip Pad to Install
Liner and Leak Detection/
Collecting System
T:
— *
—*>

— >
-

ype of Certification Required
Annual Professional
Engineer (PE) Certification

One-Time PE Certification of
Drip Pad Liner

Annual PE Certification of
Drip Pad

One-Time PE Certification of
Drip Pad and Liner

Annual PE Certification of
Drip Pad

-*
One-Time PE Certification
of Drip Pad and Liner



* "Under Construction" includes those drip pads for which an owner/operator signed or entered into a
binding financial agreement for construction prior to this date.
Inspections
Drip pads must be inspected weekly and after storm
events.   The inspection must  include checks  for
deterioration  of the  run-on  and  run-off  control
systems, the presence of leakage, proper functioning
of the leak detection system, and deterioration of the
drip pad surface.  Records  of drip  pad inspections
should be maintained  at the facility for at least three
years from the date of inspection. Exhibit 17 contains
information  concerning a facility's obligations with
respect to drip pad inspection and maintenance.
Drip Pads
         Section 5-13

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                                                                     June 19,1996
Operating Log
                      A  drip  pad  owner/operator  must  comply  with
                      several recordkeeping requirements.  Facilities are
                      required to keep an operating log to document many
                      of  their  activities  with   respect  to   drip  pad
                      maintenance  and  the  management  of hazardous
                      waste. It is advisable to keep all information  related
                      to  hazardous  waste  management  activities  in the
                      operating log.

                              Exhibit 17
                    Responding to Drip Fad Cracks	_____
                       Did the Crack(s)
                          Lead
                        To a Release
                         To the
                         vironment?
  Does the
  Drip Pad
Have any Cracks?
                        Does Crack
                         Effect the
                         Hydraulic
                        Conductivity
                         of the Pad?
                          Check Pad
                          Frequently
                        (Recommended)
1.
2.
3.
Take Cracked Portion of
the Pad Out of Service
Notify the EPA Regional
Administrator or
Delegated State Director
Within 24 Hours
Record Release in
Operating Log

2. Repair Crack
^.Jr
/I Obtain RecertificatiorN.
/ 2. Renotify EPA Regional^
I Administrator and i
                                    Take Cracked Portion of Drip
                                     Pad Out of Service and
                                          Repair
                            The  following  operations  and  activities  must  be
                            documented in the facility's  operating log:

                            •    Leakage/drippage — date, time, and quantity of
                                 leakage collected and  removed  from  leakage
                                 collection system, drip pad, and sump

                            •    Drip Pad Cleaning — date and time of each drip
                                 pad and all cleaning procedures

                            •    Drip Pad Operation — documentation  that  all
                                 treated wood is held on the pad until  drippage
                                 has ceased
 Drip Pads
                                     Section 5-14

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                                                                   June 19,1996
Releases of
Hazardous Waste
from Drip Pads
 •   Inspections — documentation of all inspections
     conducted in accordance with the requirements
     of Subpart W.  To inspect a drip pad, owners/
     operators   must    look   for    deterioration,
     malfunctions or improper operation of run-on
     and run-off control systems, proper operation of
     leak detection systems and leakage from  these
     systems, and deterioration or cracking of  the
     drip pad's surface.

 •   Waste Handling —  documentation of facility
     waste handling practices, including preservative
     formulations  used  in  the   past,   drippage
     management practices, and treated wood storage
     and handling practices.  The log must describe
     the operation  that will  be followed to ensure
     that all wastes are  removed  from the  drip pad
     and collection system at least once every 90 days.

 There  are  several steps a facility must take in  the
 event of a release of hazardous waste from a drip pad.
 Upon discovery of a release, owners/operators must:

 •   Discontinue operations  on the affected portion
     of the drip pad
 •   Record  the leak in the facility  operating  log,
     noting the date and time
 •   Determine what repairs are required,  remove
     leakage  from below  the pad,  and  establish a
     schedule for cleanup and repair
 •   Notify the  EPA  Regional  Administrator  or
     delegated State  director within  24 hours  of
     discovery, and provide a written description of
     the planned cleanup and repair within 10 days
 •   Promptly perform repairs
 •   Following completion of  repairs, notify  the EPA
     Regional  Administrator in  writing  that  the
     cleanup   and   repairs   were   completed   in
     accordance with the previously submitted plan.
     This  notification   must  be  certified  by  a
     registered, professional engineer.

Note:   It   is  not   EPA's   intent    to   require
owners/operators  to   notify   the  EPA   Regional
Administrator for every  repair made to a Subpart  W
drip  pad. The owner/operator must notify  the  EPA
Drip Pads
         Section 5-15

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                                                                   June 19,1996
Contingency Plans
Regional Administrator  or  State director only when
there has been an actual release of hazardous waste
from the drip pad.  Cracks and other conditions  that
have the potential to lead to  a  release  in  the future
need not be reported.   Owners/operators  must  still
make all appropriate  repairs in  a timely fashion  and
note the  repairs in the facility  log.

Each facility must develop a contingency plan  that
describes the steps an  owner/operator will  take  in
response to a leak of hazardous waste from drip pads.
Large quantity generators are required by regulation
to develop  such  plans  and amend them  whenever
necessary.   A copy of the contingency plan  must  be
maintained at the facility and submitted to all local
police departments, fire departments, hospitals, and
State  and   local   emergency   response   teams.
Contingency  plans   must  contain  the  following
information:

•    General information about the facility
•    The name, address, and phone number of the
     emergency  coordinator   and  an   alternate
     emergency coordinator
•    Emergency procedures to  be  followed  in the
     event of a spill, fire, or explosion
•    The evacuation  plan and a list of all emergency
     equipment at the facility.

Small quantity generators are also required  to have
contingency plans.  These plans may be less  detailed
than those required for large  quantity generators.
However,   because  they  are  held  to  the same
standards   as  large  quantity  generators   when
accumulating hazardous waste on drip pads, small
quantity generators  are required  to develop  full
contingency plans identical to those required  of large
quantity generators.    Conditionally  exempt small
quantity generators  are not required  to  maintain
contingency plans under RCRA, but are encouraged
to do so.

Note: 'This facility contingency plan is different from
the  storage  yard  clean-up plan  that  is also  required
under the drip pad standards.
Drip Pads
         Section 5-16

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                                                                   June 19,
 Closure of Drip Pads
Frequently Asked
Questions
Question 1
Closure Timeframe
 To ensure that drip pads are properly managed when
 operations  have  ceased, all  drip  pads  must  be
 "closed" in a way that prevents future migration of
 contaminants into the  environment.  Closure of a
 drip pad involves removal or decontamination of all
 waste residue, contaminated soils, and equipment.  If
 it  is  impossible  or  impractical  to remove   all
 contaminated soil,  the  unit must  be treated and
 closed in a manner  similar  to  a hazardous  waste
 landfill.  Generators  accumulating hazardous  waste
 on drip pads are also subject  to  certain closure
 requirements.    For a more  detailed  discussion
 concerning   generator   closure  requirements,  see
 Section 3 of this Guide.

 Upon closure, owners/operators may also choose to
 remove  and  dispose of old  drip  pads at a facility.
 These drip pads will most likely be considered listed
 hazardous  waste by virtues of being  debris which is
 contaminated with  a listed  hazardous waste  (e.g.,
 F032, F034, F035). In such cases, it is possible to grind
 and separate the drip pad into those  portions which
 do contain  listed  hazardous waste,  and  those that
 remain uncontaminated because they never had any
 contact with a listed waste at all.  By separating the
 two waste  streams,  owners/operators  can reduce
 waste  management  costs by  sending  only  those
 portions  of the drip pad that are contaminated with
 listed hazardous waste to a hazardous waste landfill.

 The  following   are  frequently  asked   questions
 concerning regulatory scenarios encountered at wood
preserving  facilities.  Please consult the appropriate
implementing    agency   for    final   regulatory
 determination regarding site-specific situations.
     Once a large  quantity generator begins closure
     activities on a Subpart W  drip pad, is there  a
     specific   timeframe   during  which   closure
     activities must be completed?

     There is no specified time frame  during which
     generators accumulating hazardous waste on
     drip  pads must  complete closure activities;
     however, other RCRA regulations may prevent
Drip Pads
         Section 5-17

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                                                                  June 19,1996
Question 2
Drip Pad Cleaning
owners/operators from accumulating hazardous
waste  on-site  longer  than  90  days  without
obtaining a RCRA permit. Section 262.34 allows
large  quantity  generators   to   accumulate
hazardous waste on-site for  up to 90 days.  A
large quantity generator in the process of closing
a drip pad will, in fact, lose its generator status if
closure activities necessitate storing hazardous
waste on site for longer than 90 days. If the 90-
day  limit is exceeded,  the  facility  will enter
interim  status,  and   all  applicable   closure
timelines for interim status facilities will apply.

Although no  timeframes exist for generator
closure  activities   on  the   Federal  level,
owners/operators    should    consult     the
appropriate  State  hazardous waste  agency  to
learn of possible State regulations.  Many States
allow no more than 180 days to complete closure
activities.

Subpart W  requires owners/operators  to clean
the  hazardous  waste  drip pads  to allow  for
weekly inspections.  Is shoveling the drip pad
considered an appropriate method for  meeting
this requirement?

EPA  intentionally   developed  the drip  pad
cleaning requirements to be performance-based.
Thus, any method that allows owners/operators
to  effectively  conduct  the  required  weekly
inspection of the drip pad is appropriate. When
performing          cleaning        activities,
owners/operators must take special precautions
to avoid damage to the impermeable surface of
the drip pad (if owners/operators have chosen
to comply with that design option).
Drip Pads
     Section 5-18

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                                                                   Jtmel9,1996
Question 3
Curbs on Covered
Drip Pads
Question 4
Certification of
Operating Practices
Question 5
Upgrading Drip Pads
If a drip pad is covered by a  roof, is a curb
required?

In order to meet the Subpart W  drip pad design
criteria, a drip pad must have a curb to prevent
precipitation run-off and run-on.  However, if a
drip pad is inside or under a cover (i.e., a roof)
and the surrounding landscape is graded so that
run-on cannot occur, the drip pad curb need not
be very high  to  prevent   run-on  and   run-
off  of    rain  occurring during a 24-hour, 25-
year storm. The requirement in  §265.443(f) is
designed for those facilities that do  not have
enclosed drip pads.

Structures built over drip pads should meet the
following specifications:

1.    The  structure must  cover the  drip pad
entirely and have eaves that extend beyond the
curb of the  drip pad to prevent most wind-
blown  rain  from  hitting   the   drip  pad.
Owners/operators may also install walls outside
the curb to serve the same purpose.

2.   Owners/operators  should   install  rain
diverters,  gutters,   or  similar   devices  that
prevent water from running off the roof and
onto the drip pad.

Is the  professional  engineer (PE) certification
required to  address operating conditions at the
facility in addition to assessing and certifying the
drip pad's integrity?

No,  the purpose of the  PE  certification is  to
assess the physical and  structural aspects of the
drip pad, not the facility's operating practices.

Are  owners/operators  of  existing  drip  pads
required to upgrade their pads to meet all of the
design criteria of Subpart W?  If so, when must
these upgrades be complete?

No, the final drip pad standards do not contain a
final deadline by which owners/operators must
Drip Pads
    Section 5-19

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                                                                   June 20,1996
Question 6
Collection System and
Drip Pad Clean-out
    upgrade their drip pads to install liners and leak
    detection systems.  Instead, owners/operators of
    existing pads that have not been upgraded must
    continue to annually certify the integrity of their
    existing  drip  pad  until   such  upgrades  are
    completed.  A written plan for upgrading is only
    required if the treater  plans to upgrade the drip
    pad to include a liner.   Such  plans must  be
    submitted at least two years prior to upgrading.

•   After cleaning the drip pad and the collection
    system (sumps)  every 90  days, as required for
    large and small  quantity generators, how  long
    can the hazardous waste remain on site?

    If the  hazardous  waste is placed  in  satellite
    accumulation areas, the waste can remain there
    until the  drum is full.  Once the drum is full, it
    must  be dated and moved to  the hazardous
    waste   storage  area.    The   90 or  180   day
    accumulation clock starts  once the hazardous
    waste has been sealed into  a drum or placed in a
    tank.

Note:  If the sump is in compliance  with  Subpart J, it
does not have  to be cleaned  out  every 90 days.  Waste
is generated only when it is cleaned out.
Drip Pads
         Section 5-20

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                                                                               June 19,1996
 Additional information is available on the subjects discussed above:
        •      For general information on RCRA, refer to EPA's RCRA Orientation Manual,
               1990 Edition, EPA/530-SW-90-036.
        •      For information on the specific regulations, consult the following sections of
               the Code of Federal Regulations:
                      New vs. Existing Drip Pad — 40 CFR 265.440
               -  .    Assessment of Existing Drip Pad Integrity — 40 CFR 265.441
                      New Drip Pad Design Standards — 40 CFR 264.573 and 265.443
                      Sealed Drip Pads — 40 CFR 265.442
                      Drip Pad Liners — 40 CFR 264.573 and 265.443
                      Leak Detection/Collection Systems — 40 CFR 264.573 and 265.443
                      Uncovered Drip Pads — 40 CFR 265.440
                      Drip Pad Operations — 40 CFR 265.443
                      Temporary Accumulation of Hazardous Waste on Drip Pads — 40 CFR
                      262.34
                      Releases of Hazardous Waste from Drip Pads — 40 CFR 265.443, 265.445
                      Recordkeeping and Reporting Requirements — 40 CFR 265.444
                      Contingency Plans — 40 CFR 265.440
                      Closure of Drip Pads — 40 CFR 265.111,265.114,265.445.
Drip Pads                                Section 5 - 21

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Introduction
                               Section  6
                           Storage  Yards
Most wood  preserving  facilities  maintain  storage
yards to hold treated charges of wood until they are
sent off-site for sale.  Because of the  high cost of
controlling wastes  in storage yards (e.g.,  building
storage  sheds and  paving storage yards), EPA  has
imposed  minimal   RCRA  regulation   on   the
management of  storage yards at wood preserving
facilities.  Because of enhanced waste minimization
efforts throughout  the wood pSreserving  industry
and the drip  pad operating standards of Subpart W,
little waste, if any, is generated in these areas.

The drip pad regulations require that all  treated wood
(from both pressure and non-pressure  processes) be
held  on  drip  pads  until  drippage  has  ceased.
Incidental and infrequent drippage in  the storage
yard from a charge that stopped dripping before it was
removed from  the drip pad is not considered illegal
disposal if it is cleaned up within 24  hours (or 72
hours  if  the  drippage   occurs  on  a  holiday  or
weekend)   in    accordance   with   the   facility's
contingency plan. Drippage that is cleaned up must
be handled as hazardous waste.

The contingency plan  must  be  developed  and
maintained  on file at the facility. The  contingency
plan must describe how the facility will:

•    Clean up  any  drippage within  72  hours  of
     occurrence (not detection)
•    Document the cleanup  of such drippage,  and
     retain records  of the cleanup for  a period of
     three years
•    Manage  any contaminated  media  (e.g.,  soil,
     water)   as  F-listed   hazardous   waste    or
     characteristic hazardous waste.

EPA expects  an  adequate storage yard contingency
plan to include frequent storage yard inspections, to
ensure that incidental drippage and soils are cleaned
Storage Yards
         Chapter 6 -1

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                                                                   June 19,1996
Stormwater Run-off
in Storage Yards
up within 24 hours (72 hours if  over a holiday or
weekend).

EPA  encourages owners/operators of  facilities  to
develop grid locator systems in their storage yards to
facilitate  the tracking  of  cleanup activities.    In
addition, EPA also recommends constructing covered
storage yards to reduce the  potential  of run-off
contamination.

Generally, stormwater runoff in storage yards is not
considered a listed waste. EPA has clarified  that the
hazardous  waste  listings  for   wood   preserving
chemicals do not apply to precipitation run-off from
treated wood in storage yards without  drip  pads,
where the owner or operator has allowed the treated
wood to sit on the  drip pad until all drippage has
ceased.   This is  consistent   with EPA's  general
position that the derived-from rule does not  apply to
precipitation run-off (see 40 CFR 261.3(c)(2) and 45 FR
33096; May 19,1990). Stormwater  that  falls  onto the
drip pad, however, and that is collected and disposed,
will be considered a listed waste and subject to RCRA
regulation.

As discussed above, owners/operators  must   keep
treated wood on drip  pads until all drippage has
ceased. In order for precipitation run-off in storage
yards not to be considered a listed hazardous waste,
an owner/operator  must show through its records
that the facility complies with this requirement.  In
the case  of  incidental  drippage  in   storage yards,
owners/operators must  maintain  a spill  contingency
plan for such occurrences.  If the facility does not
have  documentation that it is  in compliance  with
Subpart W,  EPA can  assert  that the  stormwater
transported  a listed hazardous  waste  and  that the
resulting sludge also carries the listing.

EPA encourages the  construction of stormwater  run-
off mitigation systems and the  appropriate handling
of  sediments  generated   as   a  result  of   such
management. In addition, any of these wastes may
exhibit a characteristic  of  hazardous  waste,  even
though they may not meet a listing description.
Storage Yards
         Chapter 6-2

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                                                                                June 19,1996
Additional information is available on the subjects discussed above:
        •       For information on the specific regulations, consult the following section of
               the Code of Federal Regulations:
                      Storage yard contingency plans — 40 CFR §265.440(c).

        •       For more information on the management of drippage in storage yard, consult the
               regulatory interpretive correspondence dated May 31,1991, written from Lowrance
               to Hazardous Waste Management Division Directors.  This memorandum is also a
               part of the RCRA Permit Policy Compendium. #9489.1991(02).
Storage Yards  *                          Chapter 6 - 3

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Introduction
                               Section  7
                        Tanks and  Sumps
Tanks are  used by wood preserving facilities in a
number of ways.  Some  tanks are used to mix  and
store preservative  solution, while others are used to
store and treat hazardous waste generated as a result
of wood preserving operations. Tanks that are used
to mix and store preservative solution which does
not contain RCRA hazardous waste are not covered
by the regulations described below.   If, however,
tanks are  used to accumulate,  store, or treat waste
from the wood preserving process, such as hazardous
waste drippage from Subpart W drip pads, the tanks
are governed by RCRA Subpart J requirements.

Both   large   and   small    quantity    generators
accumulating hazardous  waste in tanks are required
to comply with the requirements in Subpart J. Large
quantity generators must follow  the  interim  status
tank standards in 40 CFR Part 265,  and small quantity
generators  are  governed by special tank  standards,
also in Part 265, Subpart J.

Note: A small number  of wood preserving facilities
perform  non-pressurized wood  treatment using large
tanks  of preservative formulation   in  which  charges
of wood are submerged.   If the facility has not been
equipped with a Subpart W drip pad, the charge must
remain over the tank until all drippage has ceased.

Sumps  are man-made  reservoirs  built into  the
ground  that  are designed to capture  waste from
troughs or trenches. Sumps  meet the definition of
tanks under  RCRA, and are subject to  regulation
under Subpart J.   Both tanks and sumps are often
used to capture waste from drip pads.

Tanks  and sumps  that are part  of  wastewater
treatment   units  may  be   exempt  from  RCRA
regulation if they are otherwise subject to regulation
under the  Clean Water Act (CWA).
Tanks and Sumps
          Section 7-1

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                                                                  June 19,1996
New vs. Existing
Tanks
Assessment of
Existing Tanks
                          This section of the Compliance Guide will discuss the
                          following RCRA requirements that apply to tanks:
                              Tank Assessment
                              Secondary Containment and Leak Detection
                              Ancillary Equipment
                              Operating and Maintenance Requirements
                              Inspections
                              Response to Releases
                              Closure
                              Underground Storage Tanks (USTs).
Different regulatory requirements apply depending
on whether tanks are classified as "existing" or "new"
under   RCRA.    The   "new"   versus  "existing"
distinction dictates  when secondary containment
systems  must  be  installed.    Tanks  which  held
hazardous waste before July 14,  1986 (the effective
date of  applicable EPA regulations), are classified as
"existing," while tanks that began holding hazardous
waste after that date are considered  "new."   New
tanks also include reinstalled and replacement tanks
or components.

All tanks must be  assessed  to  evaluate structural
integrity and compatibility with the wastes that the
tank will hold.  The  assessment must  address design
standards, corrosion protection, testing, and the age
of the tank.

Most existing tanks do not have to meet the technical
standards for new tanks  until the tank system is 15
years old. To ensure the tank's structural integrity
until   then,   existing   tanks  without   secondary
containment    systems    (secondary   containment
systems  are  discussed  in detail  below) must  be
assessed for  leakage  and  overall   fitness.    The
assessment must show that the  tank  is not leaking
and is otherwise fit for use.  This assessment was to
have occurred by January 12,1988.

An assessment of an existing tank must verify that
the tank was designed and maintained to contain the
particular wastes stored  or treated without failing,
collapsing,  or rupturing.   The  written  assessment
Tanks and Sumps
         Section 7-2

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                                                                  June 19,1996
Assessment of
New Tanks
Corrosion Protection
must be certified by a registered professional engineer
and placed in the facility's operating log.

New tanks must satisfy the following requirements:

•    The system  must  have  adequate foundations,
     structural  support, and  corrosion protection to
     prevent collapse, rupture, or failure.
•    All  seams and connections must be adequately
     sealed.
•    Facilities  must   prepare  a   written   design
     assessment,  which  must   be  certified  by  a
     registered professional engineer and kept in the
     operating log.

New  tanks must be inspected  prior to  use by  a
registered professional engineer to ensure no damage
to the tank occurred during tank installation or that
necessary repairs  were properly performed.  All new
tanks and  ancillary  equipment must be tested for
tightness, and any leaks  must be remedied before the
tank may be used. The  assessment must ensure  the
following:

•    Design and  method  of  operation will protect
     underground components from  damage caused
    by vehicle traffic.
•    Tank foundations will support the load of a full
     tank.
•    Tank  is  anchored   to  prevent  floating  or
     dislodgment.
•   Tank can withstand the effects of frost.
•   Backfill, used for  underground  tank  systems,
    made   up   of   noncorrosive,    porous,   and
    homogeneous  materials,  has  been  placed to
    ensure proper support.
•   Ancillary equipment  has been  supported and
    protected against physical damage.

New  tanks  and  tank system components  made in
whole  or  in part of  metal must  have  adequate
corrosion protection if the system will be in contact
with soil or water.  One  or more of the following
corrosion protection methods is required:
•   Use of materials that are corrosion-resistant.
Tanks and Sumps
         Section 7-3

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                                                                  June 19,1996
Leak Detection and
Secondary
Containment
•    Corrosion-resistant coating in combination with
     cathodic   protection   (cathodic   protection
     prevents   corrosion   by  reversing  naturally
     occurring electrical current in tanks, for example
     through the use of sacrificial anodes).
•    Electrical isolation devices.

Regardless of the protection method used, installation
of the corrosion protection system must be supervised
by an independent corrosion expert.

Secondary  containment  and leak detection systems
allow detection of leaks from  the primary or inner
tank and provide an emergency, short-term secondary
barrier to contain  releases and prevent  them  from
entering into the environment.  These  systems also
provide protection from spills  caused by operational
errors, such as  overfilling.  Large sumps under retort
areas   should   not   be   considered   secondary
containment if they routinely hold hazardous wastes
generated from the retort.

All new hazardous waste tank systems not otherwise
exempted  from regulation  must  have secondary
containment   and   leak  detection.     Secondary
containment and leak  detection for existing tanks is
to be phased in over time, based on the age of the
tank and its hazardous waste contents.  For example,
existing tanks of known and documented age must
have detection and  containment within two years
after January 12, 1987,  or when  the tank  system has
reached 15 years of age.

A secondary containment system  must  satisfy the
following requirements:

•    Designed,  installed,  and operated so that no
     waste  is  released   to    surrounding   soil,
     groundwater, or surface water
•    Constructed  of  material   or   liner  that  is
     compatible with  the  waste being stored  or
     treated in the tank
•    Capable of containing accumulated waste until it
     is removed (accumulations must be removed
     within 24  hours)
•    Structurally strong enough  to prevent failure
Tanks and Sumps
         Section 7-4

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                                                                  June 19,1996
Leak Detection
Systems
Secondary
Containment Devices
•    Foundation must be capable of resisting failure
     due to normal  movement of the surrounding
     soils.

As part  of the  secondary  containment  system,
hazardous waste tanks must be equipped with a leak
detection system capable of detecting failure either in
the primary or secondary containment structures.
The presence  of  accumulated  materials  in  the
secondary  containment system  must  be detected
within 24 hours or at the "earliest practicable time."
Thermal  conductivity  sensors, electrical  resistivity
sensors,  and  vapor detectors are  common  leak
detection  devices.  Daily visual inspections may be
used  where  tanks  and tank  components   are
accessible.

Secondary  containment   systems   prevent  waste
leaking  from the  tank  from migrating  to  the  soil,
groundwater, or  surface  water.  The containment
device must be capable of detecting and  collecting
releases and must be:

•   Constructed   of   or  lined   with  materials
    compatible with the waste to be contained
•   Strong enough to prevent failure from pressure,
    contact with the waste, climate, and  the stress of
    daily operations
•   Placed on a foundation capable of supporting the
    system
•   Equipped with a leak detection system
•   Sloped  or  otherwise  designed  to  drain   or
    remove liquids resulting  from spills,  leaks,  or
    rain.

Hazardous waste tank regulations require the use of
one  of  the  following  four secondary containment
systems:

•   An   external   liner  designed  to  work   in
    connection with a barrier  — the liner must  be
    free of  cracks and  should  completely  surround
    the unit with an  impermeable  material.  The
    liner  can be made of many different  types  of
    materials,   including  synthetic  membranes,
    concrete, clay, cement, or  asphalt, and must  be
Tanks and Sumps
         Section 7-5

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                                                                 June 19,1996
Exemption from
Secondary
Containment
Requirement
Secondary
Containment for
Ancillary Equipment
   , large enough  to  contain  100 percent  of  the
    capacity of the largest hazardous waste  tank
    within its boundary. The liner must be designed
    to prevent run-on and run-off.

•   A vault, which is an underground area designed
    to contain releases not visible to the operator —
    if the vault is  constructed of concrete, it must
    have a waterproof exterior and  must be lined
    inside with a leak proof sealant.  The vault must
    be large enough  to contain 100  percent of the
    capacity of the largest hazardous waste  tank
    within its boundary and must be equipped with
    protection against the formation and ignition of
    vapor within the vault.

•   A double-walled tank ("tank within  a tank") —
    this  option  is considered  to  be   the  most
    protective.   A double-walled  tank  must  be
    designed and  constructed so that any  release
    from the inner tank is completely contained by
    the outer tank. Such tanks must be equipped
    with built-in, continuous leak detection.

•   An alternative equivalent device, subject to the
    approval of the EPA Regional Administrator.

Some  tanks  may automatically  qualify  for   an
exemption from  secondary containment  and  leak
detection requirements.  One  exemption  applies to
tanks,  including  sumps, that  serve  as  part of a
secondary containment system.  This exemption does
not apply to drip pad sumps as these sumps serve as
primary, not secondary, containment systems.

All ancillary equipment must  have  full secondary
containment.  Ancillary equipment  includes devices
such as piping, fittings, flanges, valves, and pumps,
that are used to distribute, meter, or control the flow
of hazardous waste from its point of generation  to a
storage or treatment tank.  Examples of secondary
containment for ancillary equipment include use  of a
trench, jacketing,  or  double-walled piping.     If
inspected daily, the following  equipment is exempt
from this requirement:
Tanks and Sumps
         Section 7-6

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                                                                  June 19, 1996
Operating and
Maintenance
Requirements
Inspections
 •    Aboveground piping
 •    Welded flanges, joints, and connections
 •    Seal-less or magnetic coupling pumps
 •    Aboveground pressurized piping systems with
     automatic shut-off devices.

 Hazardous waste tanks and secondary containment
 systems must be  operated  so that releases will be
 minimized or eliminated.  Spills or overflows from
 the tank or secondary containment system must be
 prevented by:

 •    Using spill prevention  controls, such as check
     valves
 •    Using  overfill  prevention   controls  such  as
     alarms and automatic feed cutoffs
 •    Maintaining sufficient distance between the top
     of the tank and the surface of the waste in the
     tank (freeboard).

 To verify  that hazardous waste tanks,  components,
 and secondary containment systems are operated and
 maintained  in   satisfactory  condition,   routine
 inspections   are  required.    Records  of all tank
 inspections should be kept in the operating log.

 The  following  tank  system  components must  be
 inspected at least once a day:

 •    Overfill/spill control equipment to ensure it is
     in good  working order
 •    Aboveground portions  of the tank system to
     detect corrosion or release of waste
 •    Data   gathered  from   monitoring  and  leak
     detection equipment
 •    Construction    materials    and   the    area
     immediately surrounding the accessible portion
     of the  tank  system,  including  secondary
     containment  structures, to detect corrosion  or
     waste release.

The  cathodic protection system must be inspected
within  six  months  of  installation  and annually
thereafter.    All  sources  of  impressed  current  (a
specific type of corrosion  protection using  direct
Tanks and Sumps
         Section 7-7

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                                                                  June 19,1996
Response to Releases
Closure
current from an external source) must be inspected
and/or tested at least every other month.

A tank system or secondary containment system that
has  leaked  must  be  taken  out   of   operation
immediately.  The flow of waste into the tank must
be stopped, and the system must be inspected  to
determine  the cause  of the release.   All visible
contamination  must  be  removed   and  properly
disposed.  Any waste remaining in the tank must  be
removed within 24 hours.

Unless the release  is exempt (leaks of less than one
pound that are immediately contained  are  exempt
from Federal reporting obligations), the facility must
immediately notify the EPA Regional Administrator
or the National Response Center (NRC) and submit a
follow-up  written  report  to   the  EPA  Regional
Administrator within 30  days.

The  tank  must then be  repaired,  equipped with
secondary containment  (if not  already equipped),  or
closed.  If the leaking component is aboveground and
can be inspected  visually,  secondary containment
does not need to be provided after repair.

If any of the repairs are major, they must be certified
by a registered professional engineer; this certification
must   be   submitted   to  the   EPA   Regional
Administrator  within seven days after returning the
system to  service.  Except for  the notification and
reporting  requirements,  the above procedures apply
even if a  release has been contained by a secondary
containment system.

When  a tank containing hazardous waste at a wood
preserving facility is no  longer  used,  or abandoned,
owners/operators   must  complete  proper  closure
activities to complete their regulatory
responsibilities.  Whenever possible,  a storage  or
treatment  tank system  must be  "clean  closed"  by
removing  or  decontaminating all  waste  residues,
contaminated containment system components, and
contaminated  soils, structures  and  equipment.    If
clean closure is not possible, the facility may opt to
leave the  contamination in place.  If this occurs, the
Tanks and Sumps
         Section 7-8

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                                                                        June 29, 1996
 Underground  Storage
 Tanks
facility must develop a plan for taking care of the
remaining  waste for a number of years after closure,
similar to that developed for  a landfill.

EPA has developed a separate regulatory program for
underground storage tanks (USTs).  Tanks regulated
under  this  program   contain   what   are  called
"regulated  substances"  which   include   petroleum
products  and hazardous substances as defined under
CERCLA.    The  primary  distinction  between  the
regulations described above and USTs is the content
of the tanks.  Specifically, underground storage tanks
are  those  underground  tanks  storing   "regulated
substances."  The definition  of regulated substance
specifically  excludes  any RCRA  hazardous wastes.
Thus,  any  tank holding  a RCRA  hazardous waste
will not  be subject  to  the  Part 280 underground
storage tank regulations.
 Additional inf ormation is available on the subjects discussed above:
       •     For general information on RCRA, refer to EPA's RCRA Orientation Manual
             1990 Edition, EPA/530-SW-90-036.
       •     For information on the specific regulations, consult the following sections of
             the Code of Federal Regulations:
                    Exclusion from Tank Regulations — 40 CFR §§ 264.1(c)(10); 270.1(c)(2)(v)
                    New vs. Existing Tanks — 40 CFR §260.10
                    Assessment of Existing Tanks — 40 CFR §265.191
                    Design of New Tanks — 40 CFR §265.192
                    Secondary Containment and Leak Detection — 40 CFR §265.193
                    Variance from Secondary Containment Requirements — 40 CFR §265.193(g)
                    Secondary Containment for Ancillary Equipment — 40 CFR §265.193(f)
                    Operating and Maintenance Requirements — 40 CFR §265.194
                    Inspections — 40 CFR §265.195
                    Response to Releases — 40 CFR §265.196
                    Closure — 40 CFR §265.197
                    Underground Storage Tanks — 40 CFR Fart 280.	
Tanks and Sumps
         Section 7-9

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                               Section  8
     Additional  Federal  Statutory  Requirements
 Clean Water Act
NPDES Program
 In 1972, Congress passed the Federal Water Pollution
 Control  Act,  commonly  referred to  as the Clean
 Water Act (CWA). The goal of the CWA is to restore
 and maintain the chemical, physical, and biological
 integrity of the nation's surface waters by prohibiting
 the discharge of pollutants to surface waters  in toxic
 amounts.

 The  CWA  regulates  both   direct   and   indirect
 discharges.   Direct  discharges  or  "point   source"
 discharges are from sources such as pipes and sewers.
 Indirect    discharges    through    publicly-owned
 treatment  works  (POTWs)  are regulated  by the
 industrial waste pretreatment program.

