-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
describe automatic waste
feed cutoff system,
including any pre-alarm
systems
use of direct transfer
operations requires
submittal of information
supporting 266.1 1 1
conformance
demonstration of
266.1 1 2 conformance if
claim is made that
residues are excluded
from regulation
CHECKLIST
REFERENCE
85
85
85
.
FEDERAL RCRA CITATION
270.22(d)
270.22(e)
270.22(f)
ANALOGOUS
STATE
CITATION
STATE ANALOG 1$:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
_
BROADER
M SCOPE
SUBPART D - CHANGES TO PERMITS
27 PERMIT MODIFICATION AT THE REQUEST OF THE PERMITTEE
replace "270.21" with
•270.22" and "and
270.63" with "270.63
and 270.66"
paragraph heading is
changed to "Newly
regulated wastes and
units"
add wording at end of
paragraph regarding the
continued management of
hazardous waste in units
newly regulated as
hazardous waste
management units;
change "wates" to
"wastes"
94
85
85,94
270.42(c)(1Kiv)
270.42(g)
270.42(g)(1)
'
Page 107 of 121
DCBIFMJ 15
Rewind: O9/29/9*
12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
insert "The unit" before
"was in existence"; add
"or newly regulated
waste management unit"
after "characterized
waste"; add "or
regulating the unit" at end
of paragraph; change
"effetive" to "effective"
insert "The permittee"
before "submits"; insert
"or unit" after "waste"
insert "The permittee"
before "is"; insert
"applicable" before
"standards*; change "Part
265" to "Parts 265 and
266 of this chapter"
delete "In the case of
Classes 2 and 3
modifications,"; insert
"The permittee" before
"also"; replace "permit
modification" with "Class
2 or 3 modification";
change "180 days after*
to "180 days of"; add "or
subjecting the unit to
RCRA Subtitle C
management standards" ,
to end of paragraph
/
CHECKLIST
QCCVBAJftp '
l"KrW"n
270.42{g)(1)(iii)
270*2(g)(1)(iv)
ANALOGOUS
STATE
CITATION
•
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
•
Page 108 of 121
OCKF94J.1&
O9/29/94
PMiMd: 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
insert 'the permittee"
before "certifies"; insert
"each" before "such
unit"; change "Part 265"
to "requirements of Part
265 of this chapter for";
add ", or regulating the
unit as a hazardous waste
management unit" after
"hazardous"; change
"clarify" to "certify";
insert "all" before "these
requirements"; change
"shall lose" to "will lose"
CHECKUST
REFERENCE
85
FEDERAL RCRA CITATION
.
270.42(g)(1)(v)
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
.EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
28
Page 109 of 121
DC8IF94J.15 - R*vM: 09/29/94
12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
change heading of "L." to
"Incinerators, Boilers, arid
Industrial Furnaces"; in
•LI." &-L.2." replace "a
waste feed rate limit, or
an organic feed rate limit"
with "a feed-stream feed
rate limit, a chlorine/
chloride feed rate limit, a
metal feed rate limit, or
an ash feed rate limit"; in
"L.3." replace "HCI" with
"HCI/Cla metals,"; in
"L.3." & "L.4." insert .",
boiler, or industrial
furnace" after "incinera-
tor"; in "L.5." replace "."
after "requirements" with
":"; in "L.5.a." insert "or
maximum" before "com-
bustion gas temperature"
& add "flue gas carbon
monoxide and hydro-
carbon concentration,
maximum temperature at
the inlet to the paniculate
matter emission control
system, or operating
parameters for the air
pollution control system"
after "chamber"; change
"L.6." heading to "Bum-
ing different wastes:"; in
"L.6.a." change "incine-
ration" to "burning"; in
"L.6.a. & b." change all
"to incinerate" to "to
burn"; in "7.b." change
"waste incineration" to
"waste burning"; in "L.8."
insert "non-hazardous
waste before "fuel"
CHECKLIST
OCCCBEIdfY
ncrcnEn\*c
85,94
FEDERAL RCRA CITATION
270.427
Appendix 1
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRW-
GENT
MORE
STRIN-
GENT
\
BROADER
IN SCOPE
^^
•
Page 110 of 121
DCBIF94J.1S
O9/29/94
Print*!: 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA IS
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
/
CHECKLIST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STNN-
GENT
BROADER
IN SCOPE
SUBPART F - SPECIAL FORMS OF PERMITS
PERMITS FOR BOILERS AND INDUSTRIAL FURNACES BURNING HAZARDOUS WASTE
new boilers and industrial
furnaces subject to
270.66(b}-(f); those under
interim status standards
of 266. 103 subject to
270.66(g)
permit for new boiler or
industrial furnace shall
specify appropriate
conditions for the
following operating
periods:
pretrial burn period
described; Director must
establish in Pretrial Burn
Period of permit
conditions, allowable
hazardous waste feed
rates and operating
conditions; extension of
period for up to 720
additional hours; permit
may be modified to reflect
extension as per 270.42
submittal of statement
with Part B that suggests
operating conditions, for
266.104-266.107
compliance during period,
including restrictions on
266.102(e) operating
requirements
85
85
85
85
270.66(a)
270.66(b)
270.66(b)(1)
270.66(b)(1)(i)
Page 111 of 121
DCBIF94J.1S
RcviMd: 09/2904
Printed: 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
review of Part B materials
and specification by
Director of requirements
sufficient to meet
266.104-266.107
performance standards
based on engineering
judgment
for duration of trial burn.
Director establishes
conditions in permit to
determine feasibility of
compliance with
266.104-266.107
standards and to
determine adequate
266.102(e) operating
conditions; applicants
must propose a trial burn
plan as per 270.66(c) and
submit with Part B
for defined minimum
period immediately
following trial burn, during
which submission and
review of trial burn results
and modification of permit
by Director occurs.
