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
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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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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
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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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
.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
-------
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
-------
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
-------
Appendix A
Instructions on Electronic Access to
this Guide
-------
-------
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
-------
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
-------
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$, you will be given the option to comment to the system
operator (Sysop). Please indicate what files you have sent, and
that the comments or supplemental documents should be placed
in Directory 51 - "Sector Compliance Information and Guides."
Messages can also be sent to the Sysop from the main menu
using the Message option.
Appendix A - 7
-------
D. ADDITIONAL RESOURCE DOCUMENTS AVAILABLE ON E$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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
"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
-------
-------
STORM WATER
LIST OF CONTACTS
March 1995
•
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-------
;-«*"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
-------
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
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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
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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«
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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
WPO#123#DHEC4
005.COLUMB35#c
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US
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
WPCW123/DHEC4
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/CDANIELHSri25#
@gm.STATE.SC.
US
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
-------
&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
-------
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
-------
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
-------
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
-------
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
-------
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
-------
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
•
-------
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
-------
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
-------
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
-------
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
-------
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
-------
-------
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
-------
-------
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
-------
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:
-------
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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