 The  National  Pollutant  Discharge   Elimination
 System (NPDES), promulgated  pursuant  to CWA
 §402, is the national program for issuing, monitoring,
 and  enforcing  permits  for  direct  discharges  of
 pollutants to  the navigable  waters  of  the  United
 States. NPDES permits, issued by either EPA or an
 authorized    State,     contain    industry-specific,
 technology-based and/or water quality-based effluent
 limits, and  establish  pollutant  monitoring  and
 reporting requirements.   A facility that intends to
 discharge into the nation's waters must first obtain
 an NPDES permit. A permit applicant must provide
 quantitative analytical data identifying  the  types of
 pollutants present in the facility's effluent discharge.
 The  permit  will  then  set forth the  conditions and
 effluent limits under which a facility may discharge.

 The  NPDES permit application, whether for a new
 discharge or  for  an  existing  discharge,  requires
 extensive information  about  the facility  and  the
nature of the  discharge  from  the  facility.   EPA
 application  forms   include   Form   1   (general
information),  Form   2 (detailed  information  on
existing sources), Form 2D (detailed information on
new  sources and new discharges),  Form  2E (for
facilities that discharge only non-process  wastewater),
Additional Requirements
         Section 8-1

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                                                                 June 19,1996
Stormwater Discharges
and  Form 2F  (for  stormwater  discharges).   State
application forms must,  at a minimum, require the
information required by EPA's forms.

One of the primary purposes of the NPDES permit is
to establish effluent limitations.  The CWA mandates
a  two-part  approach   to   establishing  effluent
limitations. First, all dischargers are required to meet
specific established treatment levels.   The effluent
limitations for  the  wood preserving  industry are
found in  40 CFR Part 429.   Second, more stringent
requirements  must  be  met  where   necessary  to
achieve water quality goals for the particular body of
water into which the facility discharges.

In 1987, Congress  amended  the CWA  and created a
program   for   the    comprehensive    control   of
stormwater discharges.  Pursuant to that delegated
authority,  EPA  established  a  stormwater program
which  requires facilities  to obtain  a permit   for
stormwater  discharges  associated  with  industrial
activity, including discharges to a municipal storm
sewer.

All  wood treating plants,  regardless  of size, must
obtain an NPDES  permit for stormwater discharges.
The  permit  is  a  legally  enforceable   agreement
between the  regulatory agency  (either EPA  or the
State)  and the  industrial facility  that governs  the
quality of stormwater effluent released into receiving
waters, such as creeks, streams, ponds,  and rivers.

EPA published permit application requirements  for
stormwater  discharges  associated  with   specific
industrial activities   in  the Federal  Register  on
November 16, 1990  (55 FR 47990).  The  regulations
outline   three  permit  application   options   for
stormwater  discharges  associated with  industrial
activity:

1-  Submit   an   individual    application.      An
individual   permit   application   requires  detailed
quantitative  information  based  on   sampling  of
stormwater discharges collected during storm events.
Additional Requirements
          Section 8-2

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                                                                   June 19, 1996
 Pretreatment
 Program
 2-   Participate  in  a group  application.    Group
 applications allow similar dischargers to apply as a
 group for a permit.  This  type of permit reduces the
 cost of compliance  for  group  members  and  the
 administrative   costs  for regulators.    Additional
 information on group applications is provided in the
 September 29, 1995, Federal Register (60 FR 50804).

 3 -   File a Notice of Intent (NOI) to be covered under
 a general multi-sector stormwater permit.  Under the
 multi-sector permit,  stormwater dischargers have to
 develop  site-specific  pollution  prevention   plans
 based on industry-specific  best management practices
 specified in the permit.

 NPDES  stormwater  permits  are  issued by  the  EPA
 Regional office or by  States  authorized by EPA  to
 administer the program. Contact your EPA Regional
 office to   determine  who  is  administering  the
 program in your facility's jurisdiction.

 Industrial  discharges that do not discharge directly
 into waters of the U.S., but instead discharge into  a
 public sanitary sewer system are regulated under the
 CWA pretreatment  program  (CWA  §307(b)).   The
 national pretreatment program controls the indirect
 discharge of pollutants to POTWs by industrial users.
 Facilities regulated under §307(b) must pretreat their
 wastewater before discharging.   The  goal of the
 pretreatment   program is  to  protect  municipal
 wastewater treatment plants from damage that may
 occur when hazardous, toxic,  or other wastes are
 discharged .into  a sewer system.   Discharges to  a
 POTW are  regulated primarily  by the POTW itself,
 rather than by the State or EPA. EPA  has  developed
 technology-based   pretreatment    standards   for
 categories  of industrial users of POTWs; different
 standards apply to existing and new sources within
 each category.

 EPA's Office of Water,  at  (202) 260-5700, will  direct
 callers  with  questions  about  the  CWA  to  the
appropriate  EPA  office.    EPA also  maintains   a
 bibliographic database  of Office of Water  publications
which  can be accessed  through the Ground  Water
and Drinking Water resource center, at (202) 260-7786.
Additional Requirements
         Section 8-3

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                                                                      June 19,1996
Federal Insecticide,
Fungicide, and
Rodenticide Act
(FIFRA)
The  Federal Insecticide, Fungicide, and  Rodenticide
Act  (FIFRA),  regulates  chemicals  with  pesticidal
properties  that  are sold in  commerce  as poisons.
Many of the chemicals used by the wood preserving
industry are regulated under FIFRA.

Wood  preserving formulations  must be registered
with EPA by the producer.  To register a chemical, an
application package that includes product chemical
composition and health risk data must be submitted
to EPA.

Under  FIFRA,  products  are  classified  as either a
restricted-use   or  general-use  pesticide.     This
classification must appear  on  product labels.  Wood
preserving   formulations   containing   creosote,
pentachlorophenol,   and   inorganic  salts  such  as
chromated copper arsenate are classified  as restricted-
use pesticides.  The application of such formulations
is therefore limited to licensed pesticide applicators
or an individual under the direct supervision of a
licensed pesticide  applicator.   Wood   preserving
facilities using these formulations must have  at least
one  employee who is licensed to apply restricted-use
pesticides.  The standards for licensing are established
by the Federal  government or by State governments
with Federal approval.  (A list of State contacts  for
licensing is provided  in Appendix B).

In addition  to the  licensing  requirements,  wood
preserving facilities  using arsenic are  required to
either conduct air monitoring on personnel working
in areas where arsenic  exposure  might  occur or
require  operators  to wear  respirators.   This  air
monitoring and associated recordkeeping must be
done in accordance with EPA's Permissible Exposure
Limit  (PEL) Monitoring   Program.   The  analytical
results from the PEL Monitoring  Program must be
submitted annually to PEL Monitoring, U.S. EPA.
      Additional Requirements
                                        Section 8-4

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                                                                      June 19, 2996
Clean Air Act
     Wood Products Contact
     PEL Monitoring (2223A)
     Manufacturing Branch
     U.S. Environmental Protection Agency
     401 M Street, SW
     Washintong, D.C. 20460

In order to educate consumers on the safe and proper
handling   of   wood   treated   with   creosote,
pentachlorophenol,   and  inorganic  arsenicals,  a
voluntary   Consumer  Awareness  Program   was
established jointly by EPA and the wood preserving
industry.   Through  the  program,  a  Consumer
Information   Sheet  (CIS) containing  information
about treated wood is distributed to  end-users at the
time of sale or delivery.  The  CIS contains  language
agreed  upon  by EPA  and  the  wood  treatment
industry. The primary  responsibility  for  ensuring
that the CIS is distributed to  the  consuming public
resides with the wood treaters. They are responsible
for distributing CISs and signs and placards to their
retailers, wholesalers, and distributors, and attaching
a CIS to each  bundle or batch of pressure treated
wood as well as to each invoice.

EPA's   National    Pesticides   Telecommunications
Network,  at  (800) 858-PEST, answers questions  and
distributes  guidance  regarding  the   registration  of
pesticides, labeling,  the PEL Modeling  Program, and
the Consumer  Awareness  Program.   The Network
operates  weekdays from  6:30 a.m.  to  4:30 p.m., PST,
excluding Federal holidays.

The Clean Air Act  (CAA) is  the principal  Federal
statute governing air pollution and is administered
by EPA.  EPA may grant  States the  authority  to
administer certain provisions  of the CAA following
approval of State Implementation Plans (SIPs).

Currently, the CAA does not impact wood preserving
processes directly, however several  portions of  the
Act may affect facility operations.    For instance,
boilers burning sawdust for fuel may be regulated for
particulates emitted to the atmosphere.  Some States
regulate kilns using natural gas for fuel, and require a
permit for their use.  If you use  a fuel oil or diesel
    Additional Requirements
         Section 8-5

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                                                                 June 19,1996
                         back-up, your State may require emissions data on
                         sulfur dioxide.

                         Title  I  of  the  CAA  established  New  Source
                         Performance Standards (NSPSs), which are national
                         emission standards for new stationary sources falling
                         within  particular  industrial  categories.  The NSPS
                         regulations in 40 CFR 60.110b - 60.117b might apply to
                         an oil  borne wood processing facility if the  facility
                         uses a process tank that has a design capacity of over
                         40 cubic meters and was built after July 23,1984.

                         Pursuant to the CAA,  EPA has established National
                         Emission Standards for  Hazardous Air  Pollutants
                         (NESHAPs).    NESHAPs   are  national   standards
                         oriented toward controlling particular  hazardous air
                         pollutants  (HAPs).  Wood  treating plants  are  not
                         currently regulated  under  these  rules.   Although
                         arsenic, copper, chromium,  and pentacholorphenol
                         are  listed  as  HAPs, no  standards have  been
                         established for them.

                         Under the CAA Title V, each industrial source of air
                         emissions that is  defined as a "major source" must
                         submit a permit  application.  One purpose of  the
                         permit  is to include all air emissions requirements
                         that apply to a given facility in a single document. A
                         "major source" is defined as a stationary source that:

                         •  Emits or has the potential  to  emit 100 tons  per
                            year of  any pollutant  listed under §302 of  the
                            CAA.

                         •  Emits or has the potential to emit certain criteria
                            pollutants (volatile organic compounds, nitrogen
                            oxides, sulfur oxides, carbon monoxide, lead,  and
                            particulates) in non-attainment  areas designated
                            under Title I.

                         •  Emits or has the potential to emit 10 tons per year
                            of any HAP (listed in CAA §112(b)), or 25 tons per
                            year of any combination of HAPs, or any source
                            subject to NSPSs or NESHAPs.
Additional Requirements
Section 8-6

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                                                                   June 19, 1996
                           Most  wood  treating  facilities  will  be  considered
                           minor    sources    of   air   pollution;   however,
                           documentation to establish this  classification may be
                           requested by EPA  or  the State.   One method  of
                           calculating  emissions   potential   is   to  review
                           equipment specifications provided by the designer or
                           supplier.    Other   calculation   methods  include
                           evaluating the quantities of chemicals purchased and
                           processed per year.

                           In  the  1990  Clean Air Act Amendments, Congress
                           added subsection (r)  to CAA section  112 for the
                           prevention of chemical accidents. The goals  of the
                           chemical accident prevention provisions are to focus
                           on chemicals  that  pose significant hazard to the
                           community  should an accident occur, to prevent
                           their  accidental  release,   and  to  minimize  the
                           consequences of such release.  Regulations for the
                           §112(r)  Risk  Management  Program are  currently
                           being  established  by  EPA.   To  date,  EPA  has
                           established the list of chemicals  and thresholds for
                           on-site storage and use, but not the requirements for
                           risk management  plans.    These  rules  may  be
                           applicable to wood preserving  facilities.    EPA's
                           EPCRA  Hotline  will be  able to provide specific
                           information  about this  reporting requirement  when
                           it is published in the Federal Register.

                           EPA's Control  Technology   Center, at (919) 541-0800,
                          provides  general assistance and information on CAA
                          standards.   The  Stratospheric  Ozone   Information
                          Hotline,    at   (800)   296-1996,  provides   general
                          information  about regulations  promulgated  under
                          Title VI  of the CAA, and EPA's  EPCRA Hotline,  at
                          (800) 535-0202, answers  questions  about  accidental
                          release  prevention  under  CAA §112(r).  In  addition,
                          the  Technology  Transfer Network  Bulletin  Board
                          System (modem access (919) 541-5742)  includes recent
                          CAA rules, EPA guidance documents,  and updates  of
                          EPA activities.
Additional Requirements
Section 8-7

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                                                                   June 19,1996
Comprehensive
Environmental
Response,
Compensation,
And Liability Act
The  Comprehensive  Environmental  Response,
Compensation,  and  Liability Act (CERCLA)  of
1980, commonly known as Superfund, authorizes
EPA to respond to releases, or threatened releases,
of hazardous substances that may endanger public
health, welfare, or the  environment.    CERCLA
also  enables EPA to force parties responsible for
environmental contamination to  clean it up or to
reimburse  the Superfund  for   response  costs
incurred by EPA. The Superfund Amendments
and  Reauthorization Act (SARA) of 1986 revised
various sections of CERCLA, extended the taxing
authority for the  Superfund, and created a  free-
standing law, SARA Title m, also known as the
Emergency Planning  and Community  Right-to-
Know Act (EPCRA).  A discussion of the EPCRA
regulations follows the discussion of CERCLA.

The  CERCLA hazardous substance release reporting
regulations found in 40 CFR Part 302 direct persons
in charge of  facilities  to  report to  the National
Response Center  (NRC) any release of  a hazardous
substance which  within a 24-hour period equals  or
exceeds a designated reportable  quantity (RQ).  The
NRC, located at U.S. Coast Guard Headquarters ((800)
424-8802),  is  a  national  communications   center
continuously  staffed to handle  activities related  to
spills and releases.

Hazardous substances and RQs are defined and listed
in 40 CFR §302.4. Arsenic, chromium,  cresote, and
pentachlorophenol   are a  few  of  the  hazardous
substances listed in 40  CFR §302.4 often  found  at
wood preserving facilities and  for which reporting
may be required.  The RQs for these substances are:

 • Arsenic - 1 Ib.
 •  Chromium - 5,000 Ibs.
 •  Creosote - 1 Ib.
 •  Pentachlorophenol-10 Ibs.

 The Superfund Hotline can provide RQs for other
 specific  hazardous   substances  and  assist   in
 determining which releases are reportable. A report
 of a release may  trigger a response by EPA, or by one
     Additional Requirements
                                       Section 8-8

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                                                                    June 19,1996
Emergency
Planning And
Community
Right-To-Knpw
Act
 or  more  Federal  or State  emergency  response
 authorities.

 EPA implements  hazardous  substance responses
 according to procedures outlined in the National Oil
 and Hazardous  Substances  Pollution Contingency
 Plan (NCP) (40 CFR Part 300).  The NCP includes
 provisions  for  permanent  cleanups,  known  as
 remedial  actions, and other  cleanups referred to as
 "removals."   EPA  generally  takes remedial  actions
 only at sites on  the  National  Priorities  List (NPL),
 which currently  includes approximately 1300 sites.
 As of May 1996, approximately 45 sites were on the
 NPL because of contamination stemming  from wood
 preserving operations.

 EPA's RCRA/Superfund/UST  Hotline, at (800) 424-
 9346, answers  questions  and  references  guidance
 pertaining  to the  Superfund  program.  The  Hotline
 operates weekdays from 9:00  a.m. to 6:00 p.m., EST,
 excluding  Federal holidays.

 The Superfund Amendments and  Reauthorization
 Act (SARA) of 1986 created the  Emergency Planning
 and Community  Right-to-Know Act (EPCRA), also
 known as SARA Title HI.  This  law was designed to
 improve community access  to information about
 potential  chemical  hazards  and  to facilitate  the
 development of chemical emergency response plans
 by State and local governments.  EPCRA required  the
 establishment   of   State   Emergency  Response
 Commissions  (SERCs), responsible for coordinating
 certain  emergency  response  activities   and   for
 appointing Local  Emergency  Planning Committees
 (LEPCs).

EPCRA regulations, at 40 CFR Parts 350-372, establish
four types of reporting obligations for facilities which
store or manage specified chemicals:

 •   EPCRA §302 -  Emergency Planning  requires
    facilities to notify their SERC and LEPC  of the
    presence of any extremely hazardous substance
    (EHS)  in  excess  of the  substance's  threshold
    planning  quantity (TPQ)  (the list of EHSs and
    TPQs is in 40 CFR Part 355, Appendices A and B).
   Additional Requirements
         Section 8 - 9

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                                                                June 19,1996
                             EPCRA §302 also directs facilities  to appoint an
                             emergency response coordinator.  It is unlikely
                             that this  section of EPCRA is  applicable to the
                             wood preserving industry because the types  of
                             chemicals generally  stored  do  not   meet the
                             regulatory definition of an extremely hazardous
                             substance.

                             EPCRA §304 - Emergency Release Notification
                             requires facilities to notify the SERC and LEPC in
                             the event of a release  exceeding  the  reportable
                             quantity   of  either   a  CERCLA   hazardous
                             substance or an EPCRA extremely  hazardous
                             substance which may affect persons beyond the
                             facility's boundaries.

                             EPCRA.   §§311/312  -  Hazardous   Chemical
                             Inventory Reporting requires facilities at which
                             a  hazardous chemical,  as  defined  by the
                             Occupational Safety and Health Act, is present in
                             an amount  exceeding  a specified threshold  to
                             submit material safety  data sheets (MSDSs) and
                             hazardous  chemical   inventory  forms   (also
                             known as Tier I and II forms) to the SERC, LEPC,
                             and local fire department by March  1 of every
                             year.     This  information   helps   the   local
                             government respond to a spill or release  of the
                             chemical. Many of the chemicals used by wood
                             treaters are defined as hazardous chemicals.

                             EPCRA §313 - Toxic Chemical Release Inventory
                             requires  manufacturing facilities included in SIC
                             codes  20 through  39, which have ten or more
                             full-time  employees, and which manufacture,
                             process,  or use specified chemicals in amounts
                             greater than threshold quantities, to  submit  an
                             annual toxic chemical  release report by July 1 of
                             every  year.  The SIC code for lumber  and wood
                             products is 24. This report, commonly known as
                             the Form R, covers releases and transfers of toxic
                             chemicals   to    various     facilities   and
                             environmental  media,  and  allows  EPA  to
                             compile the national  Toxic Release  Inventory
                             (TRI) database.
Additional Requirements
                                  Section 8 -10

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                                                                      June 19,1996
Safe Drinking
Water Act
 All  information  submitted  pursuant  to  EPCRA
 regulations is publicly available, unless protected by a
 trade secret claim.

 EPA's  EPCRA  Hotline,  at  (800) 535-0202, answers
 questions and distributes guidance regarding  EPCRA
 regulations.  A guidance document,  "Title III Section
 313  Release   Reporting   Guidance,   Estimating
 Chemical    Releases   from    Wood    Preserving
 Operations,"  is available  from  the Hotline.    The
 EPCRA Hotline operates  weekdays from  9:00 a.m.  to
 6:00  p.m.,  EST, excluding federal  holidays.

 The Safe Drinking Water Act (SDWA) mandates that
 EPA establish regulations to protect human health
 from contaminants  present in drinking  water.  The
 law authorizes  EPA to  develop  national  drinking
 water standards and to create a  joint Federal-State
 system to  ensure compliance  with these standards.
 The SDWA  also directs EPA to protect underground
 sources of  drinking water through the control  of
 underground injection of liquid wastes.

 The  SDWA  may  be  of concern  to  the  wood
 preservers   if  dry wells  are   used.     If  water
 contaminated with wood preservative is allowed  to
 drain into  a dry well, it could lead to contamination
 of underground  sources of drinking  water.  Under
 the SDWA, a permit program for  the safe disposal  of
 wastes  through  controlled  underground  injection
 has  been established.   The  Underground  Injection
 Control (UIC)  program  (40  CFR  Parts  144-148)
 regulates five classes of injection  wells  and may be
 applicable  to wood treaters.   UIC  permits include
 design,  operation,   inspection,   and   monitoring
 requirements. Wells used to inject hazardous wastes
 must  also  comply with RCRA corrective action
 standards to be granted a RCRA  permit, and must
 meet  applicable RCRA  land  disposal restriction
 standards.

 EPA's Safe Drinking Water Hotline,  at (800) 426-4791,
 answers   questions    and   distributes    guidance
 pertaining to SDWA standards.  The Hotline operates
from  9:00  a.m.  through  5:30  p.m.,  EST, excluding
 Federal holidays.
    Additional Requirements
         Section 8 -11

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                                                                     .June 19,1-996
DOTS
Hazardous
Materials
Transportation
Act (HMTA)
The Department  of Transportation (DOT) regulates
all aspects of the shipping and receiving of hazardous
materials  when those activities  are  performed in
commerce.  "In commerce" includes the shipping of
hazardous   materials  typically  found  at  wood
treatment     sites,     such     as     chromium,
pentachlorophenol,  arsenic,  and  creosote, to  an
industrial facility for use in industrial processes.

Hazardous materials  are those materials that  DOT
has determined  may  harm human health  and the
environment during shipping.  Hazardous materials
include specific hazardous chemicals, such as arsenic
acid, but also include general hazardous categories, or
classes. The DOT Hazardous Materials Table (49 CFR
Part 172.101) includes  a list of all hazardous materials,
as well as requirements for proper shipment  of listed
items.  The  Hazardous Materials Table also provides
information on proper containers and labels, as well
as vehicle requirements.

DOT requires that proper shipping papers accompany
all  shipments  of hazardous   waste  or  hazardous
materials.   Shipping  papers indicate  what  is being
shipped,  the quantity  being  shipped,  and  the
particular hazards of  the material.  When shipping
wood  preserving  chemicals,  an Annotated Bill of
Lading may be used that includes all required DOT
shipping  information.    For  shipping  hazardous
waste, a RCRA  hazardous waste manifest  must be
used.

DOT's Hazardous Materials  Information   Line, at
(800)   467-4922,  provides  general   assistance   and
information    on  HMTA   regulations.       The
Information   Line  operates  weekdays from 8:00 a.m.
to 5:30 p.m., EST, excluding Federal holidays.
     Additional Requirements
         Section 8-12

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                                                                 June 19,1996
Pollution
Prevention
Act
Toxic Substances
Control Act
 Congress enacted the Pollution  Prevention  Act in
 1990  to  promote pollution  prevention  in  existing
 regulatory  programs,  including  EPCRA,   RCRA,
 CWA,  and  CAA.   The  first  step  in  pollution
 prevention is the development and implementation
 of a pollution prevention plan.  Wood preserving
 facilities  are  impacted  by  pollution   prevention
 regulations  related to the generation of hazardous
 and non-hazardous waste in the treating process, and
 through  other  activities  and  stormwater   control
 measures.

 For  assistance in  developing  a facility  pollution
 prevention plan,  contact the regulatory  Hotlines for
 the EPCRA, RCRA, CWA,  and CAA programs.

 The Toxic Substances Control Act (TSCA) grants EPA
 the authority to create  a  regulatory  framework to
 collect data on chemicals in order to evaluate, assess,
 mitigate, and control risks which  may  be posed by
 their  manufacture,   processing,  and  use.    Wood
 treating plants may be affected by a TSCA reporting
 requirement  promulgated pursuant to section 8(c) of
 TSCA and found at 40 CFR §717.  These regulations
 enable employees, consumers, the general public, or
 environmental advocacy groups to allege that the
 chemicals used by a plant caused an adverse effect to
 their  health  or the environment that had not  been
 previously identified.  If such an allegation is made,
 it should be documented on company letterhead and
 placed in the company's TSCA  8(c) file for  future
 reference.

 EPA's TSCA  Assistance  Information  Service,  at  (202)
 554-1404, answers questions  and distributes guidance
 pertaining to TSCA standards.  The  Service  operates
from  8:30 a.m.  through  4:30 p.m., EST,  excluding
 Federal  holidays.
Additional Requirements
         Section 8-13

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                                                                            June 19,1996
Additional information is available on the subjects discussed above. The following is a list of Code
of Federal Regulation citations applicable to the wood preserving industry.

•   For regulatory information on Clean Water Act, consult the following sections of the Code of
    Federal Regulations:
    -   National Pollutant Discharge Elimination System - 40 CFR Parts 122 and 125
       Effluent Guidelines and Standards for the Timber Products Processing Point Source
       Category - 40 CFR Part 429

•   For regulatory information on FIFRA, consult the following sections of the Code of Federal
    Regulations:
       Worker Protection Standards - 40 CFR Part 170
       Certification of Pesticide Applicators - 40 CFR Part 171
       For information about the PEL monitoring program, see Federal Register Vol.49, no. 136, July
       13,1984, p28666-28689.

•   For regulatory information on the Clean Air Act, consult the following sections of the Code of
    Federal Regulations:
    -   New Source Performance Standards - 40 CFR §60.110b - 60.117b
       National Emission Standards for Hazardous Air Pollutants - 40 CFR Part 61
       Risk Management Programs - 40 CFR Part 68
       National Emission Standards for Hazardous Air Pollutants for Source Categories - 40 CFR
       Part 63                                        .

•   For regulatory information on the Superfund program, consult the following sections of the Code
    of Federal Regulations:
    -   National Contingency Plan - 40 CFR Part 300
    -   Hazardous Substance Release Reporting - 40 CFR Part 302

•   For regulatory information on EPCRA, consult the following sections of the Code of Federal
    Regulations:
    -   Emergency Planning - 40 CFR Part 355
    -   Release Reporting - 40 CFR §355.40
       Hazardous Chemical Inventory Reporting - 40 CFR Part 370
    -   Toxic Chemical Release Reporting - 40 CFR Part 372

•   For regulatory information on the Safe Drinking Water  Act, consult the following sections of
    the Code  of Federal Regulations:
    -   Underground Control Program - 40 CFR Parts 144-148

•   For regulatory information on DOT's Hazardous Materials Transportation Act, consult the
    following sections of the Code of Federal Regulations:
    -   Hazardous Materials Table - 49 CFR §172.101

•   For regulatory information on TSCA, consult the following sections of the Code of Federal
    Regulations:
    -   Records and Reports of Chemical Health Effects - 40 CFR Part 717
Additional Requirements                 Section 8-14

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        Appendix A
Instructions on Electronic Access to
           this Guide

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           APPENDIX A - INSTRUCTIONS FOR
	DOWNLOADING  THIS  GUIDE

     Electronic Access to this Guide via the Enviro$en$e World Wide Web
        (E$WWW) and the Enviro$en$e Bulletin Board System (E$BBS)


This Guide is available through two electronic systems, the Enviro$en$e Bulletin
Board System (via modem  connection), and the Enviro$en$e World Wide Web
(via  Internet).  The Enviro$en$e Communications  Network  is a free, public,
interagency-supported system operated by EPA's Office of Enforcement  and
Compliance Assurance and Office of Research and Development. The Network
allows regulators, the regulated community, technical  experts, and the general
public to share information  regarding: pollution prevention  and innovative
technologies;  environmental  enforcement and  compliance  assistance;  laws,
executive orders, regulations,  and policies; points of contact  for services  and
equipment; and  other  related topics.   The Network  welcomes receipt  of
environmental messages, information, and data from any public or private
person or organization.  This document first provides summary information on
E$WWW access as well as  information on downloading protocols from within
the E$BBS.

A.    ACCESS THROUGH THE ENVIRO$EN$E WORLD WIDE WEB

      To access this Guide through the Enviro$en$e World Wide Web, set your
      World Wide Web Browser to the following address:

      WWW/INTERNET ADDRESS:  http://es.inel.gov/oeca/metd/guide

      HOTLINE NUMBER  FOR E$WWW ONLY:  208-526-6956

      EPA  E$WWW MANAGER: Louis Paley 202-564-2613
                               Myles Morse 202-260-3151

      Here you will be given several file choices.
                               Appendix A -1

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	6/20/96


PROCEDURES FOR MAKING COMMENTS AND SENDING DOCUMENTS TO
EPA VIA $WWW

      •     From the EPA Sector Notebook home page
            (http://es.inel.gov/comply/sector/index/html):

            (a) at the 4th paragraph click on "send comments or supplemental
            materials." or

            (b) at the end of each Guide's summary information, click on "send
            comments."

      •     At the Comments on EPA Sector Notebook home page
            (http://er.inel.gov/comply/sector/comments.html):

            (a) at the 2nd paragraph, click on "Guide ©epamail.epa.gov", or
            click on  "sector Guide comment form": or

            (b) follow the specific instructions delineated in the 3rd paragraph.

      •     Simply follow the instructions outlined on these pages and forms.

B.    ACCESS THROUGH THE ENVIRO$EN$E BULLETIN BOARD SYSTEM -
      Instructions for Connecting, Registering and Downloading Files

      E$BBS MODEM CONNECTION NUMBER:  703-908-2092

      HOTLINE FOR E$BBS ONLY: 703-908-2007

      MANAGERS:  BBS PLATFORM:   Louis Paley 202-564-2613
                                     Myles Morse 202-260-3161

The following instructions are condensed from longer documents that provide
information on  the full features of the Enviro$en$e  Bulletin  Board.  Further
documentation  is available on-line in the files that are listed at the  end of this
Appendix.

STEP1.     ESTABLISHING MODEM SETTINGS

Connecting  to  the  ENVIRO$EN$E   BBS  is  done  using  a  modem  and
communications software.  The modem can  be either an  internal  or external
model connected directly to your computer, or part of a modem pool that is
accessible  through  your  Local  Area  Network  (LAN)  system.     The
communications software (e.g., CrossTalk, ProComm, QModem, Microphone,
etc.) is what allows you to access and control your modem.  Your software needs
                                Appendix A - 2

-------
to be set to the  values  noted below  (many of these settings are the  standard
defaults used):

      •     Telephone Number - 703-908-2092 (Tip: Be sure you have  entered
            the  appropriate dialing prefix; e.g., 9 for an outside line, 1 for  long
            distance)

      •     Baud Rate - up to 28,800 EPS is supported (always select the highest
            speed which your modern will support).

      •     Terminal Emulation - BBS, ANSI, VT-100, VT-102 etc. (Tips: Do not
            use  TTY. After you log in, if you see screen characters appear on the
            lines where  you  need to enter  information, chances  are  that you
            need to properly set your terminal  emulation.   The  emulation  can
            normally   be   reset   before  or   during   communication   with
            Enviro$en$e).

      •     Data Bits - Eight

      •     Stop Bits - One

      •     Parity - None.

      •     Transfer Protocols - ZModem,  YModem,  XModem,  HS/Link,
            BiModem, ASCII (text files only). If your communications  software
            supports ZModem, this  will increase  upload/download efficiency.
            You  must   select   the  same  protocol   that   BOTH  your
            communications  software and  the BBS support so that they can
            "talk the same language" when sending and receiving files.

      •     Error Correction/Data Compression Protocols - v.32, v.42, and other
            older, hardware-dependent ones are supported.

      Refer to your communications  software manual  on how to set and save
      the communication parameters noted above (these will generally be the
      default). Also, check to make sure you know where the communications
      software will send the files you download.   Due to document sizes, it is
      best not to download Sector Guides on to floppy disks.

STEP 2.     CONNECTING AND REGISTERING

      •     Connect to E$BBS via modem, using communications software set
            .to the above settings by dialing:

                                  (703) 908-2092
                                 Appendix A - 3

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                                                                June 19,1996
            Note:  EPA Employees  can access E$ directly via LAN from the
            Agency Lan Services Menu or Icon and then follow the instructions
            below.  The end of this document lists  additional resources  for
            accessing E$BBS through the LAN.

      •     Once you are in the BBS, hit the ENTER/RETURN key twice(2)  to
            accept the default values for the screen.

      •     On  successive  pages,  type  your,  first   name    and  hit
            ENTER/RETURN; type your last name  and hit ENTER/RETURN;
            and type your password (if you have NOT registered yet, create a
            password, and  remember  it for subsequent  logons to E$ and hit
            ENTER/RETURN; and

      •     Register (first time only)  and immediately receive access to the BBS
            for 120 minutes per day;

                  Type  responses  to  the  registration questions, and hit
                  ENTER/RETURN to begin using ENVIRO$EN$E.  (Tip: the
                  last registration question is  Country?	)

                  You  may need to hit ENTER/RETURN  several times  to
                  move past System News and Alert messages.

STEP 3.     DOWNLOADING FILES

The files that appear on  the following table can be downloaded from E$.  Except
for short text files e.g., "txt" files cannot be viewed on-screen  within the E$BBS.
As indicated o the following table, each document formats - WordPerfect 5.1 (PC),
WordPerfect 6.1 (PC), PDF (viewable through free Adobe Acrobat software which
can be downloaded). Please note that the quality of formatting and  graphics is
highest  in the file version  in which the Guide was originally created, i.e., the
underlined ones. The high quality versions are underlined on the following list
of filenames.

Information on Macintosh Word Files

Available Macintosh files are not compressed. The files are easily identified by
the seventh  and eight position in the filename - which is "MA."  They  can be
directly downloaded and read using Microsoft Word 5.1a, or within other word
processing  software that  supports  the conversion of Microsoft  Word  5.la
documents.  Conversion to  other programs may alter formatting  and graphics
quality.
                                Appendix A - 4

-------
                                                                    6/19/96
Information on PC/WordPerfect Files
The WordPerfect files are all compressed ("zipped" files ending with  the  .ZIP
extension)  files  that  need to be  decompressed  ("unzipped")  after they are
downloaded. The Guides that are available in WP5.1 and  WP 6.0  are zipped
together (this is why the filenames on the following table are the same). When
these  files are downloaded and  unzipped,  you will  have a version with the
extension ".WP5" and one with ".WP6."