Director establishes
operating requirements
most likely to ensure
compliance with
266.104-266.107
standards
/
CHECKLIST
n> rrnriinr
wrcncnwc
85
111,114
85
85
.-
FEDERAL RCflA CITATION
270.66(b)(1)(ii)
270.66(b}(2)
270.66(b)(3)(i)
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
Page 112 of 121
DCHF94J.15
09/29/94
Primed: 12/21/M-
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
submittal of statement
with Part B that identifies
operating conditions for
266.104-266.107
compliance during period,
including restrictions on
266.102(e) operating
requirements
review and specification
by Director of
requirements sufficient to
meet 266.104-266.107
performance standards
based on engineering
judgment
for final period of
operation, Director
develops operating
requirements in
conformance with
266.102(e> and 266. 104-
266.107 standards;
Director shall make
necessary modifications
to permit as per 270.42
based on trial burn results
to ensure compliance
information the trial burn
plan must include;
Director may require
supplemental information
analysis of each
feedstream, as fired
/
CHECKLIST
REFERENCE
85
85
85,94
85
85
FEDERAL RCRA CITATION
270.66(b)(3)(ii)
270.66(b)(3)(iii)
270.66(b)(4)
270.66(c)
270.66(0(1)
270.66(c)(1)(i)
270.66(c)(1)(ii)
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
Page 113 of 121
DCWF94J.15
: 09/29/9*
Phnt»d: 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
I
analysis of each
hazardous waste, as fired
detailed engineering
description of boiler or
industrial furnace
detailed description
of sampling and
monitoring procedures
detailed test schedule for
each hazardous waste for
which the trial burn is
planned
detailed test protocol
description of, and
planned operating
conditions for, any
emission control
equipment to be used
procedures for rapid
stopping of hazardous
waste feed and emissions
control if an equipment
malfunction
i
CHECKLIST
REFERENCE
85
85,94
85
85
85,94
85
85
85
85
85
85
FEDERAL HCRA CITATION
270.66(c)(2)
270.66(c)(2)(i)
270.66
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REOWflEMENTS
other information Director
finds necessary
trial burn conducted to
demonstrate conformance
with 266.104-266.107
standards under an
approved trial burn plan
findings under which the
Director shall approve a
trial burn plan
submit to Director within
90 days of trial burn
completion a certification
that trial burn was carried
out in accordance with
approved plan and results
of all 270.66(c) required
determinations
submit all data collected
during any trial bum
270.66{d) submissions
must be certified by
signature of person
authorized to sign permit
application or 270.11
report
for DRE trial burn under
266.104(a). Director will
specify trial POHCs; basis
for specification
determinations to be
made based on each trial
burn:
CHECKLIST
REFERENCE
85
85
85
85
85
85
85
85
FEDERAL RCRA CITATION
270.66(C)(9)
270.66(d)(1)
270.66(d)(2)
270.66(d)(2)(i)
270.66{d)(2)(ii)
270.66(d)(2)(iii)
270.66
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
quantitative analysis of
specified materials in the
feedstreams
determinations needed
when a DRE trial burn is
required under
266.104(a)
quantitative analysis of
stack gas and a
computation showing
conformance with the
emission standard when a
trial bum is required for
chlorinated dioxins and
furans under 266.104(e)
quantitative analysis of
stack gas and
computations showing
conformance with
applicable emission
standards when a trial
bum is required for
paniculate matter, metals,
or HCI/C12 under 266.105,
266.106(c) or (d), or
266.1 07 (b}(2) or (c)
quantitative analysis of
scrubber water, ash
residues, other residues
and products to estimate
fate of trial POHCs,
metals, and
chlorine/chloride when a
trial burn is required for
DRE, metals or HCI/CI2
under 266.104(a),
266.106(c) or (d), or
266.107(b)(2) or (c)
CHECKLIST
•MTCTIfUMT
^ETC^EnirfC
85
85
85,94
85
85
FEDERAL RCRA CITATION
270.66(f)(1)
270.66(f)(2)
270.66(f)(2Mi)
270.66(f)(2Mii)
270.66(f)(2)(iii)
270.66(f)(3)
270.66(f)(4)
270.66(f)(5)
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
m
W
•
Page 116 of 121
DCMF94J »5
09/29/94
Print** 12/21/S4
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REOXRflEMENTS
identification of sources
of fugitive emissions and
their means of control
continuous measurement
of CO, oxygen, and HC in
stack gas
such other information as
Director specifies
to determine feasibility of
compliance with
266.104-266.107
performance standards
and adequate operating
conditions under
266.103, applicants of
existing devices operated
under interim status must
either prepare and submit
a trial burn plan and
perform a trial burn or
submit 270.22(a)(6)
information; submit trial
burn resujts with Part B
application if plan
approved before Part B
submission; date for
submission; requirements
if submitting trial burn
plan with Part B
application
/
CHECKUST
REFERENCE
85
85
85,94
85
-•
FEDERAL RCRA CITATION
270.66(f)(6)
270.66(f)(7)
270.66(f)(8)
270.66(g)
ANALOGOUS
STATE
CITATION
*
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRW-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
•
SUBPART G - INTERIM STATUS
CHANGES DURING INTERIM STATUS
add new paragraph
regarding the addition of
newly regulated units if a
revised Part A permit
application is submitted
on or before the date the
unit becomes subject to
the new requirements
85
270.72(aM6)
« „..-• *««.. OCWF94J.1S - FbviMd: 09/29/94
Page 1 17 of 121 P*** 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and industrial Furnaces as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
add new paragraph
regarding the addition of
newly regulated units
under 270.72(a)(6)
CHECKLIST
REFERENCE
85
FEDBW. RCRA CITATION
270.72(b)(7)
ANALOGOUS
STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STMH-
GENT
MORE
STMN.
GENT
BROADER
IN SCOPE
TERMINATION OF INTERIM STATUS
insert "which has
achieved interim status
prior to November 8,
1 984, interim status
terminates" before "on
Novembers, 1989"
insert "which has
achieved interim status
prior to November 8,
1984, interim status
terminates" before "on
Novembers, 1992"
85,94
85,94
270.73(f)
270.73(g)
>
•
1 Revision Checklist 85 (February 21, 1991; 56 EB 7134) redesignated the old paragraph (d)(2)
as (d)(3) and introduced a new paragraph (d)(2) into the code. Revision Checklist 94 (July 17,
1991; 56 F_B 32688) made technical corrections to the February 21, 1991 amendatory
language for 261.2 and incorrectly redesignated paragraph (d)(3) as (d)(4) and paragraph
(d)(4) as (d)(5). The Federal code, as of February 21, 1991, did not include 261.2
-------
OSWER DIRECTIVE NO. 9841.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
.*
5 Note that, there is a typographical error in the Federal Register addressed by Revision Checklist
94 (56 FJJ 32692; July 17, 1991). The "§266.4" in the heading should be "§266.40." This
error was corrected by Revision Checklist 96 at 56 FR 42512 (August 27, 1991).
6 This paragraph was entered into the code by Revision Checklist 85 and was modified by
Revision Checklist 96. Subsequently, Revision Checklist 98 issued an administrative stay of
the BIF rule as it applies to coke ovens burning certain hazardous wastes from the coke by-
products recovery process. This administrative stay was removed by Revision Checklist 105
(57 FR 27880; June 22, 1992). Note also that Revision Checklist 98 incorrectly changed the
reference "266.100(b), (c), (d) and (f)" to "266.100(b), (c) and (d)." This error was corrected
by Revision Checklist 111 at 57 FR 38564 (August 25, 1992).
7 Revision Checklist 112 (57 £B 41566, September 10, 1992) removed and reserved Subpart E
of Part 266 and recodified the Subpart E provisions as portions of the new Part 279. To
reflect this change. Revision Checklist 112 revised 266.100(b)(1) to refer to Part 279 rather
than Subpart E of Part 266.
8 Note that the Federal Register addressed by Revision Checklist 85 designated this paragraph
as "266.102(d)(4)(D)." This is a typographical error; the correct designation is
"266.102{d)(4)(iv)." See technical correction at 56 FR 32688 (July 17, 1991; Revision
Checklist 94).
^ There seems to be an error in the Federal Register addressed by Revision Checklist 85.
Federal code refers to "paniculate matter standard in § 266.111 (b)," but 266.111 (b)
addresses definitions of "direct transfer equipment" and "container," not paniculate matter
standards. It appears that the Federal code should likely reference 266.105(a) as it does
contain a paniculate matter standard.
10 Note that in the February 21, 1991 rule addressed by Revision Checklist 85, the subparagraph
designation was not italicized. This is a typographical error. The August 27, 1991 (56 FR
42504; Revision Checklist 96) technical correction fixes this error.
11 Note that the August 27, 1991 Federal Register, which addressed the technical correction for
this citation, has a typographical error; the reference to "266.102(e)(4)(iii)(c)(7) and (2)' in
this citation should be "266.102(e)(4)(iii)(C)(7) and (2)."
12 Note that in the federal Register for Revision Checklist 85, the subparagraph designation was
not italicized. This is a typographical error. The 56 FR. 32688 (July 17, 1991; Revision
Checklist 94) technical correction fixes this error.
13 Note that the July 1, 1992 CFR inadvertently omitted the text to 266.103(c)(1)(iHxiii) and
266.103(c)(3)(ii)-(i!i)(C) from the Federal code. States should incorporate these paragraphs,
as found in the Federal Register addressed by Revision Checklist 85 (56 FJJ 7134; February
21, 1991), and amended by Revision Checklist 94 (56 FR 32688; July 17, 1991).
_ „„.* »-«.. OCBIF94J.1S -*•*»«* 09/29/94.
Page 119 of 121 »*«.* 12/21/9*
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
14 In the Federal Register addressed by Revision Checklist 85, the designation for this
subparagraph is 266.104(g)2. This is a typographical error; the correct designation is
266.104(g)(2). See the technical correction at 56 FR 32689 (July 17, 1991; Revision
Checklist 94).
15 Note that there is an error in the Federal Register for Revision Checklist 111 (57 FR 38558;
August 25, 1992) for this rule. The phrase "dispersion modeling to predict the maximum
annual average off-site ground level contamination for each" appears twice but should only
occur once.
16 In the Federal Register addressed by Revision Checklist 85, the designations for these
subparagraphs are 266.107G/m3" in
the July 16, 1991 Federal Register and the "8G/m3" in the 1991 CFR should read "//g/m3" not
"g/m3" as shown at 57 £R 38566 (August 25,1992).
Page 120 of 121
DCWF94J.15
O9/29/94
PrintMl: 12/21/94
-------
OSWER DIRECTIVE NO. 9541.00*21
SPA 15
CONSOLIDATED CHECKLIST: Burning of Hazardous Waste in
Boilers and Industrial Furnaces as of June 30, 1994 (cont'd)
23 Note that Revision Checklist 96 replaced the old section 7.0 introduced into the code by
Revision Checklist 94. •'
Note that Revision Checklist 85 simply makes an announcement concerning the publishing of
the Appendix at a future date. The Appendix was actually entered into the code by Revision
24
Checklist 94.
25 This appendix was originally introduced by Revision Checklist 94; Revision Checklist 85
merely announced that the appendix would be published at a future date. Revision Checklist
125 removed Part 266 Appendix X and Appendices A, B and C to Appendix X, "Guidelines on
Air Quality Models (Revised)" and changed references to the guidelines in Part 266 to refer to
40 CFR Part 51, Appendix W.
26 Note that this is the same section of code which contained the specific Part B information
requirements for the Wood Preserving listing (55 FR 50450). Thus, the Part B
boilers/industrial furnace requirements were added so that the Part B information requirements
for drip pads were inadvertently removed by the rule addressed by Revision Checklist 85 (56
FR 7134; February 21, 1991). On July 1, 1991 (56 £R 30192; Revision Checklist 92} a
technical correction was published moving the wood preserving requirements to 270.26.
27 States only need to make changes if they have adopted, or plan to adopt, the provisions
addressed by Revision Checklist 54 (53 FR 37912), because 270.42 is not required by
271.14 to be part of a State's permitting program.
28 The paragraph following 270.42(g)(1)(v) in Federal code, i.e., 270.42
-------
-------
1
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
Consolidated Checklist for the Toxicity Characteristics Revisions
as of June 30, 1994
The following consolidated checklist
should replace the existing version in
SAM Appendix K
-------
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST
for the
Toxicity Characteristics Revisions as of June 30, 1994
Note: 1} This checklist consolidates the changes to the Federal code addressed by the Toxicity
Characteristic (TO Rule 155 FR 11798; March 29, 1990; Revision Checklist 74] and subsequent
revisions which have occurred through June 30, 1993, as follows:
Revision Checklist 74 [55 FR 11748 (March 29, 1990), 55 FR 26986 (June 29, 1990)];
Revision Checklist 80 [55 FR 40834 (October 5, 1990), 56 FR 3978 (February 1, 1991), 56
FR 13406 (April 2, 1991)];
Revision Checklist 84 [56 FR 5910 (February 13, 1991)1;
Revision Checklist 108 [57 FR 30657 (July 10, 1992)];
Revision Checklist 117 B [57 FR 23062 (June 1, 1992)]; and
Revision Checklist 119 [57 £fi 55114 (November 24, 1992)].