                        Filename, and File Formats

      Note: Underlined file contains the highest quality format/graphics

                  PC WP5.1          PC WP 6.1        PDF File
Wood Preserving     WDPRESSN.ZIP   WPRESSN.ZIP    WDPRES.PDF
RCRA Compliance
Guide

STEP 3 CONTINUES - PROCEDURES FOR DOWNLOADING

      •     From the E$ Main Menu, select  "D" to  Download  then hit
            ENTER/RETURN.

      •     Type in the filename from above that you would like to select for
            downloading and hit ENTER/RETURN.

      •     The system will ask  you to select a file transfer protocol. Select the
            file  transfer protocol that matches what you have selected within
            your PC communications software (ZModem is recommended) and
            hit ENTER/RETURN.  (Tip: ZModem users may also be allowed to
            enter  more  than one  filename  to  download  more  than  one
            document at a time.  Simply continue to enter a new filename  each
            time a new filename  prompt appears on the  screen.  This option  is
            disabled for other users.)

      •     At  this   point,  you  may   begin  downloading   by  hitting
            ENTER/RETURN.   This  should begin the  download  if you are
            using the Zmodem  transfer protocol.  If you don't see information
            on the screen showing the progress of the  download,  follow the
            next step.

      •     If the download  does not begin after following the last step, you
            need to tell your communications software to start receiving the
            file.  To do this, look for a "RECEIVE" icon  or command  on your
            communications software  menu and  activate  it.  This tells your
            software to begin downloading.
                                Appendix A - 5

-------
      •     The downloaded file will appear in the folder or directory that you
            defined in your communications software.

      •     Repeat the above procedure to download other files.

            THE FOLLOWING STEP MUST  BE TAKEN BY ALL USERS THAT
            HAVE DOWNLOADED ZIPPED FILES (files with a ".ZIP" filename
            extension) FROM E$.

                 In order to read the zipped file(s) you have downloaded, you
                 must  download the decompression  software  required  to
                 "unzip"  your  files.   To  download  the  decompression
                 software, follow the same downloading instructions  given
                 above.   Type  in  the  filename  TKZ204G.EXE"  and  hit
                 ENTER/RETURN.   You only  need to download this file to
                 your hard drive once.

      •     Log-off using the [G]oodbye command from the main menu.

      •     To end the phone connection, the user should use the "hang up" or
            "terminate call" option provided with your communications
            software.

STEP 4.     DECOMPRESSING ".ZIP'D" DOWNLOADED FILES

      After you have downloaded a compressed (",ZIP") file  to your PC, you
must decompress it to its original format and size by using the "PKUnzip"  file
which  you downloaded at the beginning  of Step 3.  The  file which you
downloaded; "PKZ204G.EXE"  contains PKZip.EXE  and  PKUnzip.EXE files.
PKUNZIP will decompress the file, returning it  to its original size and format as
if it had never been compressed or transmitted over the BBS. To use the PK
commands (pkunzip.exe & pkzip.exe),  you must  be at the DOS prompt (third-
party software interfaces  exist for Windows). For details on how to use  either
command, simply type at the DOS prompt (without any parameters, i.e., just type
"PKUNZIP") and hit  ENTER/RETURN. Since  parameters are required for the
PKs to work they will automatically go into help mode and  give you a brief
explanation  of how they work. If a user needs more direction,  there is  full
documentation included in the PKZ204G.EXE in the  "Hints" file.

To decompress any file, use PKUNZIP.EXE by taking the following steps:

      •     Go to the DOS C: prompt and type PKUNZIP.EXE; then,

      •     Type "PKUNZIP [Filename]" (e.g., the filename and the path of the
            compressed file you wish  to decompress). Note:  after the paired
                                Appendix A - 6

-------
            files are unzipped, two files will exist, one extension  ".WP5" and
            one with the extension ".WP6."

C.    COMMENTING OR PROVIDING ADDITIONAL INFORMATION VIA
      E$BBS

      Comments on the Guide, or supplemental documents of interest, can  be
uploaded  to  the  Enviro$en$e BBS.   Follow the  uploading instructions  that
appear on the screen, or look at the instructions for compressing and uploading
documents.   The instructional documents  are  listed in Section D of this
Appendix. All documents that you  upload will be publicly accessible, and should
contain a  short abstract (less that 50 words) that describes the document.  It is
recommended that this abstract contain  the words "Wood Preserving Guide
Comments,"  the title of the  Guide  that the  comments  are  directed  toward, and
the words  "SIC 24."

      NOTE:   To help the system  operator know  what  you've
      uploaded  and where  it should  be put within the  BBS, it is
      helpful to send a message to the system operator.  Before logging
      out  of E$, you will be given the option to comment to the system
      operator (Sysop).  Please indicate what files  you have sent, and
      that the comments or supplemental documents should be placed
      in Directory 51 - "Sector Compliance  Information  and Guides."
      Messages can also be  sent to the Sysop from the main menu
      using the Message option.
                                 Appendix A - 7

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D.    ADDITIONAL RESOURCE DOCUMENTS AVAILABLE ON E$BBS

      The following files can be viewed from the  "Bulletins" section  of E$BBS
main menu.    To  receive  these documents  electronically, the files  can be
downloaded (and viewed) from Directory #160 (utilities).  If you would like to
download these files, follow the  same procedures outlined in Section C.   The
directions for  direct dial modem users are different than the directions for EPA
LAN users. How you have  accessed the E$BBS determines  which of the paired
files listed below that you should follow.
    Entered E$
    via Modem
Entered E$
EPA LAN
CONREGWP.TXT    CNREGLAN.TXT
FINDVIEW.TXT     FNDVWLAN.TXT
CONVCOMP.TXT    CVCMPLAN.TXT
DNLDTXWP.TXT    DNLTXLAN.TXT
DNLDZPWP.TXT    DNZPLAN.TXT
UPLOADWP.TXT    UPLDLAN.TXT
SNHOWTO.TXT    SNHOWLAN.TXT
Descriptions of File

How to Connect and Register on the E$BBS via
Modem
Finding and Viewing Files from E$BBS via
Modem
Converting, Compressing & Uncompressing Files
via Modem
Flagging and Dowloading "Uncompressed" Files
from E$BBS
Flagging and Downloading "Compressed" Files
from E$BBS
Directions for Uploading Files via Modemto the
E$BBS
Contains this document "Appendix A -
Downloading Instructions"
                                  Appendix A-8

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Appendix B
 Contact Lists

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                                                             June 19, 1996
                            CONTACT LISTS



This appendix contains the following contact lists:



1)    Information Sources



2)    State Solid and Hazardous Waste Contacts



3)    State Emergency Response Commissions (SERCS)



4)    NPDES State Directors



5)    Storm Water Contacts



6)    State Pesticide Agencies



7)    Regional Air Compliance/Enforcement Contacts.
                                 Appendix B -1

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                              Information Sources

U.S. EPA cannot endorse the products or services of any group. The following
sources are provided simply as a first step to locating information that might be
useful to plant operators.

Drip pad construction

American Concrete Institute
P.O. Box 19150
Detroit, MI 48219
(313) 532 2600
This group can provide documents, such as, A Guide to the Use of Water Proofing.
Damp Proofing. Protective and Decorative Barrier Systems for Concrete (document
number 515.1R-79(85)).

Steel Structures Painting Council (SSPC)
P.O. Box 641256
Pittsburgh, PA 15264-1256
(412) 281-2331
This group publishes the Journal of Protective Coatings and Linings, which
periodically features a buyer's guide.
(800) 837-8303

National Association of Corrosion Engineers International
(NACE International)
1440 S. Creek Drive
Houston, TX  77084-4906
(713) 492-0535
A committee  called the "Joint Task Group H (with SSPC) Looking at Secondary
Containment Over Concrete" will be releasing a report in the near future.  Ask to
speak to the chairman of the task group.

Suppliers of preservatives may be able to provide technical assistance on drip pad
construction.

Compliance Information

National Technical Information Service
5285 Port Royal Road
Springfield, VA  22161
sales desk: (703) 487-4650
fax:   (703) 321-8547
                              Information Sources -1

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This service, which is provided by the U.S. Department of Commerce, is a
clearinghouse for scientific, technical, and engineering information developed by
government agencies including the U.S. Environmental Protection Agency.  Callers
should request a free copy of the catalog of Products and Services.

U.S. Government Printing Office
Superintendent of Documents (mail stop: SSOP)
Washington, D.C. 20402-9328
Copies of the Code of Federal Regulation (CFR) can be ordered by writing to the
address above.  Of primary interest are 40 CFR (Protection of Environment) sections
260 to 265.

RCRA/Superfund  Hotline
1725 Jefferson Davis Highway
Arlington, VA 22202
phone: (800) 424-9346
or (703) 412-9810

Answers to specific questions and information on relevant publications is available
though this U.S. EPA hotline.

U.S. EPA
RCRA Docket Information Center
Office of Solid Waste (mail code 5305W)
401 M St. S.W.
Washington, D.C. 20460
voice: (703) 603-9230
fax:   (703) 603-9234

This information center provides background materials relating to RCRA
regulation development, such as, Federal Register Notices, records of public
comment, meeting summaries, fact sheets, Health and Environmental Effects
Profiles, et cetera.
Agency Addresses
U.S. Environmental Protection Agency Regional Offices

U.S.EPA Region I
John F. Kennedy Federal Building
Boston, MA 02203-0001
(617) 565-3420

Region I encompasses: Connecticut, Maine, Massachusetts, New Hampshire, Rhode
Island, and Vermont.
                                 Information Sources - 2

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 U.S. EPA Region E
 Waste Management Division
 290 Broadway
 New York, NY 10007-1866
 (212) 637-3725

 Region II encompasses:  New Jersey, New York, Puerto Rico, and the Virgin Islands.

 U.S. EPA Region El
 Hazardous Waste Management Division
 841 Chestnut Building
 Philadelphia, PA 19107
 (215) 597-8181

 Region IE encompasses: Delaware, the District of Columbia, Maryland,
 Pennsylvania, Virginia, and West Virginia.

 U.S. EPA Region IV
 Waste Management  Division
 245 Courtland St. N.E.
 Atlanta, GA 30365
 (404) 347-3454

 Region IV encompasses: Alabama, Florida, Georgia, Kentucky, Mississippi, North
 Carolina, South Carolina, and Tennessee.

 U.S. EPA Region V
 Waste Management  Division
 77 West Jackson Blvd.
 Chicago, E, 60604-3507
 (312) 886-7579

Region V encompasses:  Illinois, Indiana, Michigan, Minnesota, Ohio, and
Wisconsin.

U.S. EPA Region VI
Fountain Place  12th  Floor, Suite 1200
1445 Ross Avenue
Dallas, TX 75202-2733
(214) 665-8179

Region VI encompasses: Arkansas, Louisiana, New Mexico, Oklahoma, and Texas.
                                Information Sources - 3

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U.S. EPA Region VH
Air and RCRA Compliance Branch
726 Minnesota Avenue
Kansas City, KS 66101
(913) 551-5000

Region VH encompasses: Iowa, Kansas, Missouri, and Nebraska.

U.S. EPA  Region VIE
Hazardous Waste Management Division
999 18th Street Suite 500
Denver, CO 80202-2405
(3030) 293-1603

Region VIE encompasses: Colorado, Montana, North Dakota, South Dakota, Utah,
and Wyoming.

U.S. EPA Region IX
Hazardous Waste Management Division
75 Hawthorne Street
San Francisco, CA 94105
(415) 744-1305

Region DC encompasses:  Arizona, California, Hawaii, Nevada, American Samoa,
and Guam.

U.S. EPA Region X
Hazardous Waste Division
1200 Sixth Avenue
Seattle,  WA 98101
(206) 553-4973

Region X encompasses: Alaska, Idaho, Oregon, and Washington.
                              Information Sources - 4

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                           State Solid and Hazardous Waste Contacts
Alabama
Solid Waste
Russel A. Kelly, Chief
1751 Congressman W.L. Dickinson Drive
Solid Waste Branch
Land Division
Alabama Department of Environmental Mgmt.
PO Box 301463
Montgomery,   AL    36130-1463
Phone: (334) 271-7988
Fax:   (334) 279-3050
Hazardous Waste Phone Inquiries
Jeff Hurst
Hazardous Waste Management Program
Industrial Operations Section
Division of Air and Water Quality
AK Department of Environmental Conservation
410 Willoughby Ave., Suite 105
Juneau,   AK  99801-1795
Phone: (907) 465-5168; (800) 550-7272 (AK only)
Fax:   (907) 465-5274
Hazardous Waste
Steve Jenkins, Chief
RCRA Compliance Branch
Land Division
Alabama Department of Environmental Management
1751 Congressman W.L. Dickinson Dr.
PO Box 301463
Montgomery,   AL   36130-1463
Phone: (334) 271-7737
Fax:   (334) 279-3050
American Samoa

Solid and Hazardous \Vaste
Sheila Wiedman, Program Manager
AS Environmental Protection Agency
Executive Office Building
Pago Pago,   AS   96799
Phone: [0111 (684) 633-2304
Fax:   [0111 (684) 633-5801
Alaska

Solid Waste
Heather Stockard, Program Manager
Solid Waste Program
Division of Environmental Health
Alaska Department of Environmental Conservation
410 Willoughby Ave., Suite 105
Juneau,   AK  99801-1795
Phone: (907) 465-5162; (800) 550-7272 (AK onlv)
Fax:   (907) 465-5164
Pat Young
Office of Pacific Islands and Native American Programs
EPA Region 9
75 Hawthorne St.
San Francisco,  CA   94105
Phone: (415) 744-1594
Fax:   N/A
Hazardous Waste
Geoffrey Kany, Program Manager
Hazardous Waste Management Program
Industrial Operations Section
Division of Air and Water Quality
AK Department of Environmental Conservation
410 Willoughby Ave., Suite 105
Juneau,  AK  99801-1795
Phone: N/A
Fax:   (907) 465-5274
Arizona

Solid Waste
Jim North, Unit Manager
Solid Waste Inspections and Compliance Unit
Division of Waste Programs
AZ Department of Environmental Quality
3033 N. Central Ave.
Phoenix,   AZ   85012
Phone: (602) 207-4121
Fax:  (602) 207-4467

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 Hazardous Waste
 Pat Kuefler, Unit Manager
 Hazardous Waste Compliance Unit
 AZ Department of Environmental Quality
 3033 N. Central Ave.
 Phoenix,   AZ   85012
 Phone: (602) 207-4105
 Fax:   (602) 207-4138
 Solid Waste Phone Inquiries
 Switchboard
 CA Integrated Waste Management Board
 8800 Cal Center Dr.
 Sacramento,   CA   95826
 Phone: (916) 255-2200 or (800) 553-2962 (CA only)
 Fax:  (916) 255-2220
 Arkansas

 Solid Waste
 Al Eckert, Chief
 Solid Waste Division
 AR Department of Pollution Control and Ecology
 8001 National Dr., Building E
 P.O. Box 8913
 Little Rock,  AR   72219-8913
 Phone: (501) 682-0580
 Fax:   (501) 682-0611
 Hazardous Waste
 Ted N. Rauh, Deputy Director
 Hazardous Waste Management Program
 CA Department of Toxic Substances Control
 P. O. Box 806

 Sacramento,   CA   95812-0806
 Phone: N/A
 Fax:  (916) 324-4495
Hazardous Waste
Mike Bates, Chief
Hazardous Waste Division
AR Department of Pollution Control and Ecology
8001 National Dr.
P.O. Box 8913
Little Rock,  AR   72219-8913
Phone: (501) 682-0831
Fax:   (501) 682-0880
Hazardous Waste Phone Inquiries
Switchboard
CA Integrated Waste Management Board
8800 Cal Center Dr.
Sacramento,  CA   95826
Phone: (916) 324-1781 or (800) 61-TOXIC (CA onlv)
Fax:   (916) 255-2220
California

Solid Waste
Doug Okumura, Executive Director
CA Integrated Waste Management Board
8800 Cal Center Dr.

Sacramento,  CA   95826
Phone: N/A
Fax:  (916) 255-4073
Colorado

Solid Waste
Glenn Mallory, Section Chief
Solid Waste Section
Hazardous Materials and Waste Management Division
CO Department of Health and Environment
4300 Cherry Creek Dr., South
Mail Code: HMWMD-HWC-B2
Denver,   CO   80222
Phone: N/A
Fax:   (303) 759-5355
                          State Solid and Hazardous Waste Contacts

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  Hazardous Waste
   ian Sowinski, Section Chief
    izardous Materials and Waste Management Division
  CO Department of Health and Environment
  4300  Cherry Creek Dr., South
  Mail Code: HMWMD-HWC-B2
  Denver,   CO   80222-1530
  Phone: N/A
  Fax:   (303) 759-5355
                                                            Delaware

                                                            Solid Waste
                                                            Richard Folmsbee, Supervisor
                                                            Solid Waste Branch
                                                            Air and Waste Management Division
                                                            DE Dept. of Natural Resources and Environmental Control
                                                            89 Kings Hwy.
                                                            P.O. Box 1401
                                                            Dover,   DE   19903
                                                            Phone: (302) 739-3820
                                                            Fax:   (302) 739-5060
 Hazardous Waste Phone Inquiries
 Public Assistance Hotline
 Hazardous Materials and Waste Management Division
 CO Department of Health and Environment
 4300 Cherry Creek Drv South
 Mail Code: HMWMD-HWC-B2
 Denver,   CO   80222
 Phone: (303) 692-3320
 Fax:   (303)759-5355
  bnnecticut

   lid Waste
 Charles Atkins, Supervising Sanitary Engineer
 Solid Waste Program
 Waste Engineering and Enforcement Division
 Bureau of Waste Management
 CT Department of Environmental Protection
 79 Elm St.
 Hartford,   CT   06106
 Phone: (203) 424-3366
 Fax:   (203) 424-4059
                                                           Hazardous Waste
                                                           Nancy Marker, Program Manager
                                                           Hazardous Waste Management Branch
                                                           Air and Waste Management Division
                                                           DE Dept. of Natural Resources and Environmental
                                                           Control
                                                           89 Kings Hwy.
                                                           T% y^ T>   •» * f\-4
                                                           Dover,  DE   19903
                                                           Phone: (302) 739-3689
                                                           Fax:  (302) 739-5060

                                                           District of Columbia

                                                           Solid Waste
                                                           Sylvestre Yorrick, Chief
                                                           Solid Waste Management Administration
                                                           Solid Waste Disposal Division
                                                           DC Department of Public Works
                                                           3200BenningRd.,N.E.
                                                           Washington,  DC   20019
                                                           Phone: N/A
                                                           Fax:   (202) 727-9314
^^a
Hazardous Waste
Robert Isner, Environmental Analyst
Waste Engineering and Enforcement
Bureau of Waste Management
CT Department of Environmental Protection
79 Elm St.
Hartford,   CT  06106
Phone: (203) 424-3023
      (203) 424-4059
                                                          Solid Waste Phone Inquiries
                                                          Switchboard
                                                          DC Department of Public Works
                                                          2nd & N. St., S.E.
                                                          Washington,   DC   20003
                                                          Phone: (202) 645-7044
                                                          Fax:   (202) 645-6040
                             State Solid and Hazardous Waste Contacts

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Hazardous Waste
Angelo C. Tompros, Chief
Hazardous Waste Management Branch
Pesticides, Hazardous Materials and UST Division
DC Environmental Regulatory Administration
2100 Martin Luther King, Jr. Ave., S.E.
Suite 203
Washington,   DC   20020
Phone: N/A
Fax:   (202) 645-6622
Hazardous Waste Phone Inquiries
Raoul Clark, Environmental Administrator
Hazardous Waste Management Section
Bureau of Solid and Hazardous Waste
FL Department of Environmental Protection
2600 Blair Stone Rd., Twin Towers
Tallahassee,  FL   32399-2400
Phone: (904) 488-0300
Fax:   (904) 414-8061
Hazardous Waste Phone Inquiries
James Sweeney, Acting Chief
Hazardous Waste Management Branch
Pesticides, Hazardous Materials and UST Division
DC Environmental Regulatory Administration
2100 Martin Luther King, Jr. Ave., S.E.
Suite 203
Washington,   DC   20020
Phone: (202) 645-6080 Ext. 3011
Fax:   (202) 645-6622
Georgia

Solid Waste
Steve Johnson, Associate
Solid Waste Management Branch
Environmental Protection Division
G A Department of Natural Resources
4244 International Pkwy., Suite 100
Atlanta,   GA   30354
Phone: (404) 362-2696
Fax:   (404) 362-2693
Florida

Solid Waste
Mary Jean Yon, Environmental Administrator
Solid Waste Management Section
Bureau of Solid and Hazardous Waste
Division of Waste Management
FL Department of Environmental Protection
2600 Blair Stone Rd., Twin Towers
Tallahassee,  FL   32399-2400
Phone: (904) 488-0300
Fax:  (904) 414-0414
 Hazardous Waste
 Jennifer Kaduck, Branch Chief
 Hazardous Waste Management Branch
 Environmental Protection Division
 GA Department of Natural Resources
 205 Butler St., S.E.
 Floyd Towers East, Room 1154
 Atlanta,   GA   30334
 Phone: N/A
 Fax:   (404) 651-9425
 Hazardous Waste
 Bill Hinkley, Chief
 Bureau of Solid and Hazardous Waste
 Division of Waste Management
 FL Department of Environmental Protection
 2600 Blair Stone Rd., Twin Towers
 Tallahassee,   FL   32399-2400
 Phone: N/A
 Fax:  (904) 921-8061
 Hazardous Waste Phone Inquiries
 Bill Mundy, Program Manager
 Hazardous Waste Management Branch
 Environmental Protection Division
 GA Department of Natural Resources
 205 Butler St., S.E.
 Floyd Towers East, Room 1154
 Atlanta,   GA   30334
 Phone:(404)656-7802
 Fax:   (404) 651-9425
                                State Solid and Hazardous Waste Contacts

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 Guam

 (Solid and Hazardous Waste
 Francis P. Damian, Director
 Solid and Hazardous Waste Management Program
 GU Environmental Protection Agency
 P.O.Box22439GMF

 Barrigada,   GU   96921
 Phone: [Oil] (671) 472-8863
 Fax:   fOlll (671) 477-9402
                                                         Idaho

                                                         Solid Waste
                                                         Katie Sewell, Solid Waste Coordinator
                                                         Community Programs
                                                         Prevention and Certification Bureau
                                                         Division of Environmental Quality
                                                         ID Department of Health and Welfare
                                                         1410 N. Hilton St.
                                                         Boise,   ID   83706
                                                         Phone: (208) 334-5860
                                                         Fax:  (208) 373-0576
Victoria Pearman
Office of Pacific Islands and Native American Programs
EPA Region 9
75 Hawthorne St.
San Francisco,  CA   94105
Phone: (415) 744-1484
Fax:   N/A
                                                         Hazardous Waste
                                                         Orville Green, Assistant Administrator
                                                         Permits and Enforcement Branch
                                                         Division of Environmental Quality
                                                         ID Department of Health and Welfare
                                                         1410 N. Hilton St.
                                                         Boise,   ID  83706
                                                         Phone: N/A
                                                         Fax:   (208) 373-0417
  awan

Solid Waste
John Harder, Coordinator
Solid Waste Section
Office of Solid Waste Management
HI Department of Health
919 Ala Moana Blvd., 2nd Floor
Honolulu,   HI    96814
Phone: (808) 586-4240
Fax:   (808) 586-7509
                                                        Hazardous Waste Phone Inquiries
                                                        Pam Smolczynski, Hazardous Waste Analyst
                                                        Permits and Enforcement Branch
                                                        Division of Environmental Quality
                                                        ID Department of Health  and Welfare
                                                        1410 N. Hilton St.
                                                        Boise,  ID   83706
                                                        Phone: (208) 334-5898
                                                        Fax:   (208) 373-0417
Hazardous Waste
Gracelda Simmons, Section Chief
Hazardous Waste Section
Environmental Management Division
HI Department of Health
919 Ala Moana Blvd., Room 212
Honolulu,   HI   96814
Phone: (808) 586-4226
 'ax:   (808) 586-7509
                                                        Solid Waste and Hazardous Waste Phone Inquiries
                                                        Glenn Savage, Head
                                                        Field Operations Section
                                                        Bureau of Land Pollution Control
                                                        IL Environmental Protection Agency
                                                        2200 Churchill Rd.
                                                        P.O. Box 19276
                                                        Springfield,   IL   62794-9276
                                                        Phone: (217) 785-8604
                                                        Fax:  (217) 524-1991
                            State Solid and Hazardous Waste Contacts

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Hazardous Waste
Todd Marvel, RCRA Coordinator
Bureau of Land Pollution Control
IL Environmental Protection Agency
2200 Churchill Rd.
P.O. Box 19276
Springfield,   IL   62794-9276
Phone: N/A
Fax:  (217)  524-4193
Hazardous Waste Phone Inquiries
Dave Berry
Hazardous Waste Management Branch
Office of Solid and Hazardous Waste
IN Department of Environmental Management
105 N. Senate Ave.
P.O. Box 6015
Indianapolis,  IN  46206-6015

Phone: (317) 232-4417
Fax:   (317) 232-3403
Indiana

Solid Waste
Bruce Palin, Branch Chief
Solid Waste Management Branch
Office of Solid and Hazardous Waste
IN Department of Environmental Management
100 N. Senate Ave.
P.O. Box 6015
Indianapolis,   IN   46206-6015
Phone: N/A
Fax:   (317) 232-3403
golid Waste Phone Inquiries
Jerry Rud, Section Chief
Solid Waste Permit Section
Office of Solid and Hazardous Waste
IN Department of Environmental Management
100 N. Senate Ave.
P.O. Box 6015
Indianapolis,   IN   46206-6015
Phone: (317) 232-7200
Fax:  (317) 232-3403
Iowa

Solid Waste
Lavoy Haage, Supervisor
Solid Waste Section
IA Department of Natural Resources
Henry Wallace State Office Building
900 E. Grand Ave.
DesMoines,  IA   50319-0034
Phone: (515) 281-4968
Fax:   (515) 281-8895
 Hazardous Waste
 Iowa Section
 Air, RCRA; and Toxic Division
 U.S. EPA Region 7
 726 Minnesota Ave.
 Kansas City,   KS   66101
 Phone: (913) 551-7058
 Fax:  (913) 551-7521
 Hazardous Waste
 Tom Linsom, Branch Chief
 Hazardous Waste Management Branch
 Office of Solid and Hazardous Waste
 IN Department of Environmental Management
 105 N. Senate Ave.
 P.O. Box 6015
 Indianapolis,   IN  46206-6015
 Phone: N/A
 Fax:  (317) 232-3403
 Kansas

 Solid Waste
 Miles Stotts, Chief
 Solid Waste Section
 Bureau of Waste Management
 KS Department of Health and Environment
 Forbes Field, Building 740
 Topeka,  KS   66620-0001
 Phone: (913) 296-1603
 Fax:  (913) 296-1592
                              State Solid and Hazardous Waste Contacts

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 Hazardous Waste
 fohn Mitchell, Chief
 Hazardous Waste Section
 Bureau of Waste Management
 KS Department of Health and Environment
 Forbes Field, Building 740
 Topeka,   KS   66620-0001
 Phone: (913) 296-1608
 Fax:   (913) 296-1592
                                                          Solid Waste Phone Inquiries
                                                          Gerald Mathes, Assistant Administrator
                                                          Solid Waste Division
                                                          Office of Solid and Hazardous Waste
                                                          LA Department of Environmental Quality
                                                          7290BluebonnetDr.
                                                          P.O. Box 82178
                                                          Baton Rouge,  LA   70884-2178
                                                          Phone: (504) 765-0333
                                                          Fax:   (504) 765-0299
 Kentucky

 Solid Waste
 George Gilbert, Manager
 Solid Waste Branch
 Division of Waste Management
 KY Department of Environmental Protection
 14 Reilly Rd., Frankfort Office Park
 Frankfort,   KY   40601
 Phone: (502) 564-6716
 Fax:   (502) 564-4049
                                                         Hazardous Waste
                                                         Glenn Miller, Assistant Secretary
                                                         Hazardous Waste Division
                                                         Office of Solid and Hazardous Waste
                                                         LA Department of Environmental Quality
                                                         7290 Bluebonnet Dr.
                                                         P.O. Box 82178
                                                         Baton Rouge,  LA   70884-2178
                                                         Phone: N/A
                                                         Fax:   (504) 765-0617
Hazardous Waste
Mike Welch, Manager
Hazardous Waste Branch
Division of Waste Management
KY Department of Environmental Protection
14 Reilly Rd., Frankfort Office Park
Frankfort,  KY   40601
Phone: (502) 564-6716
Fax:   (502) 564-4049
                                                         Hazardous Waste Phone Inquiries
                                                         Stacy Hall
                                                         Hazardous Waste Division
                                                         Office of Solid and Hazardous Waste
                                                         LA Department of Environmental Quality
                                                         7290 Bluebonnet Dr.
                                                         P.O. Box 82178
                                                         Baton Rouge,   LA   70884-2178
                                                         Phone: (504) 765-0758
                                                         Fax:    (504) 765-0617
 Louisiana

 Solid Waste
 William Mollere, Administrator .
 Solid Waste Division
 Office of Solid and Hazardous Waste
 LA Department of Environmental Quality
 7290 Bluebonnet Dr.
 P.O. Box 82178
 Baton Rouge,   LA   70884-2178
Phone: N/A
 'ax:   (504) 765-0299
                                                        Maine

                                                        Solid Waste
                                                        Paula Clark, Director
                                                        Division of Solid Waste Facilities Regulations
                                                        Bureau of Hazardous Materials and Solid Waste Control
                                                        ME Department of Environmental Protection
                                                        State House, Station #17
                                                        Augusta,  ME   04333
                                                        Phone: N/A
                                                        Fax:  (207) 287-7826
                                State Solid and Hazardous Waste Contacts

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Solid Waste Phone Inquiries
Carol Sifrino
Division of Solid Waste Facilities Regulations
Bureau of Hazardous Materials and Solid Waste Control
ME Department of Environmental Protection
State House, Station #17
Augusta,   ME   04333
Phone: (207) 287-2651
Fax:   (207) 287-7826
Solid Waste Phone Inquiries
Hedi Alazi, Acting Chief
Solid Waste Program
Solid Waste Compliance Division
MD Department of the Environment
2500 Broening Hwy.
Baltimore,  MD   21224
Phone: (410) 631-3375
Fax:   (410) 631-3321
Hazardous Waste
Scott Whittier, Director
Division of Oil and Hazardous Materials Facilities
Regulations
Bureau of Hazardous Materials and Solid Waste Control
ME Department of Environmental Protection
State House, Station #17
Augusta,   ME   04333
Phone: N/A
Fax:  (207) 287-7826
 Hazardous Waste Phone Inquiries
 Stacey Ladner
 Division of Oil and Hazardous Materials Facilities
 Regulations
 Bureau of Hazardous Materials and Solid Waste Control
 ME Department of Environmental Protection
 State House, Station #17
 Augusta,   ME   04333
 Phone: (207) 287-2651
 Fax:   (207) 287-7826
Hazardous Waste
Harold Dye, Program Administrator
Hazardous Waste Program
MD Department of the Environment
2500 Broening Highway
Baltimore,   MD   21224
Phone: N/A
Fax:   (410) 631-3321
 Hazardous Waste Phone Inquiries
 Edward Hammerberg, Chief
 Hazardous Waste Program
 Regulations and Authorization Division
 MD Department of the Environment
 2500 Broening Hwy.
 Baltimore,   MD   21224
 Phone: (410) 631-3345
 Fax:   (410) 631-3321
 Maryland

 Solid Waste
 Barry Schmidt, Administrator
 Solid Waste Program
 MD Department of the Environment
 2500 Broening Hwy.
 Baltimore,  MD    21224
 Phone: N/A
 Fax:   (410) 631-3321
 Massachusetts

 Solid Waste
 Phil Weinberg, Director
 Division of Solid Waste
 MA Department of Environmental Protection
 One Winter St., 4th Floor
 Boston,   MA   02108
 Phone: N/A
 Fax:   (617) 556-1049
                             State Solid and Hazardous Waste Contacts

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  Solid Waste Phone Inquiries
  Jim Roberts/Caroline Ganley
  Division of Solid Waste
  MA Department of Environmental Protection
  One Winter St., 4th Floor
  Boston,  MA   02108
  Phone: (617) 292-59837(617) 292-5985
  Fax:   (617) 556-1049
  Hazardous Waste
  Jim Sygo, Chief
  Waste Management Division
  MI Department of Environmental Quality
  608 W. Allegan, 1st Floor
  Lansing,  MI   48933
  Phone: N/A
  Fax:   (517) 373-4797
 Hazardous Waste
 Steven DeGabriele, Acting Director
 Hazardous Waste Division
 MA Department of Environmental Protection
 One Winter St., 7th Floor
 Boston,   MA   02108
 Phone: N/A
 Fax:    (617) 292-5778
 Hazardous Waste Phone Inquiries
 Jack Schinderle
 Waste Management Division
 MI Department of Environmental Quality
 608 W. Allegan, 1st Floor
 Lansing,   MI   48933
 Phone: (517) 373-8410
 Fax:   (517) 373-4797
 Hazardous Waste Phone Inquiries
 James Miller, Chief of Compliance
 Hazardous Waste Division
 MA Department of Environmental Protection
 One Winter St., 7th Floor
 Boston,  MA   02108
 Phone:(617)292-5574
 Fax:   (617) 292-5778
 Minnesota