Note that there have been several technical corrections to the TC Rule preamble. An August 2,
1990 (55 FR 31387) notice corrected a typographical error in an implementation timetable found
in the TC Rule's preamble. This error created confusion among small quantity generators
regarding their notification responsibilities for TC wastes. This rule also extended the period of
time within which affected small quantity generators must comply with the new modification
requirements. An August 10, 1990 (55 FR 32377) notice corrected the August 2, 1990 notice.
On September 27, 1990, a clarification to the March 29 final rule was published in the Federal
Register (55 FR 39409) regarding four implementation issues. This clarification also only affected
the TC Rule preamble.
No final rules were promulgated between June 30, 1993 and June 30, 1994 that affected the TC
rule. Note, Revision Checklist 126 (56 FR 46040; August 31, 1993), however, replaced all
references to the TCLP in Part 261, Appendix II with a reference to the TCLP in SW-846. This
rule also replaced the TCLP in Part 261, Appendix It with a note referencing this publication that
is incorporated by reference at 260.11 (a). This rule is not indicated in the checklist reference
column of this consolidated checklist, but it is referenced in the footnote. This approach was
taken because this rule is not a correction to the TC rule per se; but rather it introduced a new
method of referencing the TCLP.
2) Two interim final rules (55 F_R 40834; October 5, 1990 and 56 FR 3978; February 1, 1991)
and a final rule (56 FR 13406; April 2, 1991) extended the compliance date of the Toxicity
Characteristic (TC) Rule for certain hydrocarbon recovery and remediation operations. This
extension is addressed by Revision Checklist 80 and included in this Consolidated Checklist.
Because a less stringent requirement than that imposed by the TC Rule was in effect until
January 25, 1993, the incorporation by States of this extension is optional.
3) States are strongly encouraged to adopt the Permit Modifications Rule (53 FR 37912;
September 28, 1988; Revision Checklist 54) and the "Christmas Tree Rule" (54 FR 9596: March
7, 1989; Revision Checklist 61) to ease implementation of the Toxicity Characteristic Rule and
future waste listings. While both of these rules are optional, they will greatly reduce the
immediate permit burden resulting from the TC Rule.
OCTC34J.15 - RoviMd: 9/29/94
Page i of 11 pnm«* 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
/
CHECKUST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STWN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
__ PART 261 - IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
SUBPART A - GENERAL
DEFINITION OF HAZARDOUS WASTE
change "Extraction
Procedure Toxicity
characteristic" to
"Toxicity
Characteristic"
117B
261.3(a)(2)(i)
EXCLUSIONS
replace
"characteristic of EP
toxicity" with
"Toxicity
Characteristic"
replace
"characteristic of EP
toxicity, and do not
fail the test for" with
"toxicity
characteristic for any
other constituent.
and do not exhibit"
insert "arsenical-
treated" after
"discarded"; replace
•characteristic of EP
toxicity" with
"Toxicity
Characteristic for
Hazardous Waste
Codes D004 through
D01 7"; delete "or
reasons," after
"reason"
74
108
74,108
261.4{b){6)(i)
261.4{b)(6)(ii)
261.4(b)(9)
• /
w
^i^
Page 2 of 11
DCTC94J.15 - toviMd: 9/29/94
Pnrtrt: 12/22/94
-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicrty Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
add new paragraph
regarding petroleum-
contaminated media
and debris that fail
the 26l.24Toxicity
Characteristic test
(D01 8 through D043
only) and are subject
to Part 280
corrective action
CHECKUST
REFERENCE
74
FEDERAL RCflA CITATION
261.4(b)(10)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STMN.
GENT
BROADER
IN SCOPE
Extension for Specified Hydrocarbon Recovery Operations
add new paragraph;
until January 25,
1 993, exclusion for
injected groundwater
exhibiting the 261.24
Toxicrty
Characteristic that is
infiltrated or
reinjected pursuant to
specified hydrocarbon
recovery operations
existing on or before
March 25, 1991;
extension only until
six months after final
rule publication for
groundwater returned
through infiltration
galleries; conditions
for new operations
involving injection to
qualify for date
extension
80
261.4(b)(11)
Page 3 of 11
DCTC94J.15 - R*v»*d 9/29/94
Printed: 12/22/94
-------
OSWER DIRECTIVE No. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL HEQWHEMENTS
operations are
performed pursuant
to a written state
agreement that
includes a provision
to assess the
groundwater and the
need for further
remediation once the
free phase recovery is
completed
3 copy of written
agreement has been
submitted to the
Characteristics
Section, U.S.
Environmental
Protection Agency
4 add new paragraph;
used
chlorofluorocarbon
refrigerants from
totally enclosed heat
transfer equipment.
provided the
refrigerant is
reclaimed for further
use
CHECKLIST
REF0CNCE
80
80
84
FEDERAL RCRA CITATION
t
261.4(b)(11)(i)
261.4(b)(11)
ANALOGOUS STATE
CTTATKM
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRH.
QENT
MORE
STRIN-
GENT
BROADER
m SCOPE
^^
•1
PCS WASTES REGULATED UNDER TOXIC SUBSTANCE CONTROL ACT
exemption for PCB-
containing wastes,
already regulated
under Part 761
(TSCA), that fail the
26 1.24 Toxicity
Characteristic test
(D0 18 through D043
only)
74
261.8
_~^^___
Page 4 of 11
DCTC94J.15 - ftoviMKl: 9/29/94
PrinMd: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
/
FEDERAL REQUIREMENTS
/
CHECKUST
REFERENCE
FEDERAL RCHA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STHN-
GENT
BROADER
IN SCOPE
SUBPART C - CHARACTERISTICS OF HAZARDOUS WASTE
TOXICITY CHARACTERISTIC
5 remove "EP" before
"toxicity"; insert
"using the
methodology outlined
in Appendix II" after
"after filtering";
change "purposes" to
"purpose"
1 remove "EP" before
"toxicity"; add D018
through D043 to
Table 1 ; as per
technical correction,
change the word
"hydroxide" in the
contaminant for
D031 to "epoxide";
add new column with
CAS numbers
74
74
261.24(a)
261.24(b)
Page 5 of 11
DCTCS4J.15 • RnriMd: 9/23/94
Print** 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL WOlNflEMENTS
CHECKLIST
nrmirtiii*f
f^roicfw**c
FEDERAL RCHA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUV-
AUENT
LESS
STNN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
TABLE 1. - MAXIMUM CONCENTRATION OF CONTAMINANTS FOR THE
TOXICITY CHARACTERISTIC
EPAHW
No.1
DOO4
DOO6
0018
O006
D019
D020
D021
0022
D007
D023
0024
D026
0026
0016
D027
0028
D029
0030
tX)12
0031
noa?
D033
DO34
DOO8
0013
DOO9
O014
0035
D036
D037
D038
0010
DO11
0039
0015
0040
D041
0042
D017
D043
Contaminant
Cadmium
Carbon tetrachloride
Chlorobenzene
Chromium
nvCrevoJ
p-Cretol
Creaol
2,4-D
1 ,4-DioHorobwizMM .
1 ,2-Diehloroethana
1 , 1 -Dichloroethylene
2,4-Dinitrotoiuene ......
Endrin
Heptechlor (and it* apoxide) .
HexacNorobutadiene
HexacNoroethane
Lead
IJndane
Mercury
MathoxycNor
Methyl ethyl ketone
PentracHorophenol ... ...
Selenium
Silver
Tetraohloroethytena
Toxaphane
TrioNoroethylene
2,4,5-Trichlorophanol
2.4,6-TricNorophenol
2,4,5-TP (Silvex)
Vinyl chloride
CAS No. '
744O-38-2
744O-39-3
71-43-2
744O-43-9
56-23-6
57-74-9
108-90-7
67-66-3
7440-47-3
95-48-7
108-39-4
106-44-5
94-76-7
106-46-7
107-06-2
76-36-4
121-14-2
72-20-8
76-44-8
118..7A.1
87-68-3
67-72-1
7439-92-1
68-89-9
7439-97-6
72-43-5
78-93-3
98-95-3
87-86-6
1 10-86-1
7782-49-2
7440-22-4
127-18-4
8001-36-2
79-01-6
96-95-4
88-06-2
93-72-1
75-O1 -4
Regulatory
Level
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
*,
CHECKLIST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
SUBPART D - LISTS OF HAZARDOUS WASTES
GENERAL
replace "EP Toxic
Waste" in the hazard
codes and in the text
following the hazard
codes with "Toxicity
Characteristic Waste"
74
261.30{b)
APPENDIX II TO PART 261
METHOD 1311 TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
5, EP toxicity test
6 procedures are
replaced by Method
1311 Toxicity
Characteristic
Leaching Procedures
{TCLP)
74
Appendix II
Withdrawal of Spike Recovery Correction Requirement From Method 1311 TCLP
change "data is" to
"data are"; delete
sentence regarding
bias determined from
matrix spike
determination and
parenthetical
reference phrase
following it
change "may not be
not less" to "may not
be less"
remove subparagraph
119
119
119
Appendix II, 8.2
Appendix II,
8.2.2
Appendix II,
8.2.5
Page 7 of 11
DCTCS4J.15 • R»VM* 9/29/94
Prinud: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
redesignate former
8.4 as 8.5; add new
8.4 and
subparagraphs
addressing use of
internal calibration
quantitation methods
former 8.4 becomes
8.5
f
CHECKUST
REFERENCE
119
119
FEDERAL RCRA CITATION
Appendix II, 8.4
Appendix II,
8.4.1
Appendix II,
8.4.2
Appendix II,
8.4.3
Appendix II,
8.4.4
Appendix II, 8.5
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQIHV.
ALENT
*
'
LESS
STIW-
GENT
MORE
STWN-
GENT
BROADER
IN SCOPE
8
9
PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS
WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES
SUBPART N - LANDFILLS <
DESIGN AND OPERATING REQUIREMENTS
replace "EP toxicity
characteristics" with
"Toxicity
Characteristic"; insert
"with EPA Hazardous
Waste Numbers
D004 through D01 7"
after "chapter"
74
264.30 1(e)(1)
Page 8 of 11
DCTC94J.16 • taviMd. 9/29/94
Printed: 12/22/94
-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
CHECKLIST
fv^QCMGE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STWN-
GENT
BROADER
IN SCOPE
PART 265 - INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF
HAZARDOUS WASTE TREATMENT, STORAGE, AND DISPOSAL FACILITIES
SUBPART K - SURFACE IMPOUNDMENTS
DESIGN REQUIREMENTS
replace "EP toxicity
characteristics* with
"Toxicity
Characteristic"; insert
"with EPA Hazardous
Waste Numbers
D004 through D01 7"
after "chapter"
74
265.221 (d)(1)
SUBPART M - LAND TREATMENT
WASTE ANALYSIS
replace "exceed"
with "equal or
exceed"; replace "EP
toxicity
characteristic" with
"Toxicity
Characteristic"
74
265.273(a)
SUBPART N - LANDFILLS
DESIGN REQUIREMENTS
10
replace "EP toxicity
characteristics" with
"Toxicity
Characteristic"; insert
", with EPA
Hazardous Waste
Numbers D004
through D017" after
"chapter"
108
265.301(dH1>
Page 9 of 11
DCTC94J.15 • RcviNd: 9/29/84
Print** 12/22/94
-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
,•
CHECKLIST
imnt!flekM*c
rVl LJKJVlA
FEDERAL RCRA OTATtON
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STWN-
GENT
BROADER
IN SCOPE
PART 268 - LAND DISPOSAL RESTRICTIONS
APPENDIX I TO PART 268
TOXICITY CHARACTERISTIC LEACHING PROCEDURE (TCLP)
5, replace Appendix
1 1 with note stating the
TCLP is located in
Appendix II of Part
261
74
Appendix I
1 Also see technical corrections to the rule at 55 JFg 26986 (June 29, 1990).
2 See the immediate final rules at 55 £B 40834 (October 5, 1990) and 56
1991) and the final rule at 56 ffi 13406 (April 2, 1991).
6
3978 (February 1,
A copy of the agreement should be sent to EPA's Characteristics Section; thus, this reference
should remain in a State's code. A copy of the written agreement may also be sent to th
State, if the State chooses to include this requirement.
The final rule (56 EB 5910, February 13, 1991) which introduced this paragraph into the
Federal code is considered "narrower in scope" because it narrows the wastes which are
regulated, by excluding from regulation certain chlorofluorocarbon refrigerants as specified at
261.4(b){12).
Revision Checklist 74 added the TCLP at Part 261, Appendix II. Note, however, that Revision
Checklist 126 CSS EB 46040; August 31,1993), a non-TC checklist, replaced the TCLP
(method 1311) in Appendnc II to Part 261 with a note referencing the TCLP "Test Methods for
Evaluating Solid Waste, Physical/Chemical Methods" as incorporated by reference at
260.11 (a). All references to Part 261, Appendix II and Part 268. Appendix IX were revised to
reflect these changes. Revision Checklist 126 did not revise the content nor the intended use
of the TCLP or the EP toxidty methods.