 Solid Waste
 Gary Pulford, Manager
 Solid Waste Section
 Ground Water and Solid Waste Division
 MN Pollution Control Agency
 520 N. Lafayette Rd.
 St. Paul,   MN   55155-1494
 Phone: (612) 296-7340
 Fax:   (612) 296-8717
Michigan

Solid Waste
Joan Peck, Manager
Solid Waste Program Section
Waste Management Division
MI Department of Environmental Quality
608 W. Allegan, 1st Floor
Lansing,   MI   48933
Phone: (517) 335-3383
Fax:   (517) 373-4797
Hazardous Waste
Roger Bjork, Manager
Hazardous Waste Regulatory Compliance Section
Hazardous Waste Division
MN Pollution Control Agency
520 N. Lafayette Road
St. Paul,   MN   55155-1494
Phone: (612) 297-8512
Fax:   (612) 297-8676
                             State Solid and Hazardous Waste Contacts

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Mississippi

Solid Waste
Billy Warden, Administrator
Solid Waste Section
Ground Water Protection Division
Office of Pollution Control
MS Department of Environmental Quality
2380 Highway 80 West
Jackson,  MS   39204
Phone: (601) 961-5171
Fax:   (601) 354-6612
Montana

Solid Waste
Jon Dilliard, Manager
Solid Waste Program
Solid and Hazardous Waste Bureau
MT Department of Environmental Quality
P.O. Box 200901
Helena,   MT  59620-0901
Phone: (406) 444-1430
Fax:   (406) 444-1499
Hazardous Waste
Jerry Banks, Acting Chief
Hazardous Waste Division
Office of Pollution Control
MS Department of Environmental Quality
2380 Highway 80 West
Jackson,   MS   39204
Phone: (601) 961-5171
Fax:  (601) 961-5741
Hazardous Waste
Don Vidrine, Program Manager
Hazardous Waste Program
Solid and Hazardous Waste Bureau
MT Department of Environmental Quality
P.O. Box 200901
Helena,  MT   59620-0901
Phone: (406) 444-1430
Fax:   (406) 444-1499
 Missouri

 Solid Waste
 Hal Morton, Jim Hull
 Solid Waste Management Program
 Division of Environmental Quality
 MO Department of Natural Resources
 P.O. Box 176
 Jefferson City,   MO   65102
 Phone: (314) 751-5401
 Fax:  (314) 526-3902
 Nebraska

 Solid Waste
 Dave Haldeman, Section Supervisor
 Integrated Waste Management Section
 Air and Waste Management Division
 NE Department of Environmental Quality
 1200 N St., The Atrium, Suite 400
 P.O. Box 98922
 Lincoln,  NE   68509-8922
 Phone: (402) 471-4219
 Fax:  (402) 471-2909
 Hazardous Waste
 Ed Sadler, Director
 Hazardous Waste Program
 Division of Environmental Quality
 MO Department of Natural Resources
 P.O. Box 176
 Jefferson City,  MO  65102
 Phone: (314) 751-3176
 Fax:   (314) 751-7869
 Hazardous Waste
 Bill Imig, Supervisor
 RCRA Section
 Air and Waste Management Division
 NE Department of Environmental Quality
 1200 N St., The Atrium, Suite 400
 P.O. Box 98922
 Lincoln,   NE    68509-8922
 Phone: (402) 471-4217
 Fax:   (402) 471-2909
                            State Solid and Hazardous Waste Contacts

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Nevada
Solid Waste
Les Gould, Supervisor
Solid Waste Branch
Waste Management Bureau
Division of Environmental Protection
NV Department of Conservation and Natural Resources
333 W. Nye Lane
Carson City,   NV   89710
Phone: N/A
Fax:   (702) 687-5856
Hazardous Waste
John Duclos, Administrator
Hazardous Waste Compliance Section
Waste Management Compliance Bureau
Waste Management Division
NH Department of Environmental Services
6 Hazen Dr.
Concord,   NH   03301-6509
Phone: (603) 271-2942
Fax:   (603) 271-2456
Solid and Hazardous Waste Phone Inquiries
Hazardous Waste Hotline
University of Nevada at Reno
Reno,  NV
Phone: (702) 784-1717 or (800) 882-3233 (NV onlv)
Fax:   N/A
New Jersey

Solid Waste
Gil Mueller
Bureau of Recycling and Planning
NJ Department of Environmental Protection
120 S. Stockton St.
Trenton,   NJ   08625
Phone: (609) 984-3438
Fax:   (609) 984-6881
Hazardous Waste
Colleen Cripps, Supervisor
Program Development Branch
Waste Management Bureau
Division of Environmental Protection
NV Department of Conservation and Natural Resources
333 W. Nye Ln.
Carson City,  NV   89710
Phone: N/A
Fax:   (702) 885-0868
Hazardous \Vaste
Frank Coolick, Administrator
Regulation Element
NJ Department of Environmental Protection
120 S. Stockton St.
Trenton,   NJ   08625
Phone: (609) 633-1418
Fax:   (609) 984-6881
New Hampshire

Solid Waste
Ken Marschner, Administrator
Waste Management Compliance Bureau
NH Department of Environmental Services
6 Hazen Dr.
Concord,  NH  03301-6509
Phone: (603) 271-2900
Fax:  (603) 271-2456
New Mexico

Solid  Waste
Gerald Silva, Bureau Chief
Solid Waste Bureau
NM Environmental Department
P.O. Box 26110
Santa  Fe,   NM   87502
Phone: (505) 827-2775
Fax:   (505) 827-2902
                             State Solid and Hazardous Waste Contacts

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Hazardous Waste
CobyMuckclroy
Hazardous Waste and Radioactive Materials Bureau
NM Environmental Department
2044 Galisteo St.
Santa Fe,   NM   87505-2100
Phone: (505) 827-1558
Fax;   (505) 827-1544
Solid Waste Phone Inquiries
Switchboard
Solid Waste Section
Division of Solid Waste Management
NC Dept. of Environment, Health, and Natural Resources
P.O. Box 27687
Raleigh,  NC   27611-7687
Phone: (919) 733-0692
Fax:   (919) 733-4810
New York

Solid Waste
Richard Baldwin
Landfill Closure Section
Division of Solid and Hazardous Materials
NY Department of Environmental Conservation
50 Wolfe Rd.,Rm 206
Albany, . NY   12233
Phone: (518) 457-5695
Fax:   (518) 485-7733
Hazardous Waste
Larry Nadler, Chief
Division of Solid and Hazardous Materials
NY Department of Environmental Conservation
50 Wolfe Rd.,Rm 423
Albany,  NY   12233
Phone: (518) 485-8988
Fax:   (518) 485-8769
Hazardous Waste
Linda Mann Culpepper, Supervisor
Hazardous Waste Section
Division of Solid Waste Management
NC Dept. of Environment, Health and Natural Resources
P.O. Box 27687
Raleigh,  NC   27611-7687
Phone: N/A
Fax:   (919) 715-3605
Hazardous Waste Phone Inquiries
Margaret Babb, Environmental Chemist
Hazardous Waste Section
Division of Solid Waste Management
NC Dept. of Environment, Health and Natural Resources
P.O.Box 27687
Raleigh,  NC  27611-7687
Phone: (919) 733-2178
Fax:   (919) 715-3605
 North Carolina

 Solid Waste
 Dexter Matthews, Chief
 Solid Waste Section
 Division of Solid Waste Management
 NC Dept. of Environment Health, and Natural Resources
 P.O. Box 27687
 Raleigh,   NC   27611-7687
 Phone: N/A
 Fax:  (919) 733-4810
 North Dakota

 Solid Waste
 Steve Tillotson, Manager
 Solid Waste Program
 Division of Waste Management
 ND Department of Health
 P.O. Box 5520
 Bismark,   ND  58506-5520
 Phone: (701) 328-5166
 Fax:  (701) 328-5200
                               State Solid and Hazardous Waste Contacts

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 Hazardous Waste
 Curt Erickson, Manager
 Hazardous Waste Program
 Division of Hazardous Waste Management
 ND Department of Health
 P.O. Box 5520
 Bismark,  ND   58506-5520
 Phone: (701) 328-5166
 Fax:  (701) 328-5200
 Solid Waste Phone Inquiries
 Dan Harris
 Solid and Infectious Waste Division
 OH Environmental Protection Agency
 2305 W. Brook Dr., Bldg C
 Columbus,   OH   43216-1049
 Phone: (614) 728-5374
 Fax:   (614)728-5315
 Northern Mariana Islands

 Solid and Hazardous Waste
 John Castro, Director
 Division of Environmental Quality
 MP Department of Public Works
 P. O. Box 1304
 Saipan,   MP    96950
 Phone: [Oil] (670) 234-6114
 Fax:   [Oil] (670) 234-1003
 Hazardous Waste
 Pam Allen, Manager
 Compliance, Monitoring and Enforcement Section
 Division of Hazardous Waste Management
 OH Environmental Protection Agency
 1800 Watermark Dr.
 Columbus,  OH   43215
 Phone: N/A
 Fax:   (614) 728-2329
Jim Branch
Office of Pacific Islands and Native American Programs
EPA Region 9
75 Hawthorne St.
San Francisco,   CA   94105
Phone: (415) 744-1601
Fax:   N/A
Hazardous Waste Phone Inquiries
Switchboard
Technical Assistance Section
Compliance, Monitoring and Enforcement Section
Division of Hazardous Waste Management
OH Environmental Protection Agency
1800 Watermark Dr.
Columbus,  OH    43215
Phone: (614) 644-2944
Fax:   (614) 728-2329
Ohio

Solid Waste
Barbara Birdicka, Chief
Solid and Infectious Waste Division
OH Environmental Protection Agency
2305 W. Brook Dr., Bldg. C
Columbus,   OH  43216-1049
Phone: N/A
Fax:   (614) 728-5315
Oklahoma

Solid Waste
Chris Varga, Chief
Solid Waste Management Service
OK Department of Environmental Quality
1000 N.E. 10th St.
Oklahoma City,   OK   73117-1212
Phone: (405) 745-7100
Fax:  (405) 745-7133
                           State Solid and Hazardous Waste Contacts

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HazardousJWaste
H.A. Caves, Chief
Division of Hazardous Waste Management
OK Department of Environmental Quality
1000 N.E. 10th St.
Oklahoma City,  OK   73117-1212
Phone: N/A
Fax:  (405) 271-8425
Hazardous Waste Phone Inquiries
Switchboard
Hazardous Waste Policy and Program Development Sect*
Waste Management and Cleanup Division
OR Department of Environmental Quality
811 S.W. 6th Ave.
Portland,   OR   97204
Phone: (503) 229-5913
Fax:   (503) 229-6977
Hazardous Waste Phone Inquiries
Switchboard
Division of Hazardous Waste Management
OK Department of Environmental Quality
1000 N.E. 10th St.
Oklahoma,   OK  73117-1212
Phone: (405) 271-5338
Fax:   (405) 271-8425
Pennsylvania

Solid Waste
William Pounds, Chief
Municipal and Residual Waste Division
Bureau of Land Recycling and Waste Management
PA Department of Environmental Protection
400 Market St.
14th Floor
Harrisburg,   PA   17101-2301
Phone: N/A
Fax:   (717) 787-1904
Oregon

Solid Waste
Charles Donaldson
Solid Waste Program
Waste Management and Cleanup Division
OR Department of Environmental Quality
750 Front St., N.E., Suite 120
Salem,   OR   97310
Phone: (503) 378-8240 ext. 266
Fax:   (503) 378-4196
Solid Waste Phone Inquiries
Marjorie Hughes
Recycling Division
Bureau of Land Recycling and Waste Management
PA Department of Environmental Protection
400 Market St.
14th Floor
Harrisburg,   PA  17101-2301
Phone: (717)  787-7382
Fax:.  (717)  787-1904
Hazardous Waste
Roy Brower, Manager
Hazardous Waste Program
Waste Management and Cleanup Division
OR Department of Environmental Quality
811 S.W. 6th Ave.
Portland,   OR   97204
Phone: N/A
Fax:   (503) 229-6977
Hazardous Waste
Leon Kuchinski, Chief
Division of Hazardous Waste Management
Bureau of Land Recycling and Waste Management
PA Department of Environmental Protection
400 Market St.
14th Floor
Harrisburg,  PA   17101-2301
Phone: (717) 787-6239
Fax:   (717) 787-0884
                              State Solid and Hazardous Waste Contacts

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Puerto Rico

Solid Waste
(Daniel Pagan, Executive Director
PR Solid Waste Management Authority
P.O. Box 40285
San Juan,   PR   00940
Phone: (809) 765-7575
Fax:   (809) 756-6353
South Carolina

Solid Waste
William Culler, P. E., Director
Division of Solid Waste Management
SC Department of Health and Environmental Control
2600 Bull St.
Columbia,   SC   29201
Phone: (803) 896-4201
Fax:   (803) 896-4001
Hazardous Waste
Israel Torres, Acting Director
Land Pollution Control Area
PR Environmental Quality Board
P.O. Box 11488
San Juan,   PR   00910
Phone: (809) 763-4448
Fax:   (809) 767-8118
Hazardous Waste
Randy Thompson, Director
Division of Hazardous and Infectious Waste Management
SC Department of Health and Environmental Control
2600 Bull St.
Columbia,   SC   29201
Phone: (803) 896-4171
Fax:   (803) 896-4002
Rhode Island

Solid Waste
Ron Gagnon, Chief
Solid Waste Section
Division of Waste Management
RI Department of Environmental Management
291 Promenade St.
Providence,   RI   02908
Phone: (401) 277-2797
Fax:   (401) 277-2017
South Dakota

Solid Waste                 "•
David Templeton, Administrator
Waste Management Program
SD Department of Environment and Natural Resources
523 E. Capitol Ave., Foss Building
Pierre,  SD   57501-3181
Phone: (605) 773-3153
Fax:  (605) 773-6035
Hazardous Waste
Thomas Epstein
Hazardous Waste Section
Division of Waste Management
RI Department of Environmental Management
291 Promenade St.
Providence,   RI   02908
Phone: (401) 277-2797
Fax:   (401) 277-2017
Hazardous Waste
Vonni Kallemeyn, Natural Resources Senior Scientist
Waste Management Program
SD Department of Environment and Natural Resources
523 E. Capitol Ave., Foss Building
Pierre,  SD   57501-3181
Phone: (605) 773-3153
Fax:   (605) 773-6035
                               State Solid and Hazardous Waste Contacts

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Tennessee

Solid Waste
Tom Tiesler, Director
Solid Waste Management Division
TN Department of Environmental Conservation
401 Church St.
L & C Tower, 5th Floor
Nashville,  TN   37243
Phone: (615) 532-0780
Fax:   (615) 532-0231
Hazardous Waste Phone Inquiries
Switchboard
Industrial and Hazardous Waste Division
TX Natural Resource Conservation Commission
P. O. Box 13087
Austin,   TX   78711-3087
Phone: (512) 239-2334
Fax:  (512) 239-2007
Hazardous Waste
Tom Tiesler, Director
Solid Waste Management Division
TN Department of Environmental Conservation
401 Church St.
L & C Tower, 5th Floor
Nashville,   TN   37243
Phone: (615) 532-0780
Fax:   (615) 532-0231
Utah

Solid Waste
Ralph Bohn, Manager
Solid Waste Section
Division of Solid and Hazardous Waste
UT Department of Environmental Quality
P.O. Box 144880
Salt  Lake City,  UT   84114-4880
Phone: (801) 538-6170
Fax:   (801) 538-6715
Texas

Solid Waste
Brian Dickson, Director
Municipal Solid Waste Division
TX Natural Resource Conservation Commission
P.O. Box 13087
Austin,   TX  78711-3087
Phone: (512) 239-6787
Fax:   (512) 239-6717
Hazardous Waste
Scott Anderson, Branch Manager
Hazardous Waste Compliance Section
Division of Solid and Hazardous Waste
UT Department of Environmental Quality
P.O. Box 144880
Salt Lake City,  UT   84114-4880
Phone: N/A
Fax:   (801) 538-6715
Hazardous Waste
Minor Hibbs, Director
Industrial and Hazardous Waste Division
TX Natural Resource Conservation Commission
P.O. Box 13087
Austin,   TX  78711-3087
Phone: N/A
Fax:  (512) 239-2007
Hazardous Waste Phone Inquiries
Switchboard
Hazardous Waste Compliance Section
Division of Solid and Hazardous Waste
UT Department of Environmental Quality
P.O. Box 144880
Salt Lake City,  UT   84114-4880
•Phone: (801) 538-6170
Fax:   (801)538-6715
                              State Solid and Hazardous Waste Contacts

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Vermont

Solid Waste
Gary Schultz, Acting Director
Solid Waste Management Program
VT Department of Environmental Conservation
103 S. Main St., 1 South
Waterbury,   VT  05671
Phone: N/A
Fax:   (802)241-3273
 Virgin Islands

; Solid and Hazardous Waste
 Larry Austin Moorhead,. Director
 Division of Environmental Protection
 VI Department of Planning and Natural Resources
 Government of the Virgin Islands
 1118 Watergut Homes
 Christiansted
 St. Croix,  VI    00820-5065
 Phone: (809) 773-0565
 Fax:   (809) 773-9310
Solid Waste Phone Inquiries
Chris Wagner
Solid Waste Management Program
VT. Department of Environmental Conservation
103 S. Main St., 1 South
Waterbury,  VT  05671
Phone: (802) 241-3444
Fax:   (802) 241-3273
 Virginia

 Solid Waste
 Ulysses Brown
 SW Compliance Section
 Waste Division
 VA Department of Environmental Quality
 P.O. Box 10009
 Richmond,   VA   23240-0009
 Phone: (804) 762-4238
 Fax:   (804) 762-4383
Hazardous Waste
George Desch, Acting Director
Hazardous Materials Division
VT Department of Environmental Conservation
103 S. Main St., West Building
Waterbury,   VT   05671
Phone: N/A
Fax:   (802) 241-3296
Hazardous Waste
Steve Frazier
Compliance Section
Hazardous Waste Division
VA Department of Environmental Quality
P.O. Box 10009
Richmond,  VA   23240-0009
Phone: (804) 762-4238
Fax:   (804) 762-4383
Hazardous Waste Phone Inquiries
Steve Simoes, Supervisor
Hazardous Materials Division
VT Department of Environmental Conservation
103 S. Main St., West Building
Waterbury,  VT   05671
Phone: (802) 241-3868
Fax:   (802)241-3296
Washington

Solid Waste
Jim Pendowski, Program Manager
Local Government Solid Waste Program
WA Department of Ecology
P.O. Box 47600
Olympia,  WA   98504-7600
Phone: N/A
Fax:   (360) 407-6102
                            Stale Solid and Hazardous Waste Contacts

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Solid Waste Phone Inquiries
Randy Martin, Environmental Supervisor
Local Government Solid Waste Services Program
WA Department of Ecology
P.O. Box 47600
Olympia,  WA   98504-7600
Phone: (360) 407-6136
Fax:   (360) 407-6102
Hazardous Waste
G. S. Atwell, Assistant Chief
Hazardous Waste Management Section
Division of Environmental Protection
WV Department of Natural Resources
1356 Hansford St.
Charleston,   WV   25301
Phone: (304) 558-5393
Fax:   (304) 558-0256
Hazardous Waste
Megan White, Program Manager
Division of Hazardous Waste and Toxics Reduction
WA Department of Ecology
P.O. Box 47600
Olympia,  WA   98504-7600
Phone: N/A
Fax:   (360) 407-6715
Wisconsin

Solid Waste
Lakshimi Sridharan, Section Chief
Solid Waste Management Section
Division of Environmental Quality
WI Department of Natural Resources
P. O. Box 7921 SW/3
Madison,   WI   53707-7921
Phone: (608) 266-2111
Fax:   (608) 267-7524
 Hazardous Waste Phone Inquiries
 Ty Thomas, Unit Supervisor
 Division of Hazardous Waste and Toxics Reduction
 WA Department of Ecology
 P.O. Box 47600
 Olympia,   WA   98504-7600
 Phone: (360) 407-6758
 Fax:   (360) 407-6715
 Hazardous Waste
 Barbara Zellmer, Section Chief
 Hazardous Waste Management Section
 Division of Environmental Quality
 WI Department of Natural Resources
 P.O. Box 7921 SW/3
 Madison,   WI   53707-7921
 Phone: (608) 266-2111
 Fax:   (608) 267-7524
 West Virginia

 Solid Waste
 Richard Cook, Assistant Chief
 Solid Waste Management Section
 Division of Environmental Protection
 WV Department of Natural Resources
 1356 Hansford St.
 Charleston,  WV   25301
 Phone: (304) 558-6350
 Fax:   (304) 558-1574
 Wyoming

 Solid Waste
 Ken Schreuder, Manager
 Solid Waste Permitting and Corrective Action Program
 Solid Waste and Hazardous Waste Division
 WY Department of Environmental Quality
 250 Lincoln St.
 Lander,  WY   82520
 Phone: (307) 332-6924
 Fax:   (307) 332-7726
                             State Solid and Hazardous Waste Contacts

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Hazardous Waste
David Findley, Administrator
Solid and Hazardous Waste Division
WY Department of Environmental Quality
122 W. 25th St.
Cheyenne,   WY   82002
Phone: N/A
Fax:   (307)  777-5973
Hazardous Waste Phone Inquiries
Carl Anderson, Hazardous Waste Supervisor
Solid and Hazardous Waste Division
WY Department of Environmental Quality
122 W. 25th St.
Cheyenne,   WY   82002
Phone: (307)  777-7752
Fax:   (307)  777-5973
                             State Solid and Hazardous Waste Contacts

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              STATE EMERGENCY RESPONSE COMMISSIONS
ALABAMA                                        AMERICAN SAMOA
Paulette Williams, Chair
Alabama Emergency Response Commission
Alabama Emergency Management Agency
520 South Court Street
Montgomery AL 36130
Phone: (334) 280-2204
Section(s): 302304311312313


John Smith, Director
Alabama Emergency Response Commission
Alabama Department of Environmental Management
1751 Congressman W.L. Dickinson Drive
Montgomery AL 36109
Phone: (334) 271-7706
Section(s): None
Faamausili Pola
Territorial Emergency Mgmt. Coordinating Officer
American Samoan Government
Department of Public Safety
P.O. Box 1086
Pago Pago AS 96799
Phone: (684) 633-1111
Section(s):  302304


Pati Faiai
American Samoa Environmental Protection Agency
Office of the Governor
Pago Pago AS 96799
Phone: (684) 633-2304
Section(s):  311312313
Edward Poolos
Alabama Department of Environmental Management
P.O. Box 301463
Montgomery AL 36130-1463
Phone:
Section(s):  302 304 311312 313

ALASKA

Brigadier General Kenneth Taylor, Jr., Acting Chair
Department of Military and Veteran Affairs
Division of Emergency Services
P.O. Box 5750
Fort Richardson AK 99505-5750
Phone: (907)428-7039
Section(s):  None
ARIZONA

William D. Lockwood, Chairman
Arizona Emergency Response Commission
5636 East McDowell Road
Phoenix AZ 85008
Phone:
Section(s): None


Daniel Roe, Executive Director
Arizona Emergency Response Commission
Division of Emergency Management
5636 East McDowell Road
Phoenix AZ 85008
Phone: (602) 231-6346
Section(s): 302 304 311312 313
Ervin Martin, Director
Department of Military and Veteran Affairs
Division of Emergency Services
P.O. Box 5750
Fort Richardson AK 99505-5750
Phone: (907) 428-7039
Section(s):  302304311312
Sandra Eberhardt
Arizona Department of Environmental Quality
Pollution Prevention Unit Manager
3033 North Central Avenue
Phoenix AZ 85012
Phone: (602) 207-4210
Section(s): 313
Camille Stephens
Department of Environmental Conservation
Pollution Prevention Office
410 Willoughby Avenue, Suite 105
Juneau AK 99801-1795
Phone: (907)465-5220
Section(s): 313

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              STATE EMERGENCY RESPONSE COMMISSIONS

ARKANSAS                                      COLORADO
Randall Mathis, Chairman
State Emergency Response Commission
c/o AR Dept. of Pollution Control and Ecology
P.O. Box 9583
Little Rock AR 72219-9583
Phone:
Section(s):  None


John Ward
State Emergency Response Commission
c/o AR Dept. of Pollution Control and Ecology
P.O. Box 8913
8001 National Drive
Little Rock AR 72219-8913
Phone: (501) 562-7444
Section(s):  302 304 311312 313

CALIFORNIA

Dr. Richard Andrews, Director
Chemical Emergency Planning and Response
Commission
Office of Emergency Services
Hazardous  Materials Division
2800 Meadowview Road
Sacramento CA 95832
Phone:
Scction(s):  None
Steve Gunderson
Colorado Emergency Planning Commission
Colorado Department of Health
Mail Code OE-EMU-B2
4300 Cherry Creek Drive South
Denver CO 80222-1530
Phone: (303) 692-3022
Section(s):  302 304 311312


Tamara Vanhorn
Colorado Emergency Planning Commission
Colorado Department of Public Health and
Environment
4300 Cherry Creek Drive South
Denver CO 80222-1530
Phone: (303) 692-3017
Section(s):  313


CONNECTICUT

Gerald P. Goudreau, Chairman
State Emergency Response Commission
c/o Ulbrich Stainless Steels
1 Dudley Ave.
P.O. Box 610
Wallingford CT 06492
Phone: (203) 269-2507
Section(s):  None
David Zocchetti
Chemical Emergency Planning and Response
Commission
Office of Emergency Services
Hazardous Materials Division
2800 Meadowview Road
Sacramento CA 95832
Phone: (916) 262-1750
Section(s): 302304311312


Stephen Hanna
California Environmental Protection Agency
Assistant for Environmental Information
555 Capitol Mall
Suite 235
Sacramento CA 95814
Phone: (916) 324-9924
Section(s): 313
David Jersey, SARA Title HI Coordinator
Department of Environmental Protection
c/o Waste Management
79 Elm Street
Hartford CT 06106-5127
Phone: (203)424-3373
Section(s): 302 304 311312


Joseph Pulaski
Department of Environmental Protection
SERC Administrator
c/o Waste Management
79 Elm Street
Hartford CT 06106-5127
Phone: (203) 424-3373
Section(s): 313

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              STATE EMERGENCY RESPONSE COMMISSIONS

DELAWARE                                       FLORIDA
Karen Johnson, Chair/Secretary
Delaware Department of Public Safety
P.O. Box 818
Dover DE 19901
Phone: (302) 739-4321
Section(s):  None


Joe Wessels, SARA Title III Coordinator
Delaware Emergency Management Agency
P.O. Box 527
Delaware City DE 19706
Phone: (302) 834-4531
Section(s):  302


 Joanne Deramo
Division of Air and Waste Management
Dept. of Natural Resources & Environmental Control
89 Kings  Highway
P.O. Box 1401
Dover DE 19903
Phone: (302) 739-4791
Section(s):  304 311312 313


DISTRICT OF COLUMBIA

 Samuel Jordan, Acting Director
Office of Emergency Preparedness
2000 14th Street, NW
Washington DC 20009
Phone:
Section(s):  None


Jacqueline Love, Environmental Planning Specialist
Emergency Response Commission for Title IE
Office of Emergency Preparedness
2000 14th Street, NW
8th Floor
Washington DC 20009
Phone: (202)673-2101 Ext. 3151
Section(s): 302304311312313
Linda Lomis Shelley, Chair
Florida Department of Community Affairs
Division of Emergency Management
State Emergency Response Commission
2740 Centerview Drive
Tallahassee FL 32399-2100
Phone: (904) 413-9970
Section(s): None


Eve Rainey, Compliance Planning
Florida Department of Community Affairs
Division of Emergency Management
State Emergency Response Commission
2740 Centerview Drive
Tallahassee FL 32399-2149
Phone: In State: (800) 635-7179
       Out of State: (904) 413-9970
Section(s): 302 304 311312


 Sam Brackett
State Emergency Response Commission
Florida Department of Community Affairs
2740 Centerview Drive
Tallahassee FL 32399-2100
Phone: (904) 413-9970
       in Florida (800) 635-7179
Section(s): 313


GEORGIA

Joe Tanner, Chairman/Commissioner
Georgia Emergency Response Commission
205 Butler Street, S.E.
Suite 1252
Atlanta GA 30334-4910
Phone: (404) 656-3500
Section(s):  None


Burt Langley, Chief
Georgia Emergency Response Commission
205 Butler Street, S.E.
Floyd Tower East, Suite 1166
Atlanta GA 30334
Phone: (404) 656-6905
Section(s): 302304311312313

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             STATE EMERGENCY RESPONSE COMMISSIONS
GUAM

Dr. George Boughton, Chairman
Guam Emergency Response Commission
Civil Defense - Guam Emergency Services Office
Government of Guam
P.O. Box 2877
Auguana GU  96910
Phone: (671) 472-7230
       FTS only: 550-7230
Scction(s): 302304311312


Fred M. Castro
Guam Environmental Protection Agency
D407 Harmon Plaza
130 Rojas Street
Harmon GU 96911
Phone: (671) 646-8863 or 8864
Section(s): 313


HAWAII

Marsha Mealey
Hawaii State Emergency Response Commission
Hawaii State  Department of Health
P.O. Box 3378
919 Ala Moana Boulevard, Room 206
Honolulu HI  96814
Phone: (808) 586-4694
Scctionfe): 302304311312313


Lawrence Miike
Hawaii State Emergency Response Commission
Hawaii State  Department of Health
P.O. Box 3378
Honolulu HI  96801
Phone: (808) 586-4410
Scction(s): None


IDAHO

Jack Peterson, Chairman
Idaho Emergency Response Commission
4040 Guard Street
Gowen Field
P.O. Box 83720
Boise ID 83720-3401
Phone: (208) 334-3263
Section(s): None
Margaret Ballard, Chief of Staff
Idaho Emergency Response Commission
4040 Guard Street
Gowen Field
P.O. Box 83720
Boise ID 83720-3401
Phone: (208) 334-3263
Section(s): 302304311312313


ILLINOIS

John Mitchell, Chair
State Emergency Response Commission
Illinois Emergency Management Agency
110 East Adams Street
Springfield IL  62701-9963
Phone: (217) 782-2700
Section(s): None


Oran Robinson
Hazardous Materials Compliance and Enforcement
State Emergency Response Commission
c/o Illinois Emergency Management Agency
110 East Adams Street
Springfield IL  62706
Phone: (217) 782-4694
Section(s): 302 304 311312


Joe Goodner
Illinois Environmental Protection Agency
Office of Chemical Safety
Emergency Planning Unit
P.O.Box 19276
2200 ChurchiU Road
Springfield IL  62794-9276
Phone: (217) 785-0830
Section(s): 313


INDIANA

Melvin Carraway, Chair
State Emergency Response Commission
Indiana Government Center South
302 West Washington Street, Room E208
Indianapolis IN  46204
Phone: (317) 232-3986
Section(s): None

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              STATE EMERGENCY RESPONSE COMMISSIONS
John Rose, Staff Director
Indiana Department of Environmental Management
100 North Senate Avenue (N-1255)
P.O. Box 7024
Indianapolis IN 46207
Phone: (317) 308-3001
Section(s): 302304311312
Walter Johnson, Vice-Chair
Iowa Emergency Response Commission
Iowa Division of Labor
1000 East Grand Avenue
Des Moines IA 50319
Phone: (515) 281 -8460
Section(s):  None
Paula Smith
Indiana Department of Environmental Management
Office of Pollution Prevention Technical Assistance
100 North Senate Avenue (N-1355)
P.O. Box 6015
Indianapolis IN 46206-6015
Phone: (317) 232-8172
Section(s): 313
KANSAS

Bob Barid
General Motors
3201 Fairfax Traffic Way
Kansas City KS 66115
Phone: (913) 573-7303
Section(s): None
IOWA

William Zitterich, P.E.
Iowa Emergency Response Commission
IA DOT, Maintenance Services Engineer
800 Lincoln Way
Ames IA 50010
Phone: (515) 239-1396
Section(s):  None

Paul Sadler
Disaster Services Division
Hoover State Office Building
Des Moines IA 50319
Phone: (515) 242-5171
Section(s):  302
Jon Flint
Kansas Emergency Response Commission
Right-to-Know Program
J Street and 2 North,
Forbes Field Building 283
Topeka KS 66620
Phone: (913) 296-1690
Section(s):  302311312313

Frank Moussa
Kansas Division of Emergency Preparedness
State Defense Building
2800 South Topeka Avenue
Topeka KS 66611-1287
Phone: (913) 274-1409
Section(s):  304
Pete Hamlin, Chief
Air Quality Bureau
Iowa Department of Natural Resources
Wallace Office Building
900 East Grand Avenue
Des Moines IA 50319
Phone: (515) 281-8852
Section(s):  304313