Because the June 29, 1990 (55 FR 26986) notice made extensive corrections to Appendix II,
Part 261, the Appendix in that notice should be used instead of the one in the March 29,
1990 (55 ffi 11798) notice.
7 On June 29, 1990 (55 EB 26986; Revision Checklist 74), EPA promulgated a final rule which
made technical corrections to the March 29, 1990 final rule, including the regulatory language
in 40 CFR Part 261, Appendix II. Those corrections reorganized the TCLP in 40 CFR Part
261, Appendix II and included adding a requirement for the spike recovery correction. The
November 24,1992 rule (57 EB55114; Revision Checklist 119) deleted the requirements j
Page 10 of 11
DCTC84J.16 -ftcvwwl 912919*
Printed: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST : Consolidated Checklist for the
Toxicity Characteristics Revisions as of June 30, 1994 (cont'd)
>
spike recovery correction of analytical data. Because such deletions provide for a standard
less restrictive than was Imposed on June 29, 1990, States are not required to include spike
recovery correction when modifying their programs to incorporate the final TCLP.
8 There is a typographical error in the federal Register: "84.4.4" should be "8.4.4."
9 There is a typographical error in the Federal Register: in the table at 8.5, second column
heading, there should be a space between "TCLP" and "extraction."
1 ° There are several errors in the Federal Register for this citation. First, "such waste does not*
should read "such wastes do not" and "261.4 of this chapter" should read "261.24 of this
chapter" as they are found in the July 15,1985, Federal Register at 50 Ffi 28750 (Revision
Checklist 17(H)) and in the 1992 CFR. Second, "Waste Number* should be "Waste
Numbers.."
11 As background, the TCLP was originally promulgated in 268, Appendix I, on November 7,
1986 (51 EB 40572; Revision Checklist 34) for use in the Land Disposal Restrictions (LDR)
program to determine whether certain wastes require treatment prior to land disposal and to
determine whether certain treated wastes meet the applicable treatment standards. The TC
rule and its June 29, 1990 modification promulgated a revised TCLP at 261, Appendix II, with
modifications based on the Agency's own research and public comment. This TCLP is to be
used in both the TC and the LDR programs. The objective of the above footnoted revision to
268, Appendix I, is to assure that the TCLP entered into the code by the November 7, 1986
notice (51 EB 40572; Revision Checklist 34) is removed and replaced by the TCLP entered
into the code and amended by the final rules (55 EB 11798 and 55 £B 26986) addressed by
Revision Checklist 74. The actual placement of the TCLP within a State's code is not that
important, per se; what is important is that a State's code contains only the Revision
Checklist 74 TCLP. States that have not yet adopted Revision Checklist 34 (the first of the
LDR restrictions) need not make this particular revision to 268, Appendix I, as they would not
yet have entered the original Part 268 TCLP into their code. Also, the change on page 7 of
this checklist for 261, Appendix II, assures that they add the Revision Checklist 74 TCLP to
their code. However, such States must be careful when adding the LDR restrictions to their
code, i.e., the Revision Checklist 34 TCLP should not be added at that time-rather, the
Revision Checklist 74 TCLP should remain the only TCLP in their code. States using the
Consolidated LDR Checklist should be sure to read the relevant footnote on that checklist
regarding this issue.
OCTC94J.15 - ItoviMd: 9/29/94
Page 11 of 11 P***: 12/22/9*
-------
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
Consolidated Checklist for the Wood Preserving Listings
as of June 30, 1994
The following consolidated checklist
should replace the existing version in
SAM Appendix K
-------
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST
for the
Wood Preserving Listings
as of June 30, 1994
Note: 1) This checklist consolidates the changes to the Federal code addressed by the following
Wood Preserving Listings checklists:
Revision Checklist 82 [55 FE 50450 (December 6, 1990)];
Revision Checklist 91 [56 FR 27332 (June 13, 1991)];
Revision Checklist 92 (56 EE 30192 (July 1, 1991)];
Revision Checklist 101 [57 £& 5859 (February 18, 1992)); and
Revision Checklist 120 [57 Ffi 61492 (December 24, 1992)].
No final rules were promulgated between January 1, 1993, and June 30, 1994, that affected the
Wood Preserving Listings rule. Therefore, this consolidated checklist is identical to that of
December 31, 1992.
2) This consolidated checklist adds, to the list of wastes from non-specific sources, three broad
categories of wastes from wood preserving processes that use chlorophenolic, creosote, and/or
inorganic (arsenical and chromium) preservatives. These wastes, F032, F034 and F035, include
wastewaters, process residuals, preservative drippage and spent formulations. The listing of
F032 and the permitting and interim status standards applicable to drip pads handling this waste
are promulgated pursuant to HSWA. The listings of F034 and F035, the permitting and interim
standards for drip pads that handle F034 and F035 wastes, and the addition of a test method to
Appendix III of Part 261 are non-HSWA provisions. EPA will implement the addition of F032 to
the list of hazardous wastes from non-specific sources in authorized States until the States
modify their programs and such modifications are approved by EPA. The non-HSWA
requirements are applicable only in those States that do not have interim or final authorization. In
authorized States, the non-HSWA requirements will not be applicable until the States revise their
programs to adopt equivalent requirements under State law, unless the wastes are designated as
hazardous due to the Toxicity Characteristic, which would allow an owner or operator to comply
with the drip pad standards administered under Federal law.
3) Note that double lines are used on the checklists to indicate the beginning and ending of
optional provisions with subparagraphs or requirements that must all be adopted if the optional
provision is adopted.
DCWFLMJ.15 • R*viwd: 09/30/9*
Page 1 of 45 pm*** 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL flEOUMEMENTS
CHECKUST
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRW-
GENT
BROADER
IN SCOPE
PART 260 - HAZARDOUS WASTE MANAGEMENT SYSTEM: GENERAL
SUBPART B - DEFINITIONS
DEFINITIONS
add "drip pad" in
alphabetical order
82
260.10
____ PART 261 - IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
SUBPART A - GENERAL ^^_____
1 EXCLUSIONS
Spent Wood Preserving Solutions and Wastewaters
add new paragraph
which excludes as a
solid waste spent
wood preserving
solutions that have
been reclaimed and
are reused for their
original intended
purpose
add new paragraph
which excludes as a
solid waste
wastewaters from
the wood preserving
process that have
been reclaimed and
are reused to treat
wood
82,92
92
261.4(a)(9)(i)
261 .4(a)(9Hii)
'•-
^1%,
(JB
^•T
2 HAZARDOUS WASTES FROM NON-SPECIFIC SOURCES
3 add the waste codes
"F032", "F034" and
"F035" in
alphanumeric order to
list as shown below:
82,t91,
t120
261.31(a)
,4s* —
Page 2 of 45
DCWPL84J.16 • RWM* O9/30/9*
Pnntad: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
j
CHECKLIST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
Industry and EPA
hazardous waste
No.
Hazardous waste
Hazard
code
F032
F034
F035
Waetewaters (except those that have not come into contact with process fT)
contaminants), process residuals, preservative drippage, and spent formulations from
wood preserving processes generated at plants that currently use or have previously
used ehlorophenolic formulations (except potentially cross-contaminated wastes that
have had the FO32 waste code deleted in accordance with I 261.36 of this chapter or
potentially cross-contaminated waetes that are otherwise currently regulated as
hazardous wastee (i.e., F034 or FO36), and where the generator does not resume or
initiate use of chlorophenolic formulations). This listing does not include K001 bottom
sediment sludge from the treatment of wastewater from wood preserving processes that
use creosote and/or pentacHorophenol.
Wastewatera (except those that have not come into contact with process (T)
contaminants), process residuals, preservative drippaga, and spent formulations from
wood preserving processes generated at plants that use creosote formulations. This
listing doee not include KOO1 bottom sediment sludge from the treatment of wastewater
from wood preserving processes that use creosote and/or pantachlorophenol.
Wastewaters (except those that have not coma into contact with process (T)
contaminants), process residuals, preservative drippaga, and spent formulations from
wood preserving processes generated at planta that use inorganic preservatives
containing arsenic or chromium. This listing does not include K001 bottom sediment
sludge from the treatment of wastswater from wood preserving processes that use
creoeote and/or pentachlorophenol.
remove the
administrative stay
addressed in
Footnote 1 of the
261.31 table
t91,120
261.31(a)/table
•
Page 3 of 45
DCWPL94J.15
09/30/94
Primed: 12/22/9*
-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
i
CHECKLIST
(MH£eOEUf*C
nCrWHuC
FEDERAL BOW CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUtV-
ALENT
LESS
STRIN-
GENT
MORE
STUN-
GENT
BROADER
IN SCOPE
DELETION OF CERTAIN HAZARDOUS WASTE CODES FOLLOWING EQUIPMENT CLEANING AND
REPLACEMENT
wastes from wood
preserving processes
at plants that do not
resume or initiate use
of chlorophenolic
preservatives will not
meet the listing
definition of F032
once the 261 .35(b)
and Cc) requirements
are met; wastes may
continue to meet
another hazardous
waste listing
description or exhibit
one or more
characteristics
generators must
either clean or replace
all specified process
equipment that may
have come into
contact with
chlorophenolic
formulations or
constituents
generators shall do
one of the following:
prepare and follow an
equipment cleaning
plan; clean equipment
in accordance with
261.35
82
82,92
82,92
92
261.35(a)
-
261.35(b)
261.35{b)(1)
261.35(b)(1)(i)
•
w
Page 4 of 45
DCWPLMJ.15 -R*va*d 09/30/9*
Pnnltd. 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
prepare and follow an
equipment
replacement plan;
replace equipment in
accordance with
261.35
6 document cleaning
and replacement in
accordance with
261.35, carried out
after termination of
use of chlorophenolic
preservatives
cleaning requirements
prepare and sign a
written equipment
cleaning plan that
describes:
equipment to be
cleaned
how equipment will
be cleaned
solvent to be used in
cleaning
how solvent rinses
will be tested
how cleaning
residues will be
disposed
equipment must be
cleaned as follows:
remove all visible
residues from process
equipment
CHECKLIST
REFERENCE
92
92
82,92
92
92
92
92
92
92
92
92
FEDERAL ROW CITATION
261.35(b)(1)(ii)
•v
261.35
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
rinse with appropriate
solvent until no dioxin
or dibenzofuran
detection in final
solvent rinse
analytical
requirements
test rinses as per
SW-846, Method
8290
"not detected*
defined
generator manages
cleaning process
residues as F032
waste
replacement
requirements
prepare and sign
written equipment
replacement plan that
describes:
equipment to be
replaced
how equipment will
be replaced
how equipment will
be disposed
generator must
manage discarded
equipment as F032
waste
documentat i
requirements
%
CHECKLIST
REFERENCE
92
92
92
92
92
82,92
92
92
92
92
92
92
FEDERAL HCRA CITATION
261 .35(b)(2)(ii)
(B)
261.35(bH2)(iii)
261.35{bH2){iii)
(A)
261 .35(b}(2)(iii)
(B)
261.35(b)(2)(iv)
261.35(b)(3)
261 .35{bH3)(i)
261.35(b)(3)(tHA)
261.35(b)(3)(i){B)
261.35(b)(3)(i)(C)
261 .35(b)(3)(ii)
26!.35(b)(4)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STHN-
GENT
BROADER
IN SCOPE
*-
Page 6 of 45
DCWFLMJ.15 • Rwwtf O9/3O/9*
Pnr*«a 12/22/9*
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUREMENTS
document previous
equipment cleaning
and/or replacement
performed in
accordance with
261.35 and occurred
after cessation of
chlorophenolic
preservative use
documentation that
must be maintained
as part of the
facility's operating
record
name and address of
the facility
formulations
previously used and
the date on which
their use ceased in
each process at the
plant
formulations currently
used in each process
at the plant
equipment cleaning or
replacement plan
name and address of
any persons who
conducted the
cleaning and
replacement
dates on which
cleaning and
replacement were
accomplished
i
CHECKUST
REFERENCE
92
82
82
82
82
82
82
82
FEDERAL RCRA CITATION
261.35(b)(4)(i)
261.35(c)
261.35(0(1)
261.35(0(2)
261.35(0(3)
261.35(0(4)
261.35(0(5)
261.35(0(6)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
AUENT
LESS
STRIN-
GENT
-
MORE
STRIN-
GENT
BROADER
IN SCOPE
Page 7 of 45
DCWPL94J.1S
09/30/94
Minted: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQINREMENTS
dates of sampling and
testing
description of sample
handling and
preparation
techniques
description of the
tests performed, the
date, and the results
of the tests
name and model
numbers of the
instrument(s) used in
performing the tests
QA/QC
documentation
signed certification
statement
f
CHECKLIST
MHM-gg».|MC
ncrwnwc
82
82
82
82
82
82
FEDERAL ROM CITATION
261.35
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
' as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
CHECKUST
ncBCacur*K
ncrcTicnivC
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
TABLE 1. - ANALYSIS METHODS FOR
ORGANIC CHEMICALS CONTAINED IN SW-846
Compound
Method No*.