Don Peddy
Iowa Division of Labor
1000 East Grand Avenue
Des Moines IA 50319
Phone: (515) 281-8460
Section(s):  311312
KENTUCKY

Ron Padgett, Acting Chair
Kentucky Emergency Response Commission
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort KY 40601-6168
Phone: (502) 564-8681
Section(s): None

Major General Robert L. DeCarn
Kentucky Emergency Response Commission
Kentucky Disaster and Emergency Services
Boone National Guard Center
Frankfort KY 40601-6168
Phone: (502) 564-8558
Section(s): 302 304 311 312

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              STATE EMERGENCY RESPONSE  COMMISSIONS
Alex Barber
Kentucky Department for Environmental Protection
14 Reilly Road
Frankfort KY 40601-1132
Phone: (502) 564-2150
Scction(s):  313


LOUISIANA

Capt. Mark  S. Oxley, Chair
Louisiana Emergency Response Commission
Office of State Police, Right-to-Know Unit
P.O. Box 66614
7901 Independence Boulevard
Baton Rouge LA 70806
Phone: (504) 925-6113
Section(s):  None
Rayna Leibowitz
State Emergency Response Commission
State House Station Number 72
Augusta ME 04333
Phone: (207) 287-4080
       in Maine (800) 452-8735
Section(s): 302304311312313


MARYLAND

David McMillian, Chairman
Governor's Emergency Management Advisory Council
c/o Maryland Emergency Management Agency
2 Sudbrook Lane, East
Pikesville MD 21208
Phone: (410) 486-4422
Section(s): None
Robert Hayes
Louisiana Emergency Response Commission
Office of State Police, Right-to-Know Unit
P.O. Box 66614
7901 Independence Boulevard
Baton Rouge LA 70806
Phone: (504) 925-6113
Section(s):  302 304 311312


Linda Brown
Department of Environmental Quality
Office of the Secretary
P.O. Box 82263
Baton Rouge LA 70884-2263
Phone: (504) 765-0737
Scction(s):  313
Lee Marshall
Maryland Department of the Environment
Hazardous Waste Program
2500 Broening Highway
Baltimore MD 21224
Phone: (410) 631-3800
Section(s): 302 304 311312


Patricia Williams
State Emergency Response Commision
Maryland Department of the Environment
Toxics Inventory Program
2500 Broening Highway
Baltimore MD 21224
Phone: (410)631-3800
Section(s): 313
MAINE

David D. Brown, Chairman
State Emergency Response Commission
Station Number 72
Augusta ME 04333
Phone: In State: (800) 452-8735
       Out of State: (207) 289-4080
Scction(s): None
MASSACHUSETTS

Kathleen O'Toole, Chair
Secretary of Public Safety
Massachusetts Emergency Response Commission
Executive Office of Public Safety
One Asburton Place, Room 2133
Boston MA 02108
Phone: (617) 727-7725
Section(s):  None

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             STATE EMERGENCY RESPONSE COMMISSIONS
Douglas Forbes
Massachusetts Emergency Management Agency
P.O. Box 1496
400 Worcester Road
Framingham MA 01701-0317
Phone:(508)820-2040
Section(s): 302304311312


William Panos
Massachusetts Dept. of Environmental Projection
Bureau of Waste Prevention
Toxics Use Reduction Program
1 Winter Street
Boston MA 02108
Phone: (617)292-5870
Section(s): 313

MICHIGAN

Captain Robert Tarrant, Chair
Michigan State Police
300 South Washington Square, Suite 300
Lansing MI 48913
Phone: (517) 334-5103
Section(s): None

Robert Jackson, Chief, Grants & Information
State Emergency Response Commission
Michigan Department of Environmental Quality
Environmental Assistance Division
P.O. Box 30457
Lansing MI 48909
Phone: (517) 373-8481
Section(s): 302304311312313

MINNESOTA

David Senjem, Chair
State Emergency Response Commission
Mayo Clinic
Rochester MN 55905
Phone: (507) 284-8890
Section(s): None
Paul Aasen
Minnesota Emergency Response Commission
Room B-5
State Capitol Building
75 Constitution Avenue
St. Paul MN 55155
Phone: (612) 282-5391
Section(s): 302 304 311312


 John Chikkala
Minnesota Emergency Response Commission
Room B-5
State Capitol Building
75 Constitution Avenue
St. Paul MN 55155
Phone: (612) 282-5396
Section(s): 313

MISSISSIPPI

J.E. Maher, Chairman
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson MS 39296-4501
Phone: (601) 960-9000
Section(s): None

John David Burns
Mississippi Emergency Response Commission
Mississippi Emergency Management Agency
P.O. Box 4501
Jackson MS 39296-4501
Phone: (601) 960-9000
Section(s): 302304311312313

MISSOURI

Bob Krauss, Coordinator
Missouri Department of Public Safety
Division of Fire Safety
P.O. Box 3133
1715 Industrial Drive
Jefferson City MO 65102
Phone: (314) 751-2930
Section(s): 302311312

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              STATE EMERGENCY RESPONSE COMMISSIONS
Gene Nickel
Missouri Department of Natural Resources
P.O. Box 176
Jefferson City MO 65102
Phone: (314) 526-6627
Section(s):  304

Eugene Nickel
Missouri Department of Natural Resources
Technical Assistant Program
P.O. Box 176

Jefferson City MO 65102
Phone: (573) 526-6627
Section(s):  313

MONTANA

Bob Robinson, Co-Chairman
Montana Emergency Response Commission
ESD/DHES
Cogswell Building A-107
Capitol Station
P.O. Box 200901
Helena MT 59620-0901
Phone: (406) 444-2544
Section(s):  302 304311312

Tom Ellerhoff, Co-Chairman
Montana Emergency Response Commission
ESD/DHES
Cogswell Building C108
Capitol Station
P.O. Box 200901
Helena MT 59620-0901
Phone:
Section(s):  302304311312313

Tom Ellerhoff
Montana Emergency Response Commission
Environmental Sciences Division
Department of Health & Environmental Sciences
Capitol Station
Cogswell Building C-108, P. O. Box 200901
Helena MT 59620-0901
Phone: (406) 444-1374
Section(s):  313
NEBRASKA

Major General Stanley M. Heng, Chairman
Nebraska Emergency Response Commission
1300 Military Road
Lincoln NE 68508-1090
Phone: (402)473-1100
Section(s): None
Dale Bush, Interim Coordinator
Nebraska Department of Environmental Quality
P.O. Box 98922
State House Station
Lincoln NE 68509-8922
Phone:
Section(s):  304311312


John Tracy
Nebraska Civil Defense
1300 Military Road
Lincoln NE 68508-1090
Phone: (402) 471-7415
Section(s):  302
John Steinauer, Coordinator
State of Nebraska Department of Environmeni
Quality
P.O. Box 98922
Lincoln NE 68509-8922
Phone: (402) 471-4230
Section(s): 313

NEVADA

Bill Owen, Executive Director
State Emergency Response Commission
555 Wright Way
Carson City NV 89711-0900
Phone: (702) 687-6973
Section(s): 302

Division of Emergency Management
2525 South Carson Street
Carson City NV 89710
Phone: (702) 687-4240
Section(s): 304

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              STATE EMERGENCY RESPONSE COMMISSIONS
Gene Williams
 ire  Marshall's  Office
 07 Jacobsen Drive
Capitol Complex
Carson City NV 89710
Phone: (702) 687-4290
Section(s):  311312
                                                     Stan Delikat
                                                     Director of Responsible Party Site Remediation
                                                     Bureau of Emergency Response
                                                     401 East State Street CN-028
                                                     Trenton NJ 08625
                                                     Phone:  (609) 633-2168
                                                     Section(s): 304
Alene Coulson
Division of Emergency Management
333 West Nye Lane
Capitol Complex
Carson City NV 89710
Phone: (702) 682-5872
Section(s): 313


NEW HAMPSHIRE
George L. Iverson, Director
New Hampshire Office of Emergency Management
Title HI Program
State Office Park South
107 Pleasant Street
Concord NH 03301
 'hone: (603) 271-2231
 ection(s): None
Leland Kimball
NH State Emergency Management Agency
Title III Program
State Office Park South
107 Pleasant Street
Concord NH 03301-3809
Phone: (603) 271-2231
Section(s): 302 304 311312 313

NEW JERSEY

Shirlee Schiffman, Chief
NJ Department of Environmental Protection & Energy
Bureau of Hazardous Substances Information, DBS
Health and Analytical Programs
401 East State Street, CN 405
Trenton NJ 08625
Phone: (609) 282-6714
Section(s): 302
                                                     Alan Bookman
                                                     NJ Dept. of Environmental Protection and Energy
                                                     Bureau of Hazardous Substances Information
                                                     Division of Environmental Safety
                                                     Health and Analytical Programs
                                                     401 East State Street CN-405
                                                     Trenton NJ 08625
                                                     Phone: (609) 984-5338
                                                     Section(s):  311312


                                                     Andrew Opperman
                                                     Department of Environmental Protection
                                                     Div. of Environmental Quality, Safety, Health &
                                                     Analytical
                                                     SARA Title III Section 313
                                                     Bureau of Chemical Release Information & Prevention
                                                     401 East State Street CN-405
                                                     Trenton NJ 08625
                                                     Phone: (609) 984-3219
                                                     Section(s):  313

                                                     NEW MEXICO

                                                     Irene Trujillo, Chairman
                                                     New Mexico Emergency Response Commission
                                                     New Mexico Department of Public Safety
                                                     P.O. Box 1628
                                                     Sante Fe NM 87504-1628
                                                     Phone: (505) 827-9223
                                                     Section(s):  None

                                                     Max Johnson, Coordinator
                                                     New Mexico Emergency Response Commission
                                                     Chemical Safety Office
                                                     Emergency Management Bureau
                                                     P.O. Box 1628
                                                     Sante Fe NM 87504-1628
                                                     Phone: (505) 827-9223
                                                     Section(s):  302 304 311312 313

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             STATE EMERGENCY RESPONSE COMMISSIONS
NEW YORK

Major General Michael Hall, Vice Chairman
New York Emergency Response Commission
State Emergency Management Office
Building 22/State Campus
Albany NY 12226-5000
Phone: (518) 457-2222
Section(s): None


William Miner
New York Emergency Response Commission
NY State Dept. of Environmental Conservation
Bureau of Spill Prevention and Response
50 Wolf Road
Room 340
Albany NY 12233-3510
Phone: (518) 457-4107
Section(s): 302304311312313

NORTH CAROLINA

Billy Camaron,  Chairman
North Carolina Emergency Response Commission
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh NC  27603-1335
Phone: (919) 733-3825
Section(s): None


Emily Kilpatrick
North Carolina Emergency Response Commission
North Carolina Division of Emergency Management
116 West Jones Street
Raleigh NC  27603-1335
Phone: (919) 733-3865
Section(s): 302304311312313

NORTH DAKOTA

Lyle Gallagher, Director of Communications
State  Radio Communications Department
P.O. Box 5511
Bismark ND 58502
Phone:  (701) 224-2121
Section(s): 304
Douglas C. Friez, Chairman
ND State Division of Emergency Management
P.O. Box 5511
Bismark ND 58502-5511
Phone: (701) 328-3300
Section(s): 302311312


Robert Johnston
North Dakota Emergency Response Commission
Division of Emergency Management
P.O. Box 5511
Bismarck ND 58502-5511
Phone: (701) 328-2111
Section(s): 313


NORTHERN MARIANA

Felix Sasamoto, Civil Defense Coordinator
Office of the Governor
Capitol Hill
Commonwealth of Northern Mariana Islands
Saipan CM 96950
Phone: (670) 322-9529 International Call
Section(s):  302 304 311312


Frank Russell Meecham, III
Division of Environmental Quality
Commonwealth of the Northern Mariana Islands
Doctor Torres Hospital
P.O. Box 1304
Saipan MP 96950
Phone:  (670) 234-6984 International Call
Section(s):  313


OHIO

Jane Harf, Chairman
State Emergency Response Commission
Ohio Environmental Protection Agency
Office of Emergency Response
1800 Watermark Drive
Columbus OH 43215-1099
Phone: (614) 644-2260
Section(s): None

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              STATE EMERGENCY RESPONSE COMMISSIONS
                                                     PENNSYLVANIA
Ken Shultz or Jeff Seattle
Ohio Emergency Response Commission
Ohio Environmental Protection Agency
Office of Emergency Response
1800 Watermark Drive
Columbus OH 43215-1099
Phone: (614) 644-2081 Shultz or Beattie
Section(s): 302 304 311312
                                                      Lt. Governor Mark S. Schweiker, Chairman
                                                      Pennsylvania Emergency Management Council
                                                      P.O. Box 3321
                                                      Harrisburg PA 17105-3321
                                                      Phone: (717) 783-8150
                                                      Section(s):  None
Cindy Dewulf
Ohio EPA
Division of Air Pollution Control
1800 Watermark Drive
Columbus OH 43216
Phone:  (614) 644-3606
Section(s):  313

OKLAHOMA

Monty Elder
Department of Environmental Quality
Support Services
1000 North East Tenth Street
Oklahoma  City OK 73117-1212
Phone:  (405) 271-1400
Section(s):  302311312313

Lynne Moss
Department of Environmental Quality
1000 N.E. 10th Street
Oklahoma  City OK 73117-1212
Phone: (405) 271-8056
Section(s):  304

OREGON

Martha  Pagel, Chair
Oregon Emergency Response Commission
c/o State Fire Marshall
4760 Portland Road, NE
Salem OR 97305-1760
Phone: (503) 378-3473 Ext. 347
Section(s): None

Bob Albers
Oregon Emergency Response Commission
c/o State Fire Marshall
4760 Portland Road, NE
Salem OR 97305-1760
Phone: (503) 378-3473 Ext. 262
Section(s): 302304311312313
                                                     Robert F. Broyles, Chief
                                                     Chemical Emergency Preparedness Division
                                                     Pennsylvania Emergency Management Agency
                                                     P.O. Box 3321
                                                     Harrisburg PA 17105-3321
                                                     Phone:  (717) 783-8150
                                                     Section(s):  302304


                                                     James Tinney or Lynn Snead
                                                     Pennsylvania Emergency Management Council
                                                     Bureau of Worker and Community Right-to-Know
                                                     Room 1503
                                                     Labor and Industry Building
                                                     7th and Forster Streets
                                                     Harrisburg PA 17120
                                                     Phone:  (717) 783-2071
                                                     Section(s):  311312313

                                                     PUERTO RICO

                                                     Hector Russe Martinez, Chairman
                                                     Puerto Rico Emergency Response Commission
                                                     Environmental Quality Board
                                                     P.O.Box 11488
                                                     Santurce PR 00910
                                                     Phone: (809) 767-8056
                                                     Section(s):  None

                                                     Genaro Torres
                                                     Director of Superfund and Emergency Division
                                                     Title III - SARA Section 313
                                                     Puerto Rico Environmental Quality Board
                                                     Sernades Junco Station
                                                     P.O.Box 11488
                                                     Santurce PR 00910
                                                     Phone: (809) 766-8056
                                                     Section(s):  302304311312313

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             STATE EMERGENCY RESPONSE COMMISSIONS
RHODE ISLAND

Joseph Camevale Jr., Director
Rhode Island Emergency Response Commission
State House Room 27
Providence RI 02903
Phone: (401) 277-3039
Section(s):  None
Michael Juras
South Carolina State Emergency Response Commission
EPCRA Reporting Point
SC Department of Health and Environmental Control
2600 Bull Street
Columbia SC 29201
Phone: (803) 896-4117
Section(s): 304313
JohnAucott
Rhode Island Emergency Response Commission
State House Room 27
Providence RI 02903
Phone: (401)421-7333
Section(s): 302304

Patrice Carvaretta
Rhode Island Department of Labor
Division of Occupational Safety
610 Manton Avenue
Providence RI 02909
Phone: (401) 457-1829
Section(s): 311312

Martha Delaney Mulcahey
Rhode Island Department of Environmental
Management
Division of Air Resources
291 Promenade Street
Attn: Toxic Release Inventory
Providence RI 02908-5767
Phone: (401) 277-2808
Scction(s): 313

SOUTH CAROLINA

Stan M. McKinney, Chairman
South Carolina Emergency Response Commission
c/o Emergency Preparedness Division
1429  Senate Street
Columbia SC 29201
 Phone: (803) 734-8020
 Section(s): 302
Peter Saussy
South Carolina State Emergency Response Commission
South Carolina Department of Health and
Environmental Control
2600 Bull Street
Columbia SC 29201
Phone: (803) 896-4116
Section(s):  302311312

SOUTH DAKOTA

Lee Ann Smith, Title III Coordinator
South Dakota Emergency Response Commission
South Dakota Dept. of Environment and Natural
Resources
Joe Foss Building
523 East Capitol
Pierre SD 57501-3181
Phone: (605) 773-3296
Section(s):  302304311312313

TENNESSEE

John White, Chairman
Tennessee Emergency Response Commission
Tennessee Emergency Management Agency
3041 Sidco Drive
Nashville TN 37204
Phone: (615) 741-0001
 Section(s):  None


 Betty Eaves, Director
 Tennessee Emergency Management Agency
 3041 Sidco Drive
 Nashville TN 37204
 Phone: (615) 741-2986
 Section(s): 302304311312313

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 TEXAS
STATE EMERGENCY RESPONSE COMMISSIONS
                                       UTAH
 James Wilson, Director
 Texas Emergency Response Commission
 Texas Department of Public Safety
 P.O. Box 4087
 Austin TX 78773-0001
 Phone: (512) 465-2138
 Section(s): None
                                       Lorayne Frank, Director
                                       Comprehensive Emergency Management Agency
                                       State Office Building
                                       Room 1110
                                       Salt Lake City UT 84114
                                       Phone: (801) 538-3400
                                       Section(s):  None
 Paula McKinney
 Texas Department of Health
 Hazard Communication Branch
 1100 West 49th Street
 Austin TX 78756
 Phone: In State: (800) 452-2791
       Out of State: (512) 834-6603.
 Section(s): 302311312

 David Barker
 Emergency Response Team'
 Texas Natural Resource Conservation Commission
 Room 241
 P.O. Box 13087
 Austin TX 78711
 Phone: (512) 463-7727
 Section(s): 304

 David James, TRI Coordinator
 Office of Pollution Prevention and Recycling
 Texas Natural Resources Conservation Commission
 P.O. Box 13087 (MC112)
 12015 Park, 35 Circle Building F
 Austin TX 78711-3087
 Phone: (512) 239-3184
 Section(s): 313

 Tom Millwee, Co-Chair
 Texas Emergency Response Commission
Division of Emergency Management
P.O. Box 4087
Austin TX 78773-0001
Phone: (512) 465-2138
 Section(s): None
                                       Neil Taylor
                                       Comprehensive Emergency Management
                                       State Office Building
                                       Room 1110
                                       Salt Lake City UT 84114
                                       Phone: (801) 536-4400
                                       Section(s):  302304

                                       John Jones
                                       UT Hazardous Chemical Emergency Response Comm.
                                       Utah Department of Environmental Quality
                                       Div. of Environmental Response & Remediation
                                       P.O. Box 14484
                                       168 North 1950 West, 1st Floor
                                       Salt Lake City UT 84114-4840
                                       Phone: (801) 536-4100

                                       Section(s): 311312313

                                       VERMONT

                                       Captain Robert Yandow, Chairman
                                       Vermont Emergency Response Commission
                                       Essex Police Department
                                       81 Main Street
                                       Essex Junction VT 05452
                                       Phone: (802) 878-8331
                                       Section(s): None

                                       George Lowe, Secretary of the SERC Board
                                       Department of Public Safety
                                       103 South Main Street
                                       Waterbury VT 05676
                                       Phone: (802) 244-8721
                                       Section(s): 304

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             STATE EMERGENCY RESPONSE COMMISSIONS
Ray McCandless
Vermont State Health Department
108 Cherry Street
P.O. Box 70
Burlington VT 05402
Phone: (802) 865-7730
Sections): 302311312
Cathy Harris
Virginia Emergency Response Council
c/o Virginia Department of Environmental Quality
P.O. Box 10009
Richmond VA 23240-0009
Phone: (804) 698-4480 or 4489
Section(s): 302304311312313
Gary Gulka
Pollution Prevention Section
103 S. Main Street
Westbury VT 05671-0411
Phone: (802) 241-3626
Section(s): 313

VIRGIN ISLANDS

Roy E. Adams, Commissioner
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response Comm. Title
III
Nisky Center
Suite 231
St. Thomas VI 00802
Phone: (809) 774-3320 Ext. 101 or Ext. 102
Scction(s): None


Ben Nazario
Department of Planning and Natural Resources
U.S. Virgin Islands Emergency Response Comm. Title
III
Nisky Center, Suite 231
St. Thomas VI 00802
Phone: St. Croix: (809) 773-0565
       St. Thomas: (809) 774-3320
Sections):  302304311312313

VIRGINIA

Addison Slayton, Jr., Chair
Vkginia Emergency Response Commission
Virginia Department of Emergency Services
310 Turner Road
Richmond VA 23225
Phone:
Section(s):  None
WASHINGTON

Mike Fitzgerald, Chair
Washington Emergency Response Commission
Department of Community Development
906 Columbia Street SW
P.O. Box 48300
Olympia WA 98504-8300
Phone: (360) 753-7426
Section(s): None


Idell Hansen, Supervisor
Department of Ecology
Community Right-to-Know Unit
P.O. Box 47659
Olympia WA 98504-7659
Phone: (360) 407-6727
Section(s): 302 311312 313


Betty Lochner
Washington State Emergency Management Agency
P.O. Box 48346
Olympia WA 98504-8346
Phone: (360) 923-4973
Section(s): 304


WEST VIRGINIA

Carl L. Bradford, Director
West Virginia Emergency Response Commission
West Virginia Office of Emergency Services
Main Capitol Building 1
Room EB-80
Charleston WV 25305-0360
Phone: (304) 558-5380
Section(s):  302 304 311312 313

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              STATE EMERGENCY RESPONSE COMMISSIONS

WISCONSIN

Leroy Conner, Chair
State Emergency Response Board
Division of Emergency Government
P.O. Box 7865
2400 Wright Street
Madison WI 53707-7865
Phone: (608) 242-3232
Section(s): None

William Clare
State Emergency Response Board
2400 Wright Street
Madison WI 53707-7865
Phone: (608) 242-3232
Section(s): 302304311312


Russ Dunst, Toxics Coordinator
Department of Natural Resources
101 South Webster
P.O. Box 7921
Madison WI 53707
Phone: (608) 266-9255
Section(s): 313

WYOMING

Guy Cameron, Chair
Cheyenne Fire Department
1806 East 19th Street
Cheyenne WY 82003
Phone:
Section(s): None

Mike Davis/Bob Beck
Wyoming Emergency Response Commission
Wyoming Emergency Management Agency
Department of Environmental Quality
P.O. Box 1709
5500 Bishop Blvd.
Cheyenne WY 82009
Phone: (307) 777-4900
Section(s): 302304311312313

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                            NPDES STATE DIRECTORS
Mr. Charles Horn, Chief
Water Division
AL Dept. of Environmental Mgmt.
1751 Congressman Dickenson Dr.
Montgomery, AL 36130
(205)271-7950
 Mr. Robert Smith, Chief
 Water Mgmt. Bureau
 CT Dept. of Environmental Protection
 79 Elm Street
 Hartford, CT 06106-5127
 (203)424-3017
Ms. Deena Henkins, Chief
Water & Wastewater Treatment Section
AK Dept. of Environmental Conservation
410WiUoughbyAve.
Juneau, AK 99801
(907) 465-5300
Mr. Brian Munson, Assistant Director
Water Quality
AR Dept. of Environmental Quality
3033 N. Central Ave.
Phoenix, AZ 85012-2810
(602) 207-2384
Mr. Chuck Bennet, Chief
Water Division
AR Dept. of Pollution Control & Ecology
8001 National Drive
Little Rock, AR 72219-8913
(501)570-2114
Ms. Sarah Cooksey, Administrator
Delaware Coastal Mgmt.
DE Dept. of Natural Resources
Div. of Environmental Control
89 Kings Hwy, PO Box 1401
Dover, DE 19903
(302)739-3451

Mr. Richard Drew, Chief
Division of Water Facilities
Bureau of Water Facilities
 Planning and Regulation
FL Dept. of Environmental Protection
2600 Blairstone Rd.
Tallahassee, FL  32399-2400
(904) 487-0563

Mr. Alan Hallum, Chief
Water Protection Branch
GA Dept. of Natural Resources
205 Butler Street, Suite 1058
Atlanta, GA 30334
(404) 656-4708
Mr. John Youngerman, Director
Division of Water Quality
CA State Water Resources Quality Control Board
P.O. Box 100
901 P Street
Sacramento, CA 95814
(916)657-1013

Mr David Holm, Director
Water Quality Control Div.
CO Dept. of Public Health & Environment
WQCD-DO-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
(303) 692-3508
Mr. Dennis Lau, Chief
Clean Water Branch
HA Dept. of Health   •
919 Ala Moana Blvd., Rm. 301
Honolulu, ffl 96814
(808) 586-4309
Mr. Orville Green, Asst. Administrator
Permits and Enforcement
ID Div. of Environmental Quality
1410 N. Hilton - State House Mall
Boise, ID 83706
(208) 334-5898

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Mr. Tom McSwiggin, Manager
Permits Section
Bureau of Water
EL Environmental Protection Agency
P.O. Box 19276
2200 Churchill Road
Springfield, IL 62794-9276
(217)782-0610
Mr. Stephen Groves, Director
Bureau of Water Quality Control
ME Dept. of Environmental Protection
State House, Station #17
Augusta, ME 04333
(207)287-3901
Mr. Lonnie Brumfield, Chief
Permits Section
IN Dept. of Environmental Mgmt.
105 S. Meridian St, Rm. 719
Indianapolis, IN 46206-6015
(317)232-8705
Mr. Wayne Farrande
Environmental Protection Division
IA Dept of Natural Resources
Henry A. Wallace Bldg.
900 East Grand Ave.
DcsMoines,IA 50319-0034
(515)281-8877
 Mr. Karl Mueldener, Director
 Bureau of Water
 KS Dept. of Health & Environment
 Bldg. 740, Forbes Field
 Topeka,KS 66620
 (913) 296-5500
 Mr. Jack Wilson, Director
 Division of Water
 KY Dept. of Natural Resources
  and Environmental Protection Cabinet
 Fort Boone Plaza, 14 Reilly Rd.
 Frankfort, KY 40601
 (502) 564-3410
Mr. Jeff Rein, Administrator
Wastewater Discharge and Permit Program
Water Management Administration
MD Dept. of Environment
2500 Broening Hwy.
Baltimore, MD 21224
(410)631-3752

Mr. Brian Donahoe, Director
Division of Water Pollution Control
MA Dept. of Environmental Protection
One Winter St., 8th Floor
Boston, MA 02108
(617)292-5635
 Mr. Robert Miller, Chief
 Surface Water Quality Div.
 MI Dept. of Natural Resources
 P.O. Box 30273
 300 South Washington St.
 Lansing, MI 48933-7773
 (517)373-1949

 Ms. Patricia Burke, Manager
 Water Quality Division
 MN Pollution Control Agency
 520 Lafayette Road
 St. Paul, MN 55155
 (612)296-7202
 Mr. Dale Givens, Asst Secretary
 Office of Water Resources
 LA Dept of Environmental Quality
 P.O. Box 82215"
 Baton Rouge, LA 70884-2215
 (504) 765-0634
 Mr. Barry Royals, Chief
 Surface Water Division
 MS Dept. of Environmental Quality
 P.O. Box 10385-0389
 Jackson, MS 39289-0385
 (601)961-5102
                                                                                NPDES State Directors

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 Mr. Daniel Schuette, Chief
 Permits Section
 Water Pollution Control Program
 MO Dept. of Natural Resources
 P.O. Box 176
 205 Jefferson Street
 Jefferson City, MO 65102
 (314)751-6825
 .Mr. Dennis Hart, Administrator
 Environmental Regulations
 Division of Water Quality
 NJ Dept. of Environmental Protection & Energy
 CN029,401E. State St.
 Trenton, NJ 08625-0029
 (609) 292-4543
 Mr. Stephen Pilcher, Acting Administrator
 Water Quality Division
 MT Dept. of Health & Environmental Sciences
 P.O. Box 200901
 Helena, MT 59620-0901
 (406) 446-2406
 Ms. Kathleen Sisneros, Director
 Water & Waste Mgmt. Division
 MM Environment Dept.
 P.O. Box 26110
 SanteFe,NM 87502 ,
 (505) 827-2855
Mr. U. Gale Hutton, Asst. Director
Water Quality Division
NE Dept. of Environmental Control
Suite 400, The Atrium
P.O. Box 98922
Lincoln, NE 68509
(402)471-2909
 Mr. N.G. Kaul, Director
 Division of Water
 NY Dept. of Environmental Conservation
 50 Wolf Rd., Rm. 306
 Albany, NY  12233-3500
 (518)457-6674
Mr. Wendell McCuny, Bureau Chief
Water Quality Planning
NV Div. of Environmental Protection
333 W. Nye Lane, Capital Complex
Carson City, NV 89710
(702) 687-4670
Mr. Raymond Carter
Administrator for Water Quality
Water Supply & Pollution Control Div.
NH Dept. of Environmental Services
6 Hazen Drive
Concord, NH 03301
(603) 271-3503
Mr. Steve Tedder, Chief
Water Quality Section
Division of Environmental Mgmt.
NC Dept. of Environment, Health & Natural
Resources
P.O. Box 29535
Raleigh, NC 27626-0535
(919)733-5083
Mr. Francis J. Schwindt, Chief
Environmental Health Section
ND Dept. of Health
P.O. Box 5520
Bismarck, ND 58502-5520
(701)221-5150 .
                                                                             NPDES State Directors

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"Mr, Paul Novack, Manager
 Pcnnits Section
 Division of Surface Water
 OH Environmental Protection Agency
 1800 Watermark Drive
 Columbus, OH 43216-3669
 (614) 644-2035
 Mr. John Craig, Director
 Water Quality Division
 OK Dept of Environmental Quality
 1000 N.E. 10th Street
 Oklahoma City, OK 73117-1212
 (405) 271-5205
Mr. Kent Woodmansey
Point Source Program
SD Dept. of Environment & Natural Resources
Joe Foss Bldg., 523 E. Capitol
Pierre, SD  57501-3181
(605)773-3151?
Mr. Paul Davis, Director
Div. of Water Pollution Control
TN Dept. of Environment & Conservation
401 Church St.
LC Annex, 6th Floor
Nashville, TN 37243-1534
(615) 532-0625
 Mr. Michael Downs, Administrator
 Water Quality Division
 OR Dept of Environmental Quality
 811SW6thAve.
 Portland, OR  97204-1390
 (503) 229-5324
 Mr. Stuart Gansell
 Div. of Permits & Compliance
 Bureau of Water Quality Mgmt
 PA Dept of Environmental Resources
 P.O. Box 8465
 400 Market Street
 Harrisburg,PA  17105-8465  ,
 (717)787-2666
Mr. Warren Davis, Director
Watershed Mgmt. Division
TX Natural Resource Conservation Commission
PO Box 13087
Austin, TX 78711-3087
(512)239-4400
 Mr. Don Ostler, Director
 Division of Water Quality
 UT Dept. of Environmental Quality
 PO Box 144870
 288 North, 1460 West
 Salt Lake City, UT  84116-4870
 (801)538-6146
  Mr. Edward S. Symanski, Associate Director
  Water Quality Management
  RI Dept. of Environmental Mgmt.
  291 Promenade St.
  Providence,'RI  02908-5767
  (401)277-3961
 Mr. Gary Schultz, Director
 Wastewater Mgmt. Division
 VT Dept. of Environmental Conservation
 103 S. Maine St., Annex Office Bldg.
 Waterbury.VT 05671
 (802)241-3822
  Mr. Russell Sherer, Chief
  Bureau of Water Pollution Control
  SC Dept of Health and Environmental Control
  2600 Bull Street
  Columbia, SC 29201
  (803) 734-5296
 Mr. Robert Burnley, Director
 Water Division
 VA Department of Environmental Quality
 P.O. Box 10009
 Richmond, VA 23240-0009
 (804) 786-8750
                                                                            NPDES State Directors

-------
 Mr. Mike Llewelyn, Manager
 Water Quality Program
 WADept. of Ecology
 P.O. Box 47600
 Olympia, WA 98504-7600
 (206) 407-6405
Mr. Lyle Bennett, Chief
Division of Water Resources
WV Dept. of Natural Resources
1201GreenbrierSt.
Charleston, WV 25311
(304)558-2108
Ms. Mary Jo Kopecky, Director
Wastewater Management Bureau
WI Dept. of Natural Resources
PO Box 7921
Madison, WI 53707
(608) 266-3910
Mr. William Garland, Administrator,
Water Quality Division
WY Dept of Environmental Quality
122 West 25th Street
Herschler Bldg., 4th Floor West
Cheyenne, WY 82002
(307)777-7781
 James A. Collier, Program Manager
 Water Resources Management
 Div. Housing and Environmental
  Regulations Administration
 Water Hygiene Branch, Suite 203
 2100 Martin Luther King, Jr. Ave., SE
 Washington, D.C. 20020
 (202)404-1120
 Fred M. Castro, Administrator
 Environmental Protection Agency
 IT&E Harmon Plaza, Complex Unit D-107
 130 Rojas Street
 Harmon, GUAM  96911
 011-671-646-8863
Pedro A. Maldonado-Ojeda, Esq.
Chairman
PR Environmental Quality Board
P.O. Box 11488
San Juan, PR 00910
(809) 767-8056
Marc Pacifico
Territorial Pollution Division
Div. of Environmental Protection
VI Dept. of Planning and Natural Resources
UlSWatergutHomes
Christiansted, St, Croiz, VI 00820-5065
(809) 773-0565
                                                                           NPDES State Directors

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                      STORM WATER
                    LIST OF CONTACTS
                          March 1995
•

-------

-------
;-«*"CONTACT.LST
                           EPA Headquarters
                           Address        VS. Eorirwimental Protection Agency
                                          Office of Water Permits Division, MC-4203
                                          401 M Street, SW
                                          Washington, DC 20460
                           Fax            (202) 260-9544
Name
Pwwto Dtrkion
Nancy Cunningham
Bwtofat
Km Hankms '
Environmental Specialist
BillSwiedik
Chief. Storm Water Section
Permits Division
BillTate
Environmental Engineer
Betty West
Program Analyst
Carmelita White
Program Analyst
Address

Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
Office of Water Permits Division, MC-4203
401 M Street, SW
Washington, DC 20460
Office of Water Permits Division, MC-4203
401 M Street, SW '
Washington, DC 20460
Telephone
Internet

202-260-9535
202-260-8328
202-260-9529
202-260-6963
202-260-8486
202-260-6053
Cunningham .Nancy
@ EPAMAIL.EPA.GOV
Hankins.Kimberly
@ EPAMAIL.EPA.GOV
Swietlik. William
@ EPAMAIL.EPA.GOV
Tate. William
@ EPAMABL.EPA.GOV
We«.Beny
@ EPAMAIL.EPA.GOV
White Ctrmeiita
@ EPAMATL.EPA.GOV
Office of General Counsel
Stephen Sweeney
, Attorney
Municipal Support Division
Bob Lee
Chief, Municipal Technical
Branch
Jim Wheeler
Environmental Engineer
Municipal Technical Branch
Joe Mauro
Environmental Engineer
Municipal Technical Branch
U.S. Environmental Protection Agency
Office of General Council, MC-2355
• 401 M Street, SW
Washington, DC 20460

U.S. Environmental Protection Agency
Office of Municipal Support, MC-7406
401 M Street, SW
Washington, DC 20460
U.S. Environmental Protection Agency
Office of Municipal Support, MC-4204
401 M Street, SW
Washington, DC 20460
U.S. Environmental Protection Agency
Office of Municipal Support, MC-4204
401 M Street, SW
Washington, DC 20460
202-260-8739

202-260-9412
202-260-7356
202-260-7356
Swececy Steve
@ EPAMAO- EJ»A GOV




                                                                                                              1 of 20

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BJDCVKWmP/CONTACTLST
Office of Research and
Development (
Rfchttd Field
Dan Murray
National Risk Management Research
Storm and Combined Sewer Pxogram Laboratory
2890 Woodbridge Avenue
Edison, NJ 08837-3679
National Risk Management Research Laboratory
Center for Environmental Research Information
26 W. Martin Luther King Drive (G-75)
Cincinnati, OH 45268
908-321-6674
513-569-7522
FAX 513-569-7585

Murray. Dan
@ EPAMAIL.EPA.GOV
                                                                                                                   : or 20

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                                   EPA Region I
                                   Address
                                  Fax
        U.S.  EPA - Region I
        JFK  Federal Building
        Boston, MA 02203
        617-565-4940
Name
Clyde Stafefc
Jiy Brota
Shefly Pttteo
Oifa Vergara
Title
Chief
Special Permits
Environmental Engineer
Environmental Protection Specialist
Environmental Protection Specialist
Telephone
617-565-3580
617-565-3590
617-565-3525
617-565-3525
Mail Stop
WMS
WMS
WCP
WCP
                                                        State Offices
                                                      in EPA Region I
             Name and Title
                           Address
                                                                                                             Telephone
Chris Stone
Storm Water Coordinator
Connecticut Department of Environmental Protection
Water Management Bureau
79 Elm Street
Hartford, CT 06106-5127
203-424-3018
FAX 203-566-8650
Norm Marcotte
Nonpoint Program Coordinator
Maine Department of Environmental Protection
Division of Environmental Evaluation
State House, Station #17
Augusta, ME 04333
207-287-3901
FAX 207-287-7826
Paul Hogan
NPDES Coordinator
Massachusetts Department of Environmental Protection
Office of Watershed
40 Institute Road
P.O. Box 116
N. Grafton, MA 01536
508-792-7470
FAX 508-839-3469
Jeff Andrews
Supervisor, Industrial Permits Section
New Hampshire Department of Environmental Services
6 Hazen Drive
Concord, NH 03301
603-271-2457
FAX 603-271-2867
Chris Feeney
Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277-6519
FAX 401-521-4230
Angelo Liberti
Supervising Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277-4519
FAX401-52M230
Kim Wiegand
Sanitary Engineer
Rhode Island Department of Environmental Management
Division of Water Resources
291 Promenade Street
Providence, RI 02908
401-277 -6519e«.
7233
FAX401-52M230
                                                                                                                     3 of 20

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             Name and Title
Brian Koiker
Chief Director, Permits Section
                                                                    Address
Environmental Conservation
Wastewater Management Division
Sewing Building
103 S. Main Street
Waterbury, VT  05671-0405
                                                                   Telephone
802-241-3822
FAX 802-244-5141
Gary Schultz
Director, Wastewater Management Division
Environmental Conservation
Wastewater Management Division
Sewing Building
103 S. Main Street
Waterbury, VT  05671-0405
802-241-3822
FAX 802-244-5141
                                                                                                                       4 of 20

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      ~\ T^CONTACT.LST
                                 EPA Region O
                                 Address
                                Fax
          U.S. EPA . Ration II
          Water "tnaks aod Compliance Branch
          290 Bnatfway
          New York. NY  10007-1866
          212-264-9997
               Name
                                                           Tftk
                                                                                                 Telephone
                                     Storm Water Regional Coordinator
                                                  212-264-8681
Joat A. Rivera
Senior Environment!] Engineer
Caribbean Field Office
Central Europa Building. Suite 417
1492 Ponce deLeon Avenue
Santurce, PR 00907
                                                                                       809-729-6951
                                                                                       FAX 809-729-7747
                                                     State Offices
                                                   fa EPA Region II
Name and Title
Barry Chaiofsky
Manager, Bureau of Storm Water
1 Permitting
1 Ed Frankel
1 Section Chief
Janet Jessel
Brian McLendon
Supervisors
General Information
N.G. Kaul
Director, Division of Water
Ken Stevens
Chief, Stormwater Management Section
Wanda Garcia-Hernandez
Chief, Permits and Engineering Division
Carlos Irizarry
_ Director, Water Quality Control Bureau
Address
New Jersey Department of Environmental Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton, NJ 08625
New Jersey Department of Environmental Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton. NJ 08625
New Jersey Department of Environmental Protection (CN-423)
Division of Water Quality
401 E. State Street
Trenton, NJ 08625
New Jersey Department of Environmental Protection
(CN-243) Division of Water Quality
401 E. State Street
Trenton, NJ 08625
New York State Department of Environmental Conservation
50 Wolf Road
Albany, NY 12233-3505
New York State Department of Environmental Conservation
Bureau of Water Quality Management
50 Wolf Road
Albany, NY 12233-3508
Puerto Rico Environmental Quality Board
431 Ponce de Leon Avenue
5th Floor, Office 527
P.O. Box 1 1488
Hato Rey, PR 00910
Puerto Rico Environmental Quality Board
431 Ponce de Leon Avenue
5th Floor, Office 527
P.O. Box 11488
Hato Rey, PR 00910
Telephone
609-633-7026
FAX 609-984-2147
609-633-7026
FAX 609-984-2147
609-633-7026
FAX 609-984-2147
609-633-7026
FAX 609-9*4-2147
518-457-6674
FAX 51M15-7786
518-457-3656
FAX 31l-41S-r7g6
809-767-1731
FAX W9-767-1962
809-767-4mi
FAX I09-?«?.i962
                                                                                                               f rf 20

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B/DCV833/I73P;CONTACT!LST
Name and Title
Jeff Miller
Environmental Specialist.nl
Address
Virgin Islands Planning and Natural Resources
Division of Environmental Protection
1118 Watergut Homes, Christiansted
St. Croix, VI 00820-5065
Telephone j
809-773-0565 I
FAX 809-773-9310
                                                                                                                               f

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                     TACT.LST
                                         EPA Region III
                                         Address        U.S.  EPA - Region III
                                                        841 Chestnut Building
                                                        Philadelphia, PA  191<)7
                                         Fax            215-597-8541/215-597-8241/215-597-3359
Name
U»feMftw
.-" • «"*y
Title
Storm Water Coordinator
Environmental Engineer
Telephone
215-597-0547
215-597-6465
Mail Stop
(3WM54)
(3WM53)
                                                              State Offices
                                                            in EPA Region III
                   Name and Title
                                                       Address
                                                                                                                   Telephone
                    Engineer
                             Delaware Department of Natural Resources and Environmental
                              Control
                             Division of Water Resources/Pollution Control Branch
                             89 Kings Highway
                             Dover, DE  19903
                                                               302-739-5731
                                                               FAX 302-739-3491
^^Bk Preffl
^^V  MM
^W——
 ;er for Water Resource
Division
       BTMM Qtreager
       Ctetf. Program Review Division
       Edwmrd Center
       Chief, Industrial Permits Division
DC Department of Consumer and Regulatory Affairs
2100 Martin Luther King, Jr. Avenue S.E.
Washington, DC  20020
                             Maryland Department of the Environment
                             2500 Broening Highway
                             Baltimore, MD  21224
                            Maryland Department of the Environment
                            2500 Broening Highway
                            Baltimore, MD  21224
202-404-1120,
 Ext.3040
FAX 202-404-1141
                                                              410-631-3543
                                                              FAX 410-631^883
                                                              410-631-3323
                                                              FAX 41CM531-4883
       Stu Gansell
       Chief of Permits and Compliance
                            Pennsylvania Department of Environmental Resources
                            400 Market Street State Office Building, 10th Floor
                            Harrisburg, PA 17101-2702
                                                              717-787-3481
                                                              FAX 717-787-2802
       R.B. Puel
       Chief of Permits Section/
        Sanitary Engineer IV
                             Pennsylvania Department of Environmental Resources - BWQM
                             Division of Permits and Compliance
                             400 Market Street State Office Building, 10th Floor
                             P.O. Box 8465
                             Harrisburg, PA 17105-8465
                                                              717-787-8184
                                                              FAX 717-772-5156
       Mr. Vu
       Sanitary Engineer
                             Pennsylvania Department of Environmental Resources - BWQM
                             Division of Permits and Compliance
                             400 Market Street State Office Building, 10th Floor
                             P.O. Box 8465
                             Harrisburg, PA  17105-8465
                                                              717-787-8184
                                                              FAX 717-772-5156
       Burton Tuxford
       Environmental Engineer
                             Virginia Department of Environmental
                             4900 Cox Road
                             P.O. Box  11143
                             Glen Allen, VA  23060
                                                              804-527-50«3
                                                              FAX KX-S27-5293
                                                                                                                             of 20

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MDIYWM73PK:ONTACT 1ST
              Name and Title
 Cathy Boatwright
 Stonn Water Program Manager
                          Address
Virginia Department of Environmental Quality
4900 Cox Road •
P.O.Box 11143
Glen Allen, VA 23060
    Telephone
804-527-5316
FAX 804-527-5293
 Jim Mason
 Engineer, Storm Water Coordinator
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston. WV  25311
304-558-8S55
FAX 304-348-5905
  Jerry Ray
  Assistant Chief, Permits
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston, WV 25311
304-558-0375.
FAX 304-348-5905
  Arthur A. Vickers
  Engineer, Storm Water Coordinator
West Virginia Office of Water Resources
Division of Environmental Protection
1201 Greenbrier Street
Charleston, WV  25311
304-558-8855
FAX 304-348-5905
                                                                                                                        8 of 20

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       ; -W»CONTACT.LST
                                 EPA Region l\
                                 Address       U.S. EPA - Region IV
                                                345 Courttand Street, NE
                                                Atlanta, GA  30365
                                 Fax           404-347-1739
Name
ECM«
-------
B»DIV833/173P(CONTACT LST
              Name and Title
 Jeff Larson
 Program Manager
                           Address
 Georgia Department of Natural Resources
 Environmental Protection Division - Municipal
 4244 International Parkway, Suite 110
 Atlanta, GA  30354
                                                                                                               Telephone
 404-362-2680
 FAX 404-362-2654
 Lawrence W. Hedges
 Program Manager
Georgia Department of Natural Resources
Environmental Protection Division - Industrial
205 Butler Street, SE, Suite 1070
Atlanta, GA,30334
 404-656-4887
 FAX 404-657-7379  \
 Will Salter
 Environmental Specialist
Georgia Department of Natural Resources
Environmental Protection Division - Industrial
205 Butler Street, SE, Suite 1070
Atlanta, GA 30334
404-656-4887
FAX 404-657-7379
 Douglas Allgeier
 Industrial Section Supervisor
Department of Environmental Protection
Kentucky Division of Water
14 Reilly Road
Frankfort, KY 40601
502-564-3410
FAX 502-564-4245
 JeffHippe
 Permit Writer
Department of Environmental Protection
Kentucky Division of Water
.14 Reilly Road
Frankfort, KY 40601
502-564-3410
FAX 502-5644245
 Herb Ray
 Environmental Engineer (Municipalities)
Department of Environmental Protection
Kentucky Division of Water
14 Reilly Road
Frankfort, KY 40601
502-564-3410
FAX 502-564-4245
 Jerry Cain
 Chief, Industrial Wastewater Branch
Mississippi Department of Environmental Quality
Office of Pollution Control
Industrial Wastewater Branch
P.O. Box 10385
Jackson, MS  39289-0385
601-961-5073
FAX 601-961-5703
 Louis Lavallee
 Chief, Storm Water Section
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson, MS  39289-0385
601-961-5074
FAX 601-461-5703
 Kenneth LaFIeur
 Assistant, Storm Water Section
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson. MS  39289-0385
60I-MI-SI42
FAX «OI-4*1-5703
 Hameh Salem
 Environmental Engineer
Mississippi Department of Environmental Quality
Office of Pollution Control
P.O. Box 10385
Jackson. MS  39289-0385
6014*1 S234
FAX «OH»I-5703
 Bradley Bennett
 Environmental Engineer
North Carolina Division of Environmental Management
512 N. Salisbury Street
P.O. Box 29535
Raleigh, NC  27626-0535
                                                                                                          FAX
 BUI Mills
 Environmental Engineer
North Carolina Department of Environment. Health and Natural
  Resources
512 N. Salisbury Street
P.O.- Box 29535
Raleigh, NC  27626-0535
  Em H§
PAX •t*-nM9(9

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              !1*CONTACT.LST
                   Name and Title
                    Engineer Associate
                                                                        Address
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia, SC 29201
                                                                                                              Telephone
803-734-5300
FAX-803-734-5216
               •

Internet
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        K. Rot Hdbrook, PE
        Storm Waaer Section Manager
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia, SC  29201
803-734-9251  .
FAX 803-734-5216

Internet
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       Harvey Daniel
       Environmental Quality Manager
4
South Carolina Department of Health and Environmental Control
Bureau of Water Pollution
2600 Bull Street
Columbia, SC  29201
803-734-9250
FAX 803-734-5216

Internet
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       Robert Haley, m
       Environmental Engineer
Tennessee Water Pollution Control
L&C Annex, 6th Floor
401 Church Street
Nashville, TN  37243-1534
615-532-0625
FAX 615-532-0614
                                                                                                                     II «f 20

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!"W«CONTACT,LST
                          EPA Region V
                          Address
                          Fax
U.S. EPA - Region V
77 W. Jackson Blvd.
Mail Code WQP16J
Chicago, IL 60604
312-886-7804
Name
Fdtf SwMAOtl
Sarre^Mw
Title
Environmental Engineer
Environmental Scientist
Telephone
312-886-0236
312-886-2446
Mail Stop
WQP-16J
WQP-16J
                                              State Offices
                                            in EPA Region V
Name and Title
Gutter Wells
Stoon Waier Management
Laura Biebcrich
Storm Water Coordinator
Gary Boersen
Chief, Storm Water Permits Unit
Dave Drullinger
Environmental Quality Analyst .
Gene Soderbeck
Engineer/Supervisor
Dan Sullivan
Staff Engineer/Storm Water Coordinator
John Morrison
Supervisor, Storm Water Unh
Robert Phelps
Storm Water Coordinator
*
Jim Helm
Storm Water Administrative Assistant
Address
Ufinois EPA
2200 Churchill Road
P.O.' Box 19276
Springfield, IL 62794-9276
Indiana Department of Environmental Management
100 N. Senate Avenue
P.O. Box 6015
Indianapolis, IN 46206-6015
Michigan Department of Natural Resources
Surface Water Quality Division
P.O. Box 30273
Lansing, MI 48909
Michigan Department of Natural Resources
Surface Water Quality Division
P.O. Box 30273
'Lansing. MI 48909
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-3898
Minnesota Pollution Control Agency
520 Lafayette Road
St. Paul, MN 55155-3898
Ohio EPA
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43216-1049
Ohio EPA, Water Pollution Control
1800 Watermark Drive
P.O. Box 1049
Columbus, OH 43216-1049
Wisconsin Department of Natural Resources
101 S. Webster
P.O. Box 7921
Madison, WI 53707
Telephone
217-782-0610 .
FAX 217-782-9891
317-233-6725
FAX 317-232-8406
517-373-1982
FAX 517-373-9958
517-335-4117
FAX 517-373-9958
612-296-8280
FAX 612-297-3683
612-296-7219
FAX 612-297-3683
614-644-2259
FAX 614-644-2329
614-644-2094
FAX 614-6*4-2329
608-266-2T*
FAX 60C-267.7664
                                                                                                   Fmg* 12 of 20

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EPA Region VI
Address       U.S. EPA • ttfion VI
              1445 Row Avenue, Suite 1200
              Dallas, TX 7S202-2733
Fax
Name
"»—"**•*
Bum Lance
Mo«ca Bwrell
Aatnt Laneo
Dorodiy Crawford
Title
Environmental Scientist
Municipal Permits Section
Environmental Scientist
Municipal -Permits Section
Environmental Engineer
Municipal Permits Section
Enforcement Branch
Environmental Engineer
Municipal Permits Section
Telephone
214-665-7521
214-665-7523
214-665-7530
214-665-6454
214-665-7107
Mail Stop
(6W-PM)
(6W-PM)
(6W-PM)
(6W-ET)
' (6W-PM)
                    State Offices
                  in EPA Region VI
f Name and Title
Mark Bradley
Permits Section Chief
Tom Killeen
Program Manager
Kilren Virdine
Environmental Coordinator - Municipal
Anne Slater • '
Coordinator - General Permits
Darlene Bernard
Storm Water Coordinator
Glen Saums
Health Program Manager, Surface Water
Section
[
Address
Arkansas Department of Pollution Control and Ecology
8001 National Drive
P.O. Box 8913
Little Rock. AR 72219-8913
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge, LA 70884-2215
Louisiana Water Department of Environmental Quality
P.O. Box 82215
Baton Rouge', LA 70884-2215
Louisiana Water Department of Environmental Quality
7290 Bluebonnet Boulevard
P.O. Box 82215
Baton Rouge, LA 70810
New Mexico Health and Environment Department
Environmental Improvement Division
1190 St. Francis Drive
P.O. Box 261 10
Santa Fe, NM 87502
Telephone
501-562-7444
FAX 501-562-4632
504-765-0525
504-765-0534
FAX 504-765-0635
504-765-0525
504-765-0534
FAX 504-765-0635
504-765-0525
FAX 504-765-0635
504-765-0525
FAX 504-765-0635
505-827-2127
FAX 505-327-2836
                                                                         F»fe 13 of 20

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&DlVSMIt73P/CONTACT,LST
              Name and Title
 Rich Powell
 Environmental Scientist
                                                                    Address
New Mexico Environment Department
Surface Water Quality Bureau
1190 St. Francis Drive
P.O. Box26110
Santa Fe, NM  87502
                                                                  Telephone
505-827-2798
FAX 505-827-2836
 Brooks Kirlin
 Environmental Engineer
Oklahoma Department of Environmental Quality
Customer Assistance Program
1000 N.E. 10th Street
Oklahoma City, OK  73117-1212
405-271-1400
FAX 405-271-7339
  Dave Farrington
  Siorm Water Coordinator
Oklahoma Department of Environmental Quality
Water Quality Program
1000 N.E. 10th Street, WQS 0207
Oklahoma City, OK  73117-1212
405-271-7335
FAX 405-271-7339
  Thomas W. Weber
  Manager, Permitting Section
  Watershed Management Division
Texas Natural Resource Conservation Commission
1700 N. Congress Avenue
Steven F. Austin Building
P.O. Box 13087
Austin, TX 78711-3087
512^63-7748
FAX 512^63-6648
  Randall B. WUbum
  Director
  Water Planning and Assessment Division
Texas Natural Resource Conservation Commission
P.O. Box 13087
Austin, TX 78711-3087
512-239-5767
FAX 512-239-4444
                                                                                                                         24

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                                  EPA Region VII
                                  Address        U.S. EPA - Region VII
                                              -  726 Minnesota
                                                 Kansas City, KS 66101
                                  Fax            913-551-7765
                Name
                       Title
Telephone
                                         NPDES Permits Coordinator
                                                     913-551-7418
                                                       State Offices
                                                    in EPA Region VII
                  and Title
                           Address
     Telephone
            Coordinator
Iowa Department of Natural Resources
Environmental Protection Division
900 E. Grand Avenue
Des Moines, IA  50319-0034
 515-281-7017
 FAX 515-281-8895
             Engineer
Kansas Department of Health and Environment
Building 283 - Forbes Field
J Street and 2 North
Topeka, KS 66620
 913-296-5557
 FAX 913-296-5509
En >•!!••• mil Engineer
Kansas Department of Health and Environment
Building 283 - Forbes Field
J Street and 2 North
Topeka, KS 66620
 913-296-5556
 FAX 913-296-5509
Environmental Specialist
Missouri Department of Natural Resources
.205 Jefferson Street
P.O. Box 176
Jefferson City, MO  65102
 314-526-5630
 FAX 314-751-9396
Richard Laux
Permits Unit Chief
Missouri Department of Natural Resources
205 Jefferson Street
P.O. Box 176
Jefferson City, MO  65102
 314-751-6125
 FAX 314-751-9396
Ron Asch
NPDES Permit Writer
Nebraska Department of Environmental Quality
Suite 400
1200 N Street. The Atrium
P.O. Box 98922
Lincoln, NE  68509-8922
 402-471-4239
 FAX 402-471-2909
David Dirie
NPDES Permit Writer
 Nebraska Department of Environmental Quality
 Suite 400
 1200 N Street, The Atrium
 P.O. Box 98922
 Lincoln, NE  68509-8922
 402-471-4239
 FAX 402-471.2909
Clark Smith
Supervisor,'Permits and Compliance Section
 Nebraska Department of Environmental Qualify
 Suite 400
 1200 N Street, The Atrium
 P.O. Box 98922
 Lincoln, NE  68509-8922
 402-471 -«239
 FAX 403-471-2909
                                                                                                                    U«f 20

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                                 EPA Region VW
                                 Address        U.S. EPA - Region VIII
                                                999 18th Street, Suite 500
                                                Denver, CO  80202-2466
                                 Fax            303-294-1386
Name
mf^ _^^^ ^^MT»
Stem Waw Coordinator (8WM-C)
PMri MMfMKry
EsfwtWBMttl Engineer
Title
U.S. EPA - Region 8
999 18th Street, Suite 500
Denver, CO 80202-2466
U.S. EPA - Region 8
Montana Operations Office
Federal Building
301 South Park, Drawer 10096
Helena, MT 59626-0096
Telephone
303-293-1630
406-449-5486 '
Ext. 234
(Montana questions
only)
                                                      State Offices
                                                   in EPA Region
            Nime and Title
                          Address
KttfayDoUn
Environmental Scientist
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
Permits and Enforcement
4300 Cherry Creek Drive South
Denver, CO 80222-1530
303-692-3590
FAX 303-7«2-0390
Sarah Johnson
Storm Water Unit Leader
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
303-492-JSW
FAX X&.7S24390
•DtnBeley
Environmental Scientist
Colorado Department of Health and Environment
Water Quality Control Division
WQCD-PE-B2
4300 Cherry Creek Drive South
Denver, CO 80222-1530
FAX JO-TO-OWO
Fred Shewman
Supervisor of Permits
Montana Department of Health and Environmental Sciences
Water Quality Bureau
1400 Broadway
P.O. 200901
•Helena, MT 59620-0901
FAX
Roxann Lincoln
Storm Water Program Manager
Montana Department of Health and Environmental Sciences
Water Quality Bureau
1400 Broadway
P.O. Box 200901
Helena, MT 59620-0901
FAX
1174
                                                                                                                       20

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B/DIV833/173P/CONTACT.LST
              Name and Title
 Jim Collins
 Environmental Scientist/Storm Water
   Coordinator
                                                                      Address
                                                                                                               Telephone
North Dakota State Department of Health
Division of Water Quality
1200 Missouri Avenue
P.O.' Box 5520
Bismarck, ND 58506-5520
 701-328-5210
 FAX 701-328-5200
 Norma Job
 Natural Resources Engineer
South Dakota Department of Environment and Natural Resources
Point Source Control Program
Joe Foss Building
523 E. Capitol
Pierre, SD  57501-3181
800-737-8676
FAX 605-773-6035
 Harry Campbell
 Environmental Engineer/Storm Water
   Coordinator
Utah Department of Environmental Quality
Division of Water Quality
288 North 1460 West
P.O. Box 144870
Salt Lake City, UT  84114-4870
801-538-6146
FAX 801-538-6016
 John Wagner
 Technical Support Supervisor
Wyoming Department of Environmental Quality - Water
Herschler Building
122 West 25th Street
Cheyenne, WY  82002
307-777-7082
FAX 307-777-5973
 Marisa Latady
 Environmental Analyst
Wyoming Department of Environmental Quality - Water
Herschler Building
122 West 25th Street
Cheyenne, WY  82002
307-777-7588
FAX 307-777-5973
                                                                                                                        of 2C

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                                  EPA Region IX
                                  Address        U.S. EPA - Region IX
                                                 75 Hawthorne Street •
                                                 San Francisco, CA  94105
                                  Fax            415-744-1235 .
Name
Eufwe Bromley (W-5-1)
Titk
Stonn Water Coordinator
Telephone
415-744-1906
Mail Stop
(W-5-1)
                                                        State Offices
                                                     in EPA Region IX
            Name and Titk
                                                                     Address
                                                                   Telephone
Robot Wilson
S»onn Water Coordinator
Arizona Department of Environmental Quality
Water Permits Unit
3033 North Central Avenue
Phoenix, AZ  85012
602-207-4574
FAX 602-207-4674
Pivkm Viale
Senior Water Resources Control Engineer
John Short
Senior Engineer
California State Water Resources Quality Control Board
Santa Ana Regional Board
2010 Iowa Avenue, Suite 100'
Riverside, CA 92507-2409
California State Water Resources Qualify Control Board
Lahontan Regional Board
2092 Lake'Xahoe Boulevard
South Lake Tahoe, CA  96150
714-782-4130
FAX 714-781-6288
916-544-3481
FAX 916-544-2271
Adam White
Associate Water Resources Control
  Engineer
California State Water Resources Quality Control Board
Central Coast Regional Board
81 Higuera Street. Suite 200
San Luis Obispo, CA 93401-5247
805-549-3147
FAX 805-543-0397
Deborah Jayne
Environmental Specialist IV.
California Regional Water Quality Control Board
San Diego Regional Board
9771 Claremont Mason Boulevard, Suite B
San Diego, CA 92124-1331
619-467-2952
FAX 619-571-6972
Betsy Jennings
Senior Staff Counsel
California State Water Resources Quality Control Board
P.O. Box 100
Sacramento, CA  95812
916-657-2421
FAX 916-657-2388
 Orlando Gonzalez
 Associate Water Resources Control
  Engineer
California State Water Resources Quality Control Board
Colorado River Basin Regional Board
73-720 Fred Waring Drive, Suite 100
Palm Desert. CA  92260
619-776-«9«2
FAX 619-341-6820
 Archie Mathews
 Supervising Engineer
 California State Water Resources Quality "Control Board
 Central Valley Regional Board
 P.O. Box 944213
 Sacramento, CA 94244-2130
916-657-0323
FAX 916-657-238*
 Pamela Barksdale
 Associate Water Resources Control
  Engineer
 California State Water Resources Quality Control Board
 Central Valley Regional Board
 3443 Routier Road
 Sacramento. CA 95827-3098
 916-255-3024
 FAX 916-255-3015
                                                                                                                      IS of 20

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     B/DtV833/173P/CONTACT,LST
 ^n  Tomt»
                   Name and Title
Tom Mumley
Stonn Water Coordinator
                                                                    Address
California State Water Resources Quality Control Board
San Francisco Bay Regional Board
2101 Webster Street, Suite 500
Oakland, CA  94612
                                                                                                                   Telephone
                                                                                                                510-286-0962
                                                                                                                FAX 510-286-1380
       Bruce Fujimoto
       Chief of Stormwater Unit
                                          California State Water Resources Quality Control Board
                                          Division of Water Quality
                                          P.O. Box 944213
                                          Sacramento, CA  94244-2130
                                                               916-657-0908
                                                               FAX 916-657-1011
       Xavier Swamikannu
       Water Resources Control Engineer
                                          California State Water Resources Quality Control Board
                                          Los Angeles Regional Board
                                          101 Centre Plaza Drive
                                          Monterey Park, CA  91754-2156
                                                               213-266-7592
                                                               FAX 213-266-7600
       John Hannum
       Associate Water Resources Control
       Engineer
                                          California State Water Resources Quality Control Board
                                          North Coast Regional Board
                                          5550 Skyland Boulevard, Suite A
                                          Santa Rosa, CA 95403
                                                               707-576-2220
                                                               FAX 707-523-0135
       Ed Chan
       Supervisor - Engineering Section
                                          Hawaii Department of Health
                                          Clean Water Branch
                                          500 Ala Moana Boulevard
                                          5 Waterfront Plaza, Suite 250A
                                          Honolulu, HI  96813
                                                               808-586-4309   '
                                                               FAX 808-586-4370
       Alec Wong
4
                                          Hawaii Department of Health
                                          Clean Water Branch
                                          500 Ala Moana Boulevard
                                          5 Waterfront Plaza, Suite 250A
                                          Honolulu, HI  96813
                                                               808-586-4309
                                                               FAX 808-586-4370
       Denis R. Lau
       Chief
                                          Hawaii Department of Health
                                          Clean Water Branch
                                          500 Ala Moana Boulevard
                                          5 Waterfront Plaza, Suite 250A
                                          Honolulu, HI  96813
                                                               808-586-4309
                                                               FAX 808-586-4370
       Rob Saunders
       Environmental Engineer, Division of
        Conservation and Natural Resources
                                          Division of Environmental Protection
                                          Capital Complex
                                          333 W. Nye Lane
                                          Carson City.  NV  89710-
                                                               702-«7-5«70
                                                               FAX 702415-0868
                                                                                                                           !« of 20

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MXVt» >*J»"CONTACT,LST
                                  EPA Region X
                                  Address
                                  Fax
U.S. EPA - Region X
1200 6th Avenue
Seattle, WA 98101
206-553-OM0-
Name
JocWafece
Title
Storm Water Coordinator
Telephone
206-553-8399
Mail Stop
(WD134)
                                                       State Offices
                                                     in EPA Region X
Name and Titk
Korwya George
Maaifer. Industrial Wastewater Program
Mfce Alien
Chief
Paul Kciran
Righu Namburi
Andy Airich
Wall West
*
Peter Birch
Supervisor of Urban Non-Point
Management Unit - Municipal
Address
•Alaska Department of Environmental Quality
410 Willoughby Avenue
Juneau, AK 99801
Idaho Department of Health and Welfare
Division of Environmental Quality
Permits and Enforcements
1410 North Hilton Street
Boise, ID 83706
Oregon Department of Environmental Quality
2020 SW 4th Avenue
Suite 400
Portland, OR 97201-5884
Oregon Department of Environmental Quality
1 102 Lincoln Street
Suite 210
Eugene, OR 97401
Oregon Department of Environmental Quality
201 W. Main Street
Suite 2-D
Medfbrd, OR 97501
Oregon Department of Environmental Quality
2146 NE Fourth, #104
Bend, OR 97701
Washington Department of Ecology
Mail Stop PV- 11
P.O. Box 47600
Olympia, WA 98504-7600
Telephone
907-465-5313
FAX 907^65-5274
208-334-5898
FAX 208-334-0417
503-229-6345
FAX 503-229-5359
503-686-7839
EXL 230
FAX 503-686-7551
503-77 64010
FAX 503-776-6262
503-388-6146
FAX S03-388-8283
206-438-7076
FAX 206-4M-WO
                                                                                                                        •

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 Addresses for State Pesticide Agencies
 Region 1

 Connecticut
 Director
__ Pesticide Management Division
 Department of Environmental
    Protection
 79 Elm Street
 Hartford, CT 06106
 (203) 424-3369

 Maine
 Director
 Board of Pestidde Control
 Maine Department of Agriculture
 State House Station #28
 Augusta, ME 04333
 (207) 287-2731

 Massachusetts
 Chief
 Pesticides Bureau
 Massachusetts Department of Food
    and Agriculture
 100 Cambridge Street, 21st Floor
 Boston, MA 02202
 (617) 727-3000

 New Hampshire
 Director
 Division of Pesticide Control
 New Hampshire Department of
    Agriculture, Markets and Food
 P.O. Box 2042
 Concord, NH  03302-2042
 (603) 271-3550

 Rhode Island
 Chief
 Division of Agriculture
 Rhode Island Department of
    Environmental Management
 22 Hayes Street
 Providence, RI 02908
 (401) 277-2782
 Vermont
 Director
 Plant Industry, Laboratory and
    Standards Division
 Vermont Department
    of Agriculture
 116 State Street
 Montpelier,VT  05602
 (802) 828-2431
Region 2

New Jersey
Assistant Director
Pesticide Control Program
New Jersey Department of
   Environmental Protection
CN411
Trenton, NJ 08625-0411
(609) 530-4011

New York
Chief
Bureau of Pesticides and Radiation
Division of SoHd and Hazardous
   Materials Regulation
New York Department of
   Environmental Conservation
50 Wolf Road
Albany, NY 12233-7254
(518) 457-7482   '

Puerto Rico
Director
Analysis and Registration of
   Agricultural Materials
Puerto Rico Department of Agriculture
Agrological Laboratory
RO. Box 10163
Santurce, PR 00908
(809) 796-1735

Virgin Islands
Pesticide Program Director
8000 Nisky Center, Suite 231
Estate Nisky, Charlotte Amalie
St. Thomas, US VI 00802
(809) 774-3320, ext 135
Region 3

Delaware
Deputy Secretary
Delaware Department of Agriculture
Division of Consumer Protection
2320 South DuPont Highway
Dover, DE  19901
(302) 739-4811

District of Columbia
Program Manager
Pesticide Hazardous Waste and
   Underground Storage lank Division
Environmental Regulation
   Administration
Department of Consumer and
   Regulatory Affairs
2100 Martin Luther King, Jr.
   Avenue, SE,Koom 203
Washington, DC 20020
(202)645-6080

Maryland
Chief
Pesticide Regulation Section
Office of Plant Industries and
   Pest Management
Maryland Department of Agriculture
50 Harry S. Truman Parkway
AnnapoEs,MD 21401-7080
(410) 841-5710

Pennsylvania
Chief
Agronomic Services Division
Bureau of Plant Industry
Pennsylvania Department of
   Agriculture
2301 North Cameron Street
Harrisburg, PA 17110-9408
(717) 787-4843

Virginia
Program Manager
Office of Pestidde Services
Virginia Department of Agriculture
   and Consumer Service
RO. Box 1163
Richmond, VA 23209
(804) 371-6558

West Virginia
Director
Pesticide'Divisfon
West Virginia Department of
   Agriculture
1900 Kanawha Boulevard, East .
Charleston, WV 25305-0190
C304) 558-2209

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State Pesticide Agencies (confd)


Region 4

Alabama
Director
Division of Plant Protection, and
   Pesticide Management
Alabama Department of
   Agriculture and Industries
RO. Box 3336
Montgomery, AL 36109-0336
(334)24242656

Florida
Director
Division of Agricultural
   Environmental Services
Department of Agriculture
   and Consumer Services
3125 Conner Boulevard
Tallahassee, PL 32399-1650
(904)488-3731

Georgia
Assistant Commissioner
Plant Industry Division
Georgia Department of Agriculture
19Mnrtln Luther KlngDrlve,SW
Atlanta, GA  30334
(404)656-4958
Kentucky
Director
Division of Pesticides
Kentucky Department
   of Agriculture
100 Fair Oaks Lane
Frankfort KY 40601
(502)564-7274

Mississippi
Director
Bureau of Plant Industry
Mississippi Department of
   Agriculture and Commerce
RO. Box 5207
Mississippi State, MS 39762
(601)325-3390
North Carolina
Assistant Pesticide Administrator
Food and Drug Protection Division
North Carolina Department of
   Agriculture
P.O. Box 27647
Raleigh, NC 27611-0647
(919) 733-3556

South Carolina
Department Head
Department of Pesticide Regulation
257 Poole Agriculture Center
Qemson University
demson, SC 29634-0394'
(803) 656-3171

Tennessee
Director
Plant Industries Division
Tennessee Department of Agriculture
P.O. Box 40627
Nashville, TN 37204
(615)360-0130
Region 5

Illinois
Chief
Bureau of Environmental Programs
Illinois Department of Agriculture
EO. Box 19281
Springfield, IL 62794-9281
(217) 785-2427

Indiana
Pesticide Administrator
Office of the Indiana State Chemist
1154 Biochemistry Building
Purdue University
West Lafayette, IN 47907-1154
(317) 494-1585

Michigan
Director
Pesticide and Plant
   Management Division
Michigan Department of Agriculture
EO. Box 30017
Lansing, MI 48909
(517) 373-1087

Minnesota
Director
Division of Agronomy Services
Minnesota Department of Agriculture
90 West Plato Boulevard
St. Paul, MN 55107
(612) 296-563<>

Ohio
Specialist in Charge of
   Pesticide Regulation
Division of Plant Industry
Ohio Department of Agriculture
8995 East Main Street
Reynoldsburg,OH 43068-3399
(614) 728-6987
          -.
Wisconsin
Administrator
Agricultural Resources
   Management Division
Wisconsin Department of Agriculture
Trade and Consumer Protection
2811 Agriculture Drive
Madison, WI'53704
(608)224-4546

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 State Pesticide Agencies (confd)


 Region 6

 Arkansas
 Director
 Division of Feeds, Fertilizer
   and Pesticides
 Arkansas State Plant Board
 #1 Natural Resources Drive
 Littie Rock, AR 72205
 (501) 225-1598

 Louisiana
 Director
 Pesticide and Environmental Programs
 Louisiana Department of
   Agriculture and Forestry
 EO. Box 3596
 Baton Rouge, LA 70821-3596
 (504) 925-3763

 New Mexico
 Chief
 Bureau of Pesticide Management
 Division of Agricultural and
   Environmental Services
 New Mexico State Department
   of Agriculture
 EO. Box 3005, Department 3AQ
 New Mexico State University
 Las Cruces, NM 88003-0005
 (505) 646-2133

 Oklahoma
 Director
 Department of Environmental Quality
 Plant Industry and Consumer Services
 Oklahoma Department of Agriculture
 2800 North Lincoln Boulevard
 Oklahoma City, OK 73105-4298
 (405) 271-1400

Texas
Assistant Commissioner for
   Pesticides
Texas Department of
   Agriculture
EO. Box-12847
Austin, TX 78711
 (512) 463-7624
Region 7

Iowa
Chief
Pestidde Bureau
Iowa Department of Agriculture
Henry A. Wallace Building
East 9th Street and Grand Avenue
Des Moines, LA. 50319
(515) 281-8591

Kansas
Director
Plant Health Division
Kansas Department of Agriculture
109 S.W. 9th Street
Tbpeka,  KS 66612-1281
(913) 296-2263

Missouri
Director
Bureau of Pesticide Control
Missouri Department of Agriculture
EO. Box 630
Jefferson City, MO 65102
(314) 751-2462

Nebraska
Director
Bureau of Plant Industry
Nebraska Department of Agriculture
301 Centennial Mall
EO. Box  94756
Lincoln, ME 68509
(402) 471-2394
Region 8

Colorado
Director
Division of Plant Industry
Colorado Department of Agriculture
700 Kipling Street, Suite 4000
Lakewood,CO  80215-5894
(303) 239-4140

Montana
Administrator
Agricultural Sciences Division
Montana Department of Agriculture
EO.BOX200201
Helena, MT 59620-0201
(406) 444-2944

North Dakota
Director
Pesticide Division
North Dakota Department
   of Agriculture
State Capitol, 600 East Boulevard,
   6th Floor
Bismarck, ND 58505-0020
(701) 3Z8-4756

South Dakota
Administrator
Office of Agronomy Services
Agricultural Services
South Dakota Department of
   Agriculture
Boss Building
523 E. Capitol
Pierre, SD 57501-3182
(605) 773-4432

Utah
Director
Division of Plant Industry
Utah Department of Agriculture
Box 146500
Salt Lake City, UT 84114-6500
(801) 538-7180

Wyoming
Director
Technical Services
Wyoming Department of Agriculture
2219 Carey Avenue
Cheyenne, WY 82002-0100
(307)777-6590

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State Pesticide Agencies (cont'd)


Region 9

Arizona
Director
Environmental Services Division
Arizona Department of Agriculture
1688 West Adams
Phoenix,AZ 85007
(602)542-3578

C*llfomia
Director
California Department of
   Pesticide Regulation
1020 N Street, Rocan 100
Sacramento, CA 95814-5624
(916) 4154300

Hawaii
Administrator
Pestidde Programs
Hawaii Department of Agriculture
EO.Box22159
Honolulu, HI 96823-2159
(808)973-9401
 Nevada
 Director
 Bureau of Plant Industry
 Nevada Division of
   Agriculture
 350 Capitol Hill Avenue
 Reno,NV 89520
 (708)688-1180

 Guam.
 Pcitfdde Program Director
 Guam Environmental
   Protection Agency
 RO.BOX22439-GMF
 BarrigndB/GU 96921
 (671) 472-8863
American Samoa EPA
Office of the Governor
American Samoa Government
EO. Box 2609
Pago Pago, American Samoa 97699
(684) 633-2304

Commonwealth of the Northern
   Mariana Islands
Department of Public Works
Division of Environmental Quality
Commonwealth of the Northern
   Mariana Islands (CNMI)
EO. Box 1304
Saipan, Mariana Islands 96950
(670)234-6984
Region 10

Idaho
Administrator
Division of Agricultural Technology
Idaho Department of Agriculture
EO. Box 790
Boise, ID 83701-0790
(208)334-3550

Oregon
Administrator
Plant Division
Oregon Department of Agriculture
635 Capitol Street, NE
Salem, OR 97310-0110
(503) 986-4635

Washington
Assistant Director
Pestidde Management Division
Washington State Department
   of Agriculture
EO. Box 42560
01ympia,WA 98504-2560
(360) 902-2010

Alaska
Director
Division of Environmental Health
Alaska Department of
   Environmental Conservation
410 Wilioughby Avenue, Room 107
Juneau,AK 99801-1795
 (907)465-5280
                                         GU, AS, CNMI

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            Regional Air Compliance/Enforcement Contacts



Contact	Phone       Fax	

Fred Weeks, Region 1                                     617-565-4171   617-565-4939
Chief, Toxic Pollutants and Compliance Section

Jehunda Menczel, Region 2                                 212-637-4045   212-637-3996
Chief, NJ/Caribbean Compliance Section

Karl Mangels, Region 2                                   212-637-4078   212-637-3996
Chief, NY Compliance Section

David McGuigan, Region 3                                 215-566-2158   215-566-2134
Chief, Air Enforcement Section

Reginald Berino, Region 4                                 404-347-4125   404-347-5207
Chief, Northern Compliance Unit

Sharron Porter, Region 4                                   404-347-2904   404-347-5207
Chief, Air Compliance Section

Diane Sipe, Region 5                                      312-886-6188   312-353-8289
Chief, Air Enforcement and Compliance Assurance (IL/IN)

Peter Spyropoulos, Region 5                                312-886-6073   312-353-8289
Chief, Air Enforcement and Compliance Assurance (MI/WI)

William MacDowell, Region 5                             312-886-6798   312-353-8289
Chief, Air Enforcement and Compliance Assurance (MN/OH)

Donna Ascenzi, Region 6                                   214-665-7229   214-665-7446
Chief, Air Enforcement Section

Don Toensing, Region 7                                    913-551-7446   913-551-7065
Chief, Air Permitting and Compliance Branch

Ron Rutherford, Region 8                                  303-312-6452   303-312-1229
Chief, Compliance  Section

Barbara Gross, Region 9                                   415-744-1138   415-744-1076
Chief, Inspection Section

Ed Snyder, Region 9                                      415-744-1154   415-744-1076
Chief, Compliance  and Oversight Section

Don Dossett, Region 10                                    206-553-8257   206-553-0110
Team Leader, Air Compliance

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        Appendix G
        Facility Checklist
    RCRA Recordkeeping and
Reporting Requirements for Wood
      Preserving Facilities

-------

-------
                                                                   June 19,1996
                            FACILITY CHECKLIST

                    RCRA RECORDKEEPING AND REPORTING
                REQUIREMENTS FOR WOOD PRESERVING FACILITIES

 The following checklist contains reporting and recordkeeping requirements for
 owners/operators of wood preserving facilities that are subject to the standards
 for hazardous waste drip pads (Subpart W) and hazardous waste tanks (Subpart
 J).  It  is intended  to  assist owners/operators in ensuring  that  the required
 documentation, certification, and records are being maintained at a facility. It is
 not intended to serve as a substitute for Federal regulations, and should  not be
 treated as an exhaustive list of requirements; rather, it should be viewed as  a
 compliance tool.

 The information provided is for wood preserving facilities that are large quantity
 generators  of hazardous waste.  For  the most part, requirements  for small
 quantity generators  will be the same.  In situations where  requirements  differ,
 appropriate  annotations are made.   Also,  for many  of  the  recordkeeping
 requirements, there  are specified time periods that  owners/operators must keep
 these records on site. Generally, these periods range from between three to five
 years.  In the event  a legal action is  pending, a facility may be required to retain
 documents  indefinitely.   If no  specific  record retention  period  exists  for a
 particular requirement, owners/operators should check with their  State agency
 to establish appropriate practices at the facility.


                              RECORDKEEPING

 Both  the RCRA  Subpart W and  drip pad standards have  recordkeeping
 requirements pertaining to the documentation of waste management operations,
 maintenance  of forms  or  other   plans, and  the  performance  of  various
 assessments. This documentation should be kept on site and  be readily accessible
 in the event  of an EPA or State inspection.  These requirements are  discussed
 below.

                             Operating Practices

 Ceased Drippage

      Documentation that all treated wood has been left on the Subpart W drip pad until
      all drippage has  ceased (§264.573(k)/§265.443(k)).
Facility Checklist                AppendixC-1

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                                                                            June 19,1996
Drip Pad Cleaning Procedures                                            	

       Documentation of drip pad cleaning procedures employed at the  facility.  , This
       should include documentation of cleaning procedures as well as the date and time of
       each cleaning. Federal regulation requires drip pads to be cleaned in a manner and
       frequency to allow for weekly inspection of the drip pad without  hindrance from
       accumulated residues (§264.573(i)/§265.443(i)).

Storage Yard Cleanup Activities                                          	

       Documentation of all cleanup activities in response to  any  infrequent incidental
       drippage in storage yard.  This documentation must be kept in the facility's files for
       at least three years  (§264.570(c)/§265.440(c)).

Structural Problems                                                      	

       Documentation of any drip pad  condition that may have or has caused a release  of
       hazardous waste from the drip pad (§264.573(m)(l)/§265.443(m)(l)).

Collections from Leak Collection System                                 	

       Documentation of the date, time, and quantity of any leakage collected in the drip
       pad's leak collection system (§264.573(b)(3)/§265.443(b)(3)).

Past Waste Handling Operations                                         	

       Documentation of past waste handling operations and practices  at the facility,
       documentation of all preservatives used throughout the operation of the facility,
       and drippage management practices employed in the process area and in storage
       yards.  Such documentation must be as  complete and  accurate as possible,  and
       include operations conducted by anyone who owned/operated the  wood preserving
       facility prior to the  present owner/operator (§264.573(n)/§265.443(n)).

 Equipment Cleaning                                                     	

        Documentation that all  required equipment  cleaning  or replacement  has  been
        performed in order to delete the F032 waste code from wastes generated on drip
        pads at facilities that once used chlorophenolic formulations.  This documentation
        includes a certification signed by the generator and must be kept  in the facility's
        operating files (§261.35).

 Tank System Inspections                                                  	

        Documentation of  any tank system inspections conducted  pursuant to Subpart J
        (§264.195/§265.195).
 Facility  Checklist                   AppendixC-2

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                                                                               June 19, 1996
Waste Removal                                                             	

       Documentation of the dates, times, and quantity of waste removed the drip pad and
       associated collection systems.  This  is to ensure  that  all  hazardous  waste  is
       removed within the accumulation times provided in §262.34.

Waste Analysis Results                                                     	

       Records of any  test results,  waste analyses,  or other  determinations  made  in
       accordance with §262.11  (hazardous waste determination).  These records must be
       kept at the facility for at least three years from the date that the waste was last
       sent to an on-site or off-site TSDF (§262.40(c)).

Personnel Training  Records                                                	

       Large quantity generators and owners/operators of TSDFs must keep records of all
       personnel and job training conducted in accordance with the provisions of §265.16.
       Among  other things,  employees must  be  familiar  with  procedures for using,
       inspecting, and repairing equipment, parameters  for automatic waste feed cut off,
       emergency response  systems, and shutdown operations.  Employees must  also
       successfully complete an on-the-job training course that explains safety procedures.
       This initial training must be renewed by all  employees annually.  Training records
       on current personnel must be kept until closure of the facility.  Training records  on
       former employees must be kept for at least three years from the date the employee
       last worked  at the facility.  Small  quantity generators are subject to personnel
       training requirements that are less detailed than the ones mentioned above.  For
       more information on these requirements, see §262.34 (d)(5).

                               Required Plans and Forms

Incidental Drippage Contingency Plan	

       A written contingency plan that describes how owners/operators will respond to a
       discharge of  infrequent or incidental drippage in storage yards.  All documents
       relating to such cleanup must be kept for three years (§264.570(c)/§265.440(c)).

Drip Pad Upgrading Plan

       If a drip pad upgrade is planned (i.e., a liner and leachate detection/collection
       system are to be  installed), a written plan for upgrading, repairing, and modifying
       the drip pad to meet the design and operating requirements of Subpart W.  This
       written  plan  must describe all changes  to be made to the  drip pad in sufficient
       detail to document compliance with the standards (§264.571(b)/§265.441(b)).  This
       plan must also be reviewed by an independent, qualified, registered professional
       engineer and submitted  to the  FJ?A Regional Administrator  (See Reporting
       Requirements).
Facility Checklist                   AppendixC-3

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                                                                               June 19,1996
Closure Plan                                                                 	

       Owners/operators of facilities  that  do not comply with the liner/leak detection
       and leak collection provisions must  develop  and maintain a written closure plan
       that will be available to inspectors, and must be maintained throughout the active
       life of the  facility.    Where  decontamination of all  contaminated  soils is not
       feasible, a  contingent post-closure plan must also be  prepared.   Note: The
       requirements for closure plans do not apply to generators of hazardous waste, but
       only to permitted/interim status facilities (§265.445(c)).

Hazardous Waste Manifest                                                 --.-•

       Owners/operators must keep a copy of each  Uniform Hazardous Waste Manifest
       used to send hazardous wastes off site for treatment, storage, or disposal.   Signed
       copies of every manifest must be retained on site for three years (§262.40(a)).

Emergency Contingency Plan                                               	

       Large quantity generators and owners/operators of TSDFs must develop facility
       contingency plans. These plans must describe the actions facility personnel must
       take to respond to fires, spills, explosions, or releases at the facility (§265.52). A
       copy of the contingency plan must be maintained at the facility and submitted to all
       local police departments, fire departments, hospitals, and State and local
       emergency response teams that may be called upon to provide emergency services.
       Small quantity generators must develop a modified contingency plan. For more
       details, see §262.34(d).

Biennial Report                                                             	

       Generators must keep a copy of each Biennial Report submitted for a period of at
       least three years from the due date of the report (§262.40(b)).

Land Disposal Restrictions (LDR)                                          	

       All LDR notifications and certifications must be kept on file at  the facility for at
       least five years (§268.7(a)(7)).

Waste Removal From Drip Pad and Collection System                  	

       A description of procedures that will be followed  to  ensure that  all wastes are
       removed from the drip pad and associated collection system at least once  every 90
       days must be kept on file.  This will help ensure  that  owners/operators  do not
       accumulate hazardous wastes on drip pads for longer than the 90 days allowed by
       Federal regulations  (§262.34(a)(iii)(A)).
 Facility Checklist                   AppendixC-4

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 	                  6/19/96


 Tank Closure Plan

        Owners/operators of facilities with  tank systems must develop a closure plan.
        Those that do not have secondary containment must also develop a contingency plan
        for closing as a landfill  if  all  contamination  cannot  be  practicably removed
        (§264.197).  Note: This requirement is only for permitted/interim status facilities.
        Generators accumulating hazardous waste in tanks are  not required to develop
        closure plans.

                            Assessments and Certifications

 Assessment of Existing Drip Pad Integrity

        All owners/operators of hazardous waste drip pads built before December 6, 1990,
        must have on file an evaluation of the integrity of the  drip  pad that  has been
        reviewed  and certified  by an independent, qualified,  registered  professional
        engineer.  This assessment must be reviewed, updated, and recertified  annually
        until all upgrades necessary to comply with the Subpart  W  design and operating
        requirements are completed (§§264.571(a)/265.441(a)).

 Annual Drip Pad Recertification                                           	

        Drip pads that do not have a liner/leak detection and leak collection system must
        be recertified  annually  by an independent, qualified,  registered  professional
        engineer.  This certification  must describe the extent to which the drip pad meets
        the drip pad design requirements (§264.573(a)(4)/ §265.443(a)(4)).

 Assessments of Drip Pads with Sealants/Coatings                        	

       All owners/operators of drip pads that are complying with the sealant option must
       keep a written assessment of the drip pad on file at  the facility.  This evaluation
       must document the extent to which the  drip pad  meets the  drip pad design and
       operating standards.   This  assessment must be certified   by an  independent,
       qualified, registered professional  engineer, and must be reviewed, updated, and
       recertified annually (§264.573(a)(4)/§265.443(a)(4)).
                        *•
 Design Standard Certification                                             	

       Drip pads must be evaluated by an independent, qualified, registered professional
       engineer  to certify  that   the  drip pad  meets   all  design  requirements
       (§264.573(g)/§265.443(g)).

 Liner Certification                                                         	

       Immediately following installation  of liners, drip pads must be certified  as
       complying with the design standards of Subpart W by an independent, qualified,
       registered professional engineer.  This certification must be  kept as part of the
       facility's operating  log (§264.574(a)/§265.444(a)).
Facility Checklist                   AppendixC-5

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                                                                            June 19,1996
Existing Tank Assessment                                                _ _ _

       All existing tanks and sumps must be assessed to ensure the integrity of the system.
       A written assessment that  has been  certified by an independent,  qualified,
       registered professional engineer must be obtained and kept on file at the  facility
       (§264.191(a)/§265.191(a)).

New Tank Assessment                                                   	

       Owners/operators of new tank systems must obtain a written assessment reviewed
       and certified by an independent,  qualified,  registered  professional engineer
       attesting that  the  system  has sufficient structural integrity  and  that  it  is
       acceptable for the storing of hazardous  waste (§264.192(a)/§265.192(a)).

Certification Statements                                                  	

       Owners/operators of new tank systems must obtain and keep on file  at the facility
       written statements by those persons required to certify the design of the tank system
       and supervise the installation  of the tank system in accordance with  the  tank
       regulations  (§264.192(g)/§265.192(g)).     These  certifications  must  also  be
       accompanied by an additional certification  attesting to  the  validity  of all
       assertions made in the assessment (§270.11(d)).

Job Descriptions  and Titles

       Large quantity generators and owners/operators  of TSDFs are required to maintain
       records of the job title for each  position related to hazardous waste management,
       and the name of the employee filling each position.  A written job description for
       each position must also be maintained,  including the  requisite skill, education, or
       other qualifications and duties of facility personnel assigned to each position.
                              REPORTING REQUIREMENTS

The  Subpart W  and  Subpart  J  standards  contain  a  number  of  reporting
requirements.  These  reports must  be prepared by the owner/operator of the
facility and submitted to EPA. The reports that will most likely be required  from
wood preserving facilities are described below.

Drip Pad Upgrade Plan                                                   	

        If owners/operators intend to upgrade (i.e., install a liner) a drip pad, upgrade
        plans must be developed and submitted in accordance with §264.571 (b)/§265.441(b)
        to the EPA Regional Administrator no later than two years before the date that all
        changes are to be made.
 Facility Checklist                   AppendixC-6

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                                                                                 June 19,1996
  Final Drip Pad Drawings

         Upon completion of all  repairs and modifications, owners/operators must submit
         final, as-built drawings for the drip pad to either the EPA Regional Administrator
         or the State Director.  These drawings must be accompanied by a certification by an
         independent, qualified,  registered professional engineer attesting that the  drip
         pad conforms to the drawings (§264.571(c)/§265.441(c)).

  Discovery of Dangerous Condition

         Within  24 hours after .discovery of a condition that may have or has caused a
         release of hazardous waste from the drip pad, owners/operators must notify the
         EPA Regional Administrator of the  condition and, within  ten  working days
         provide written  notice to the Regional Administrator with a description  of the
         steps that will be taken to repair  the  drip pad and clean up any leakage   The
         report must  also include  a  schedule   for  completion  of these  activities
         (§264.573(m)(l)/§265.443(m)(l)).

 Completion of Repair


        Upon completion of all drip pad repairs and clean up performed in conjunction with
        §264.573(m)(l)/§265.443(m)(l),  owners/operators  must  also   notify  the  EPA
        Regional Administrator in  writing  and  provide certification   signed  by  an
        independent, qualified,  registered professional engineer to  verify  that  the
        appropriate actions have been taken (§264.573(m)(3)/§265.443(m)(3)).

 Closure Plans


        Owners/operators of interim status facilities  must prepare and submit a written
        closure plan  to EPA  describing how  the  facility  will  be closed when waste
        management operations cease. Generally, closure includes cleanup of contaminated
        soils and equipment at the facility.  Although large and small quantity generators
        accumulating hazardous waste in tanks and drip  pads are required to comply with
        general closure standards, they are not required to develop or submit formal closure
        plans to EPA.

 Tank Recertification


        Before a tank system that has undergone major repair can be returned to service, it
        must be certified  by an independent, qualified, registered professional engineer to
        be capable of handling hazardous waste. This recertification must be submitted to
        the EPA Regional Administrator within seven days of returning the tank system to
        service (§264.196(f)/§265.196(f)).                                     y

 Spill Notification

        Unless an owner/operator has already reported  a release  under CERCLA §302.4,
        any release to the environment that is'greater than one pound, or that has not been
        contained immediately and cleaned up, must be reported  to the  EPA Regional
        Administrator within 24 hours of detection.  In addition, a written follow-up report
Facility Checklist
Appendix C - 7

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                                                                             June 19,1996
       must  be  sent  to  the  EPA  Regional  Administrator   within   30   days
       (§264.196(d)/§265.196(d)).

Generator Notification                                                    	

       All owners/operators of wood preserving facilities managing RCRA hazardous
       waste  must obtain  an EPA identification  number  by submitting  EPA  Form
       8700-12 to the  appropriate State  hazardous waste  agency. Conditionally  exempt
       small quantity generators are not required to obtain an EPA identification number.

Biennial Report                                                           	

       All large quantity generators and TSDFs that generate hazardous waste that  is
       sent off site to  a TSDF must submit a Biennial  Report to the EPA Regional
       Administrator by March 1 of each even numbered year (i.e., every other year). This
       must cover all generator activities during the previous year  only, and must be
       submitted on EPA Form 8700-13A. A copy of each report must be kept at the facility
       for three years from the due date of the report (§262.41).

Exception Reports                                                          	

       Large  quantity  generators  who  do not receive  a  copy of the hazardous  waste
       manifest within 45 days of the  date the waste was accepted by the hazardous
       waste  transporter must  submit an exception report to the  EPA  Regional
       Administrator. This report must include a legible copy of the manifest and a cover
       letter  explaining efforts that were taken to obtain the manifest. Small quantity
       generators who do not receive a copy of the manifest with 60 days of the date the
       waste was accepted by the  hazardous waste  transporter must also  submit  an
       exception report to the EPA Regional Administrator.  Small  quantity generators
       must submit a legible copy of the manifest with some indication that the generator
       has not received confirmation of delivery. Small quantity generators do not need to
       submit a cover letter (§262.42).
  Facility Checklist
Appendix C - 8

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      Appendix D
Subpart W (Drip Pad) Checklist

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                                   Date 	
                                   Inspector 	
                                   Facility ID #
                    SUBPART W  (DRIP PAD)  CHECKLIST

Section  A -  Design Requirements                         YES    NO

1.  Is the drip pad constructed of non-earthen
    materials  excluding wood and non-structurally
    supported  asphalt?  [265.443(a) (1) ]

2.  Is the drip pad sloped to free-drain  treated
    wood drippage,  rain and other waters,  or
    solutions  of drippage and water or  other wastes
    to the associated collection system?
    [265.443(a)(2)]

3.  Does the drip pad have a curb or a  berm around
    the  perimeter?  [265.443(a)(3)]

4.  Has  the  drip pad been evaluated to  determine
    that it  meets the requirements  of paragraphs
    (a)  through (f)  of  265.443?

    If yes,  has the owner/operator  obtained a state-
    ment from  an independent,  qualified registered
    PE certifying that  the drip pad design meets the
    requirements of this section?  [265.443(g)]


Section  B -  Sealed  Drir> Pads

1.  Is the drip pad an  existing pad or  has the owner
    or operator elected to comply with  265.442(a)(4)
    instead  of  265.442(b)?

    If no, skip to  Section C.

2.  Is < the entire surface of  the drip pad  where
    drippage occurs  or  may run across sealed, coated
    or covered  with  a surface material  that has a
    hydraulic  conductivity of less  than or equal to
    1x10"" centimeters per second?  [265.443 (a) (4) (i) ]

3.  Is the drip pad  maintained free of  cracks and
    gaps  that  could  adversely affect its hydraulic
    conductivity?  [265.443(a)(4)(i)]

4.  Is tho material  used to seal the drip  pad
    chemically  compatible with the  preservatives
    that  contact the pad? [265.443(a)(4)(i)]
                          Subpart W  1 of 8

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                                  Date 	
                                  Inspector 	
                                  Facility ID #
                                                         YES   NO
5.  Does the owner or operator have on file at the
    facility a written assessment of the integrity
    of the drip pad,  reviewed & certified by a
    registered PE that attests to the results of
    the evaluation? [265.443(a)(4)(ii)J

    If yes, is the assessment reviewed, updated
    and recertified annually?

6.  Does the evaluation document the extent to which
    the drip pad meets the design and operating
    standards of this section, except for subsection
    (b) which applies to pads with liner/leak
    detection? [265.443(a)(4)(ii)]

7.  Is the drip pad of sufficient structural
    strength and thickness to prevent failure due
    to physical contact, climatic conditions,
    stress of installation and stress of daily
    operations, e.g., vehicle traffic and movement
    of wood? [265.443(a)(5)3


Section C - Lined Drip Pads

1.  If the owner/operator elects to comply with
    265.443(b) instead of 265.443(a)(4), Does the
    drip pad have a synthetic liner installed
    below the drip pad.

2.  Is the liner designed, constructed and installed
    to prevent leakage from the pad into adjacent
    subsurface soil, groundwater or surface water at
    any time during the active life including
    closure period of the drip pad?  [265.443(b)(1)]

3.  Is the liner constructed  of materials that have
    appropriate chemical properties and sufficient
    structural strength and thickness  to prevent
    failure due to pressure gradients, physical
    contact with the waste, climatic conditions,
    stress of installation and stress  of daily
    operations, e.g., vehicle traffic  on the pad?
    [265.443(b)(l) (i)]

4.  Is the liner placed on a  foundation or base
    capable of providing  support to  the liner and
    resistance to pressure gradients above and below
    the liner to prevent  failure of  the liner due to
    settlement, compression  or uplift?
    [265.443(b)(1)(ii)]

                          Subpart  W   2 of  8

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                                   Date 	
                                   Inspector 	
                                   Facility ID #
 5.   Is  the  liner  installed to covef-all  surrounding
     earth that  could come in contact  with waste or
     leakage?  [265.443(b)(1)(iii)]


 Section D - Leakage Detection System

 1.   Does the  drip pad have a leakage  detection
     system  that is immediately above  the  liner?

 2.   Is  the  leakage Detection system designed,
     constructed,  maintained and  operated  to  detect
     leakage for the pad? [265.443(b)(2)]

 3.   Is  the  leakage detection system constructed of
     materials that are:

     Chemically  resistant to the  waste managed  in the
     drip pad  and  the leakage that might be generated?
     [265.443(b)(2)(i)(A)]

     Of  sufficient strength and thickness  to  prevent
     collapse  under the pressures exerted  by  over-
     laying  materials and by equipment used on  the
     drip pad? [265.443 (b) (2) (i) (B) ]

 4.   Is  the  leakage detection system designed and
     operated  to function without clogging through
     the scheduled closure of the drip pad?
     [265.443(b)(2)(ii)]

 5.   Is  the  leakage detection system designed so that
     it  will detect the failure of the drip pad or
     the presence  of a release of hazardous waste or
     accumulated liquid at the earliest  practicable
     time? [265.443(b)(2)(iii)]


Section E - Leakage Collection System

Leakage Collection System applies only  to drip pads
installed after December 24,  1992.

1.  Does the drip pad have a leakage  collection
     system  immediately above the liner?
     [265.443(b)(3)]

2.   Is the  leakage collection system  designed,
    constructed, maintained and  operated  to  collect
     leakage for the pad such that it  can  be  removed
     from below the drip pad?  [265.443(b)(3)]

                          Subpart W   3  of 8
                                                          YES   NO

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                                      Date 	
                                      Inspector 	
                                      Facility ID #
                                                         YES   NO
3.  Is the date, time and quantity of any leakage
    collected and removed from this system
    documented in the operating log? [265.443(b)(3)]

4.  Is the drip pad maintained such that it remains
    free of cracks, gaps, corrosion or other
    deterioration that could cause hazardous waste
    to be released from the pad? [265.443(c)]

5.  Is the drip pad and associated collection system
    designed and operated to convey, drain and
    collect liquid resulting from drippage or
    precipitation in order to prevent run-off?
    [265.443(d)]


Section F - Run-On & Run-Off Control

1.  Is the drip pad protected by a structure as
    described in 265.440.(b)?

    If yes, skip to Section G.

2.  If not protected by a structure as described in
    265.440(b), has the owner/operator designed,
    constructed, operated and maintained a run-on
    control system capable of preventing flow onto
    the drip pad during peak discharge of a  24-hour
    25-year storm?  [265.443(e)]

3.  Does the system have sufficient excess capacity
    to contain any run-on that might  enter the system
    to collect and control at least the water volume
    resulting from a 24-hour 25-year  storm?
     [265.443(e)]

4.  If not protected by a structure as described in
    265.440(b), has the owner/operator designed,
    constructed, operated and maintained a  run-off
    management system to collect  and  control at  least
    the water volume resulting from a 25-year storm?
     [265.443(f)]


Section G - Operation

1.  Has the drippage and accumulated  precipitation
    been removed from the associated  collection
     system as  necessary  to  prevent overflow onto
    the drip pad?  [265.443(g)]


                          Subpart W  4 of 8

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                                      Date 	
                                      Inspector 	
                                      Facility ID #
                                                         YES   NO
2.   Is the drip pad surface cleaned thoroughly in a
    manner and frequency such that accumulated
    residues of hazardous waste or other materials
    are removed so as to allow weekly inspections
    of the entire drip pad surface without
    interference or hindrance from accumulated
    residues of hazardous waste and other
    materials? [265.443(i)]

    If yes, has the owner/operator documented the
    date and time of each cleaning? [265.443(i)]

    Is the cleaning procedure used described in
    the facility's operating log? [265.443(i)]

3.   Is the drip pad operated and maintained in a
    manner to minimize tracking of hazardous waste
    or hazardous waste constituents off the drip pad
    as a result of activities by personnel or
    equipment? [265.443 (j)]

4.   After being removed from the treatment vessel,
    is treated wood from pressure and non-pressure
    processes being held on the drip pad until
    drippage has ceased.  [265.443(k)]

    If yes, has the owner/operator maintained
    records sufficient to document that all treated
    wood is held on the pad following treatment?

5.   Are the collection and holding units associated
    with run-on and run-off control systems emptied
    or otherwise managed as soon as possible after
    storms to maintain design capacity of the
    system? [265.443(1)]

6.   Has the owner/operator maintained as part of the
    facility operating log documentation of past
    operating and waste handling practices?
    [265.443(n)]

    If yes, does it include:
    a. preservative formulations used in the past?
    b. description of drippage management practices?
    c. description of treated wood storage and
       handling practices?
                          Subpart W  5 of 8

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                                      Date 	
                                      Inspector 	
                                      Facility ID #
                                                         YES   NO

Section H - Release of Hazardous Waste

1.  Throughout the active life of the drip pad,
    has the owner/operator detected a condition that
    may have caused or has caused a release ..of
    hazardous waste? [265.443(m) ]

    If no, skip to Section I.

2.  Has the condition been repaired within a
    reasonably prompt period of time following
    discovery? [265.443(m)]

    Upon detection of a condition that may have
    caused or has caused a release of hazardous
    waste, did the following occur;

3.  Has a record of the discovery been entered in
    the facility operating log? [265.443 (m) (i) (i) ]

4.  Was the portion of the drip pad affected by the
    condition immediately removed from service?
    [265.443(m)(1)(ii)]

5,  Has the steps for repair of the drip pad been
    determined, any leakage been removed from below
    the drip pad and a schedule for clean up and
    repair been established?  [265.443(m)(1)(iii)]

6.  Within 24 hours after discovery of the condition,
    was the Regional Administrator notified and with
    in 10 working days was a written notice provided
    to the Regional Administrator with a description
    of the steps that will be taken to repair the
    drip pad, clean up any leakage and the schedule
    for accomplishing this work?  [265.443(m)(1)(iv)]

7.  Upon completing all repairs and clean up, has
    the owner/operator notified the Regional
    Administrator in writing  and provided a certifi-
    cation, signed by an  independent, qualified,
    registered PE, that the repairs and clean  up
    have been completed in accordance with the
    written plan submitted in accordance with
    paragraph 265.443(m)(1)(iv)?  [265.443(m)(3)]
                           Subpart W  6  of  8

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                                       Date 	
                                       Inspector 	
                                       Facility ID #
                                                          YES    NO

 Section I - Record Keeping

 1.   During construction or installation,  was  the
     liner and cover system e.g.,  membranes, sheets
     or  coatings inspected for uniformity,  damage
     and imperfections e.g.,  holes,  cracks, thin
     spots or foreign materials?  [265.444(a)]

 2.   Immediately after construction  or  installation,
     was the liner  inspected  and  certified as  meeting
     the requirements of 265.443  by  an  independent,
     qualified,  registered PE? [265.444(a)]

     If  yes,  is  the certification maintained at the
     facility as part of the  facility operating
     record?  [265.444(a)]

 3.   Was the  liner  and cover  inspected  after
     installation to ensure tight seams and joints,
     and the  absence of tears,  punctures or blisters?
     [265.444(a)]

 4.   Is  a contingency plan maintained that describes
     how^an owner/operator will respond immediately
     to  incidental  drippage or kickback in the
     storage  yard?  [265.440(c)(1)]

     Has  the  facility completed the  following:

     a.  clean up of drippage/kickback within 72
        hours of the incident  not  discovery
     b.  documented  the clean up of drippage/kickback
     c.  retained documentation for three years
     d. managed  the contaminated media in accordance
       with  federal regulations

5.  Has  the  facility inspected the  drip pad weekly
    and  after storms?  [265.444(b)]

    If yes did  the facility check for the following:

    a. deterioration, malfunctions  or improper
       operation of  run-on and run-off control
       systems?  [265.444(b)(1)]
    b. the presence  of  leakage in and proper
       functioning  of  leakage  detection system?
        [265.444(b)(2)]
    c. deterioration or cracking  of the drip pad
       surface?  [265.444(b)(3)]
                          Subpart W  7 of 8

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                                      Date 	
                                      Inspector	
                                      Facility ID #
6.  Are procedures described in the facility
    operation log that will be followed to ensure
    that all wastes are removed from the drip pad
    and associated collection system at least once
    every 90 days? [262.34(a)(1)(iii)(A)]

7.  Is each waste removal, including the quantity
    of waste removed from the drip pad and the
    collection system and date and time of removal
    documented?  [262.34(a)(1)(iii)(B)]
                                                         YES   NO
                           Subpart W  8  of 8

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     Appendix E
Tank Systems Checklist for
      Generators

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                                                 Date   	
                                                 Inspector	^^
                                                 Generator EPA ID#	

                     TANKS SYSTEMS CHECKLIST FOR GENERATORS
                  (40 CFR Part 265, Subpart J - rank Systems)

NOTE:    If multiple tanks exist, list each tank and specify compliance
         cr noncompliance on the facility's site plan.  Indicate on site
         diagram which tanks are not in compliance.

1.  Are tanks presently used to accumulate waste?                     ves
    b.   Number of existing tank systems without secondary
         containment (265.193) in operation, or for which
         installation commenced on cr prior to the date the
         contained wasre became hazardous (after 7/14/86)?

    c.   Are assessments on file for each of these tank svstems
         (a & b)?
                                                                              No
2.  Are there any exempt tank systems present (Closed-loop
    Recycling System - 261.4(a)(8))?         •                       	yes  	No

3.  Assessment of the integrity of existino tank systems
    (265.191):

    a.   Number of existing tank systems without secondary
         containment (265.193) in operation, or for which
         installation commenced on or prior to Julv 14,  1986?
    If yes,  do the following apply?

         (1)   Assessment conducted by 1/12/88?                      	yes  	No

         (2)   Tor wastes becoming hazardous after 7/14/86,
              was assessment on tank containing such waste
              conducted within 1 year after the date the
              waste became hazardous?                               	yes     No

         (3)   Certification(s) by independent, qualified, and
              registered P.S.(s)?              "                    	ves  	No

         (4)   Integrity assessment(s) results?

              	 not leaking?

              	 unfit for use?  (see item ?S)

    Comments:

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                                                 DATE	
                                                 FACILITY  ID	


4.  New tank systems or components- (265.192):

    a.   Number of new tank systems  or components installed or
         put into use after 7/14/867                                	

    b.   Are assensments on file for each of the new tank systems
         or components?                                             	*es 	No
         1 * •    *
         If yes,  do the following apply:
          i
         (1)  Assessment(s) certified by an independent,
              qualified, registered P.E.?                           __.Yes 	No

         (2)  Assessment(s) include the following information:

              -  Design standards {including secondary containment
                 unless a variance-265.193 (g)' has been received?    	Ves 	No

              -  Factor affecting corrosion potential of tanks or
                 components in which the external shell or  any
                 external metal component  is in  contact with  soil
                 or water  (determined by a corrosion expert)?       	Yes 	No

              -  The  type  and degree of external corrosion
                 protection that is needed to ensure the  integrity
                 of the tank system(s)  or  components(s) described
                 above (determined  by  a corrosion expert)?          	Yes 	No

              -  A determination of design or operational  measures
                 that will protect  underground  tank system
                  cornoonents  against potential damage  from vehicular
                 traffic?                                           	Yes 	No

               -  Design considerations to  ensure that tank
                  foundations will maintain the  load of a full tank? 	Yes 	No

               -   Tank systems  will  be anchored  to prevent flotation
                  or dislodgement where it  is placed in a saturated
                  zone or is located within a seismic fault zone?   	Yes 	No

               -  Tank systems  will  withstand the effects of frost
                  heave?                                            	*es 	No

     c.   Are certification statements by  a qualified installation
          insoector or qualified registered professional engineer on
          file to attest:

          (1)  to proper tank system or component installation,
               tank system tightness, and  that necessary repairs were
               oerformed if needed?                                  	Yes 	No
                                 GSNTANK  2  of  11

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                                                  DATE	
                                                  FACILITY  ID
          (2)   That backfill, used  for  underground tank  systems
               or  components, was made  up  of  noncorroeive,  porous
               and homogeneous materials that were placed properly
               around the system or component to ensure  proper
               support?                                               	Yes  	No

          (3)   That ancillary equipment has been supported  and
               and protected against physical damage and excessive
               stress due to settlement, vibration, expansion or
               contraction?                                              yes    No

          (4.)   That the type and degree of corrosion protection
               necessary was provided,  based  on the certified design
               assessment of the system?                              	yes  	No

          (5)   That an independent corrosion  expert ensured the
               proper installation of a corrosion protection system
               if  it was field-fabricated?                            	Yes  	No

    d.   Has secondary containment been provided as recruired in
         265.193  (see Item #6)?

          (!•)   Has a variance (255.193 (g)) been obtained from
               secondary containment?                                    yes    yo

    Comments:
5.  Containment and detection of releases  (265.193).

    NOTE:     Tank systems storing hazardous waste that contain
              no free liquids and are located within buildings
              with impermeable floors are  exempt from these
              requirements (265.190(a)).

    a.   How old are the existing tank  systems?

         (1)  If not known, what is the age of the facility?
    b.   Kow many existing systems are being used to store or
         treat dioxin containing wastes:  F020, F021, F022, F023
         F026, and F027?
         Are there any existing tank systems which are used to
         store or treat materials which became hazardous wastes
         after 1/12/87?           .                                   	Yes  	No

         (1)  How many?
                                GSNTAKX  3 of  11

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                                                 DATE	
                                                 FACILITY  ID,.
    d.   Use  the  guidelines  in  265.193(a)(1)-(5)  to determine when
        secondary  containment  meeting  the  requirement  of  265.193
        is to be provided  (use narrative  explanation  sheet  if
        necessary).

    e.   Have any variances  (265.193(g))  from secondary containment
        been reoruested  for  existing  tank  systems?                 	Ves  	No
        ...     i "
    £.   Are  leak tests  meeting the requirements  of 265.ISl(b)(5)
        conducted  annually  for non—enterable underground  tanks
        without  secondary  containment?                            	Yes  	No

    g.   Are  leak tests  as  described  above, or internal inspections
        or other tank integrity examinations done by an
        independent,  qualified, registered P.E.  annually  for  all
        other types  of  tanks  systems and  ancillary equipment?      	Yes  	No

    h.   Are  records  of  the  results of leak tests or other tank
        integrity  assessments  kept on file?                       	Yes  	No

    i«   Were any tank systems  or components found to be leaking
        or unfit for use as a result of leak tests or other
        assessments?

    NO7S:      If the  answer is yes, refer to item #8 - Response  to
              leaks or spills  and disposition of leaking or unfit-for-
              use tank systems  (265.196).

    Comments:
6.  Secondary containment systems (265.193(b)-(f)).

    &.   Has secondary containment been provided  for any tank
         system or component (see Items 4.d.,  S.d, and 9.f)?        	Yes 	No

    b.   If yes, has the containment system  been:

         (1)  Designed, installed, and operated to prevent any
              migration of wastes or accumulated  liquid out of
              the system to the soil, ground water, or surface
              water at a.ny time during its use?                     	Yes 	No

         (2)  Capable of detecting and collecting releases and
              accumulated liquids until the  collected material
              is removed?                                           	Yes 	No

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                DATE	
                FACILITY ID
c.   To satisfy b. ,  has the containment system been:

     (1)   Constructed of or lined with materials that are
          compatible with the waste(s) to be contained?

     (2)   Provided with sufficient strength and thickness
          to prevent failure due to pressure gradients,
          physical contact with waste it is exposed to,
          climatic conditions, the stress of installation,
          and the stress of daily operations including
          vehicular traffic?

     (3)   Placed on a foundation or base capable of providing
          support to the system, resistance to pressure
          gradients above and below, and protection against
          failure due to settlement, compression or uplift?

     (4)   Provided with a leak detection system that is
          designed and operated so that it will detect the
          failure of either the primary and secondary
          containment structure or any release of waste  or
          accumulated liquid into the secondary containment
          system within 24 hours or at the earliest practicable
          time based on existing leak detection technology and
          site conditions?

     (5)   Sloped or otherwise designed or operated to drain
          or remove liquids resulting from leaks, spills, or
          precipitation?

d.   Which device below is used to provide secondary containment
     for tanks?  .(Check those that apply.)

     _ (1)  A liner (external to the tank)
     _ (2)  A vault
     _ (3)  A double-walled tank
     _ (4)  An equivalent device approved by the Department.

e.   If an external liner system is used, has it been:

     (1)   Designed or operated to contain 100% of the capacity
          of the largest tank within its boundary?

     (2)   Designed or operated to prevent run-on or infiltration
          of precipitation into the system?

NOTE:     If the containment collection system has sufficient
          excess capacity -' able to contain precipitation  from
          a 25-year, 24-hour rainfall event - this feature is
          not necessarv.
Yes
                                             No
                                      Yes
                                             No
                                      Yes
Yes
Yes
                                             No
                                             No
                                      Yes
Yes
                                             No
                                             No
GSNTANK 5 of 11

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                                             DATE	
                                             FACILITY ID
     (3)  Determined  to be  free  of  cracks  and gaps?             	Yes 	No

     (4)  Designed and installed to completely surround the
         tank and to cover all  surrounding  earth  to prevent
         lateral and vertical migration of  waste?             	Yes 	No

     If  a vault system is used,  has it  been:
     • . •    i
     (1)  Designed or operated to contain  100% of  the
         capacity of the largest tank  within its  boundary?     	Yes 	No

     (2)  Designed or operated to prevent  run-on or
         infiltration of precipitation into the system
          (see note above)?                                    	Yes 	No

     (3)  Constructed with  chemical-resistant water  stops
         in  place at all joints (if any)?                     	Yes 	No

     (4)  Provided with an  impermeable  interior coating or
         lining that is  compatible with the accumulated
         waste to prevent  migration into  the concrete?         	Yes 	No

     (5)  Provided with protection  against the formation  and
         ignition of vapors within the vault if the wastes
         being accumulated are  ignitable  or reactive?          	Yes 	No

     (6)  Provided with an  exterior moisture barrier or
         otherwise designed or  operated to prevent  migration
         of  moisture into  the vault (if it is subject  to
         hydraulic pressure)?                                  	^es 	No

     If  double-walled tanks are  used, are they:

     (1)  Designed as an  integral structure so that  the  outer
          shell will contain releases from the inner tank?      	Yes 	No

     (2)  Protected,  if  constructed of metal, from corrosion
          on  the inner tank interior and outer shell exterior? 	Yes 	No

     (3)   Provided with  a built-in, continuous leak detection
          system capable  of detecting a release within 24 hours
          or  at the earliest practicable time based on existing
          technology and  site conditions?                       	Yes  	No
Comments:
                            GENTANK 6  of  11

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                                                 DATE	
                                                 FACILITY ID,                   ~_


7.  General operating requirements  (265.194).

    a.   Is there any evidence of ruptures, leaks, corrosion, or
         failure in the tank system or ancillary equipment?         	Yes 	No

    NOTE:     If the answer is yes, explain in the narrative report.
         •  • ,    i
    b.   Are appropriate controls and practices such as the
         following used to prevent spills and overflows from
         tanks or secondary containment systems:

         (1)  Spill prevention controls (e.g, check valves, dry
              discount couplings, etc.)?                      "     	yes 	No

         (2)  Overfill prevention controls (e.g., level sensing
              devices, high level 'alarms, automatic feed cutoff,
              or bypass to a standby tank)?                         	ves 	No

         (3)  Maintenance of sufficient freeboard in uncoverd
              tanks to prevent overtopping by wave,- wind action,
              or precipitation?                                        ves    No
    c.   Have any leaks or spills occurred in a tank system or
         its ancillary equipment?

    NOTS:     If the answer is yes, explain what steps were taken
              in response to this situation in the narrative reoort
              (see item #8 - 265.196).

    Comments:
8.  Inspections (265.1S5)
Yes 	No
         Does the owner/operator inspect the following, each
         operating day, where present:

         (1)  Overfill/spill control equipment (e.g. waste-feed
              cutoff systems, bypass systems, and drainage
              systems)?               "                                Yes 	No

         (2)  Aboveground portions of the tank system to detect
              corrosion or releases of waste?                       	ves 	j$o

         (2)  Data gathered from monitoring equipment and leak
              detection equipment (e.g. pressure and temperature
              guages, monitoring wells)?                            	Yes 	No
                                GSN7ANX 7 of 11

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                                                DATE	
                                                FACILITY  ID
         (4)   The  construction materials and the  area  immediately
              surrounding the externally accessible portion  of
              the  tank system including secondary containment
              structures (e.g. dikes)  to detect erosion  or signs
              of releases of hazardous waste (e.g. wet spots, dead
              vegetation)?                                         	Yes  	No

    b.   'Are cathodic protection systems, if present,  inspected
         according to the following schedule:

         (1)   Six  months to confirm the proper operation of
              the  cathodic protection system after the initial
              installation, and annually thereafter?                	Yes  	No

         (2)   Every other month to inspect sources of  impressed
              current?                                             	Yes  	No

    c.    Are the inspection results documented in the  operating
         record of the facility?

    Comments:
9.  Response to leaks or spills and disposition of leaking or
    unfit-for-use tank systems (265.196).

    a.   2f a tank or secondary containment system has a leak
         or a spill has occurred, was the system immediately
         removed from service and the flow of hazardous waste
         into the system immediately stopped?                       	Yes 	No

         (1)  If the release was from the tank system, was
              as much of the waste as necessary removed within
              24 hours or at the earliest practicable time
              after its detection to allow inspection, and repair
              to be performed?                                      	Yes 	No

         (2)  If the release was to the  secondary containment
              system, were all released  materials, removed within
              24 hours or in as timely a manner as possible to
              prevent harm to'human health and the environment?     	Yes 	No

    b.   If there was a visible release  to the environment, was
         a visual inspection conducted by the owner/operator?       	Yes 	No

         (1)  Was further migration of the leak or spill  to
              soils or surface water prevented?                     	Yes 	No
                                 GSNTANX 8 of 11

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c.
NOTE:
d.
e.
                                                                   Yes 	No
                                                                   Yes 	No
NCCS:
                                             DATE	
                                             FACILITY ID
(2)  Was the visible contamination removed and
     properly disposed of?	Yes 	No

Was the release to the environment reported to the
Department within 24 hours of detection?                   	Yes 	No

     A leak cr spill of less than or equal to a
   •  quantity of one pound of hazardous waste and
     that is immediately contained and cleaned up
     is exempted from this requirement.

Was a report to the Department, as specified in
265.196{d)(3), submitted within 30 days for nonexempt
releases?

If--a leak was the cause of a release, was the system
repaired before being returned to service?

If the leak caused a release to the environment from a
component of a tank system without secondary containment,
was that component provided with secondary containment
as specified in 265.193 before it was returned to service
(see Item #6)?                                             	yes 	No

     If the leaking component is aboveground and can be
     inspected visually, secondary containment does
     not need to be provided after repair.

     If a component was replaced in order to repair the
     system, the owner or operator must comply with the
     standards for new tank systems or components
     265.1S2 and 265.193 (see item #4).

Was a major repair performed to return the tank system
back to service?                                           	yes 	jjo

(1)  If yes, was a certification of this major repair
     done by an independent, qualified, registered P.S.
     before the system was returned to service?            	Yes 	No

(2)  Was this certification submitted to the department
     within 7 days after returning the system to service?  	Yes 	No
Comments:
                            GEKTAKK 9 of 11

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                                                 DATE	
                                                 FACILITY ID.
10. Closure and post-closure care (265.197).

    a.   At closure of a tank system, did the owner/operator remove
         or decontaminate all waste residues, contaminated containment
         system components, contaminated soils, and structures and
         equipment contaminated with waste, and manage them as
         hazardous waste?                                           .	Yes 	No
         « • •   .•
    Comments:
11. Special requirements for ignitable or reactive wastes  (265.198).

    a.   Are  icnitable or reactive wastes placed in tanks?          	Yes 	No

          (1)   If yes, are they treated, rendered, or mixed
               before or immediately after placement in the
               tank .system so that:

               -  The resulting waste, mixture,  or dissolved
                 material no longer meet the definition  of
                 ignitable or reactive waste and 265.17(b)
                 is complied with?                         .         	Yes 	No

         OR

                 The waste is stored  or treated in  such  a
                 way that is protected  from any material or
                 conditions that may  cause  the  waste to  ignite
                 or react?                                          	-'es 	No

          NOTE:  If yes, use narrative  explanation  sheet to
                 describe separation  and  confinement procedures.
                 If no, use narrative explanation  sheet  to
                 describe sources  of  ignition  or reaction.

          OR   -  The tank system  is used  solely for emergencies?    	Yes 	No

     b.    Are protective distances  maintained between the
          tank accumulation areas  and  any  public ways,
          streets,  alleys, or adjoining  property lines  that
          can be  built  upgn as required  in Tables 2-1 through
          2-6 of  the  National Fire Protection Association's
          "Flammable  and Combustible  Liquids Code"?                  	Yes 	No

          Comments:
                                 GZNTANK 10 of 11

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                                                 DATE	
                                                 FACILITY ID.
12. Special requirements for incompatible wastes  (265.199).

    a.   Is there evidence that incompatible wastes were in the
         same tank?                                                 	yes 	No

    NOTE:     If yes, use narrative explanation sheet to state
              the results (e.g. signs such as fire, toxic mists,
         • . '   heat generation, bulging containers, etc.) and
              whether 265.17(b) was complied with.
          i
    b.   If a waste is to be placed in a tank that previously held
         an incompatible waste or material, was that tank
         washed.?                                   '                 	ves 	No

    NOTE:     If yes, describe the washing procedure on the
              narrative explanation sheet.  If no, was 265.17(b)
              complied with?

    Comments:
                                GSNTANX 11 of II

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      Appendix F
Facility Checklist - Other Laws

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                                                                       June 19,1996
                             FACILITY CHECKLIST

                                  OTHER LAWS

In   addition  to   the  RCRA   hazardous  waste   management   standards,
owners/operators must be familiar with several other environmental laws and
programs. The following checklist is designed to assist owners/operators of wood
preserving facilities subject  to these requirements.  It includes items  required
under the Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA), the Clean
Water  Act  (CWA),  and  the   Comprehensive   Environmental   Response,
Compensation, and Liability Act (CERCLA). It is not an exhaustive  reference to
the  requirements  under the  respective  statutes, but a  general  overview.
Owners/operators must consult the appropriate regulations  to  further ascertain
the extent of requirements under each program.

            FEDERAL INSECTICIDE, FUNGICIDE, AND RODENTICIDE ACT

The Federal Insecticide,  Fungicide,  and  Rodenticide  Act  (FIFRA) regulates
chemicals with pesticidal properties that are sold in commerce as poisons.  Many
chemicals used by the wood  preserving industry are regulated under  FIFRA.

                           FIFRA Operating Practices

Consumer Information Sheets (CISs)                                 	

       Wood preserving facilities must ensure that  Consumer Information Sheets  (CISs)
       are provided to retailers for distribution with all treated wood products.

Worker/Handler Certification                                        	

       Wood preserving facilities  must obtain proper certification for facility workers
       who will be handling regulated materials.   Facilities should be able to provide
       inspectors with the following information:
       	  Documents stating who is authorized to certify facility/pesticide  handlers
             (i.e., EPA, State, Department of Defense).
       	  A list of pesticide applicators who  are authorized to use restricted-use
             pesticides.
       	  All facility or personnel licenses/certificates.

Restricted-Use Pesticide Certification                                  	

       Wood preserving formulations containing creosote, pentachlorophenol, and inorganic salts
       such as chromated copper arsenate (CCA) are classified as restricted-use pesticides. The
       application of such formulations is limited to pesticide licensed applicators or individuals
       under the direct supervision of a licensed pesticide applicator. Thus, if the facility is using
       these formulations, at least one employee must be licensed to apply restricted-use
       pesticides.
Facility Checklist                 Appendix F -1

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                                                                              June 19,1996
Container Handling                                                        	

       Wood preserving facilities must ensure that storage, mixing/loading, and container
       disposal areas are in compliance with FIFRA regulations.  Facilities should be able
       to demonstrate:
       	  Bulk storage areas are in compliance with Federal/State requirements.
       	  The location, ventilation,  segregation,  shelter, and  housekeeping  of
              pesticides in storage/handling areas meet regulatory standards.
       	  Security, fire protection, and warning signs are in compliance with  State
              applicable regulations.
       	  Mixing  equipment  and operating procedures reduce handler exposure to
              pesticides.
       	  Employees are trained how  to use safety equipment and follow safety
              procedures.
       	  Employees are trained to properly clean and dispose of pesticide containers,

       Note:  Owners/operators should pay  particular attention to these requirements
       when performing loading, unloading, and  other  operations in the loading  dock area
       and in the  tank farm where these pesticides are transferred between  containers and
       otherwise  managed.

Pesticide Disposal                                                           	

       Wood  preserving facilities  must  dispose of  pesticides  in  accordance  with
       applicable pesticide container label and RCRA requirements.

Worker Safety Measures                                                   	

       Wood preserving facilities must implement necessary worker safety  measures (e.g.,
       pesticide applicators and assisting personnel may be required to wear safety gear).

Pesticide Application Practices                                             	

       Wood preserving'facilities  must conduct pesticide application practices according
       to appropriate procedures. These procedures include:
       	  Using proper dilution ratios when mixing pesticides.
       	  Wearing the safety  gear required by the pesticide label.


                        FIFRA  Recordkeeping  Requirements

Pesticide Registration Status                                               	

       All wood treatment facilities must maintain a list of the type, use, and registration.
       status of all  pesticides  stored and used at the facility,  particularly  if  any are
       restricted- or experimental-use pesticides.

Previous Audit Records                                                   	

Pesticide Permit Application  Records                                     	
Facility Checklist                   Appendix F - 2

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                                                                          June 19,1996
 Inventory Records                                                      	

 Employee Training Records                                             	

 Equipment Repair Records                                              	



                          FIFRA Reporting Requirements

 Air Monitoring for Arsenic                                             	

       Wood facilities using formulations containing arsenic are required to either conduct
       air monitoring on personnel working in areas where arsenic exposure might occur or
       require operators  to wear respirators.  This air monitoring must be performed in
       accordance with EPA's Permissible Exposure Limit (PEL) Monitoring Program and
       all analytical results (or the PEL checklist) must be maintained at the facility and
       submitted to EPA annually.




                                 CLEAN WATER ACT

 The goal of the Clean Water Act (CWA) is to restore and maintain  the chemical,
 physical, and biological integrity of the nation's surface waters by prohibiting the
 discharge of pollutants to surface waters in toxic amounts.   Wood preserving
 facilities are subject to some  CWA  regulations, including  the requirement to
 obtain appropriate water  permits.

                             CWA Operating Practices

 Effluent Limitations                                                     	

       Wood preserving facilities must ensure that all facility waste water discharges are
       in compliance with the effluent limitation for the wood preserving industry found
       in 40 CFR Part 429.

 NPDES Permit for Storm Water Discharge

       Wood preserving facilities must obtain and keep on site a NPDES permit for storm
       water discharge. All wood preserving facilities,  regardless of size, must obtain an
       NPDES permit for storm water discharges.  Permit application requirements for
       storm water discharges associated with specific industrial activities can be found
       in 55 PR 47990. NPDES permits are issued by the EPA Regional office or by States
       which EPA has authorized to administer the program.
Facility Checklist                  Appendix?-3

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                                                                      June 19,1996
Storm Water Sampling and Flow Measurements                      	

      Wood  preserving  facilities  must conduct storm water sampling  and  flow
      measurements, as specified by the NPDES permit at the correct location, with the
      proper frequency, and using acceptable equipment and methods. (Most CCA plants
      are required to perform storm water  sampling on a  bi-annual or annual basis;
      however, plants in some States are required to sample once a month per outfall.  In
      most cases, the storm water permit will contain a discharge monitoring schedule).

Equipment Calibration and Maintenance                              	

      Wood  preserving  facilities  must perform  all necessary calibrations   and
      maintenance procedures on storm water monitoring and sampling equipment.

Water Sample Procedures                                            	

      Wood preserving facilities must use approved procedures to collect, preserve, and
      transport water samples.
                      CWA Recordkeeping Requirements

Storm Water Pollution Prevention Plan                              	

      Wood preserving facilities  must develop and keep on file the  facility's Storm
      Water Pollution Prevention Plan which should contain the following information:
      	  A list of potential sources of storm water pollution at the plant and an
             evaluation of their significance.
      	  The Best Management  Practices (BMPs) that  are appropriate to the
             specific site and source.
      	  Implementation schedule for BMPs.
                  COMPREHENSIVE ENVIRONMENTAL RESPONSE,
                       COMPENSATION, AND LIABILITY ACT

The Comprehensive Environmental Response, Compensation,  and Liability Act
(CERCLA) of 1980, commonly known as Superfund, authorizes EPA to respond
to releases, or threatened releases, of hazardous substances that may endanger
public health, welfare, or the environment.  CERCLA also enables EPA to  force
parties responsible  for  environmental   contamination  to  clean  it  up  or to
reimburse  the Superfund  for  response  costs incurred  by EPA.   All  wood
preserving facilities must adhere to CERCLA reporting requirements.
Facility Checklist                 Appendix F - 4

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                                                                              June 19,1996
                          CERCLA Reporting Requirements

Hazardous Substance Release                                              	

       Facilities  must report any release  of a hazardous substance which,  within  a 24-
       hour period, equals  or exceeds a designated reportable  quantity  (RQ) to the
       National Response Center (NRC) at (800) 424-8802.
       Hazardous substances and RQs are defined and listed in 40 CFR §302.4.  Arsenic,
       chromium, creosote, and pentachlorophenol are hazardous substances often found a t
       wood preserving facilities. The RQs for these substances are:
           •  Arsenic-lib.
           •  Chromium - 5,000 Ibs.
           •  Creosote - 1 Ib.
           •  Pentachlorophenol - 10 Ibs.
Facility Checklist
Appendix F - 5      * u.s. GOVERNMENT PRINTING OFFICE: 1996 - 723 -143 / aaaza

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