. BanzoflO fluoranthana 8100,8250,8270.8310
APPENDIX VII TO PART 261
BASIS FOR LISTING HAZARDOUS WASTE
add "F032", "F034",
and "F035" to list in
alphanumeric order as
shown below:
82
Appendix VII
EPA hazardous Hazardous conatituanta
waata No. for which liatad
F032
F034
F035
Banz(a}anthracene, benzo(a)pyrana, dibanz(a.h)-anthracane, indano(1,2,3-od)pyrane,
pantachlorophanol, araanic, chromium, tetra-, panta-, haxa-, hoptachlorodibenzo-p-
dioxin*, tatra-, panta-, haxa-, haptachlorodibanzofurana.
Banz(a)anthracane, banzo{k)fluoranthena, banzo(a)pyrana, dibanz(a,h)anthracana,
indano(1,2,3-cd)pyrana, naphthalene, araanic, chromium.
Araanic, chromium, laad.
APPENDIX VIII TO PART 261
HAZARDOUS CONSTITUENTS
add the specified
hazardous
constituents in
alphabetical order as
shown below:
82
Appendix VIII
Page 9 of 45
DCWPL94J.1S - toviMd: 09/30/94
PiinMd: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL HEOUMEMENTS
CHECKLIST
•^V«V>MMh|Mg
wrwPiMC
FEDERAL RCHA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
CQUV
ALENT
LESS
STOW-
GENT
MORE
STHN-
GENT
BROADER
m SCOPE
Chwnieal
abstract*
CoffiiYion
abstract*
No.
Hazardoui
waste No.
B*nzo(k)fhioranth«fM
Some
207-O8-9
HdptcoNorodibamofuraiw .
HaptwNorodJbmzo-p-dimdn
PART 262 - STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE
SUBPART C - PRE-TRANSPORT REQUIREMENTS
7,8 ACCUMULATION TIME
the waste is placed:
in containers and
generator complies
with Subpart I of Part
265; and/or
in tanks and
generator complies
with Subpart J of
Part 265, except
265.197(c)and
265.200; and/or
on drip pads and
generator complies
with Subpart W of
Part 265 and
maintains following
records:
92 •
92
92
t82,92
262.34(a)(1)
262.34
-------
OSWER DIRECTIVE NO. 9541.OO-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
description of
procedures to ensure
all wastes are
removed from drip
pad and associated
collection system at
least once every 90
days
documentation of
each waste removal,
including quantity,
date and time of
removal; generator
exempt from
Subparts G and H of
Part 265, except
265.111 and
265.114
date each period of
accumulation begins
is marked and visible
;
CHECKLIST
REFERENCE
t82,92
T82,92
82,92
FEDERAL RCRA CITATION
262.34(a)UKiii)
(A)
262.34
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
COIMf. DLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
/
CHECKLIST
•MHP t*nf!+tt*fi
ncrcncnmi
FEDERAL RCflA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
FQUIV-
ALENT
LESS
STRM-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
10
SUBPART W - DRIP PADS
APPLICABILITY
Subpart W applies to
owners and operators
of facilities that use
new or existing drip
pads to convey
treated wood
drippage.
precipitation, and/or
surface water run-off
to an associated
collection system;
existing drip pads
defined; applicability
of 264.573(b)(3) leak
collection system
requirement
owner or operator of
certain drip pads
inside or under a
structure not subject
to 264.573(6} or
264.573(f)
regulations, as
appropriate
Subpart W
requirements not
applicable to
management of
infrequent, incidental
drippage in storage
yards provided:
82,92,
120
82,92
120
264.570{a)
264.570(b)
264.570(c)
^•t
J|
Page 12 of 45
DCWPWJ.15
RcviMd: 09/30/94
Printed: 12/22/9*
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
owner or operator
maintains and
complies with a
written contingency
plan describing how
owner or operator
will respond
immediately to
discharge of
infrequent and
incidental drippage;
at a minimum, what
the contingency plan
must describe
CHECKLIST
REFEREnCC
120
FEDERAL ROTA CITATION
264.570(0(1)
264.570(c)(1)(i)
264.570(c)(1)(ii)
264.570(0(1 )(iii)
264.570(c)(1)(iv)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
ASSESSMENT OF EXISTING DRIP PAD INTEGRITY
evaluation of existing
drip pads; by June 6,
1991, written
assessment obtained
and kept on file;
annual review.
update and
recertification
required until
264.573 standards
are met, except
264.573(b) standards
for liners and leak
detection systems
82,92,
120
264.571 (a)
Page 13 of 45
DCWPL94J.15 • RcviMd: 09/30/94
Print** 12/22/34
-------
OSWER DIRECTIVE NO. 9541 .OO-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL flEQU«B*NTS
development of
written plan for
upgrading, repairing
and modifying drip
pad to meet
264.573(b)
requirements;
submittal of plan to
Regional
Administrator no later
than 2 years before
completion of
modifications; written
plan documentation.
review and
certification
requirements
removed
submittal of required
drawings and
certification to
Regional
Administrator or
State Director upon
completion of all
upgrades, repairs.
and modifications
if drip pad found to
be leaking or unfit for
use, compliance with
264.573(m)
provisions or close
drip pad in
accordance with
264.575
CHECKLIST
REFERENCE
82,92,
120
82,120
82,92
82,92
.
FEDERAL RCM CITATION
- -
264.57 Kb)
264.57 1(b)(1)
264.57 1(b)(2)
264.57 1(b)(3)
264. 57 1(c)
.
264.571 (d)
ANALOGOUS STATE
CITATION
*
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
1
BROADER
IN SCOPE
11,
12
12
Page 14 of 45
OCWFIS4J.15
RcvMd 09/30/94
Print** 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
.-
CHECKLIST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
13 DESIGN AND INSTALLATION OF NEW DRIP PADS
owners and operators
of new drip pads
must ensure that the
pads are designed,
installed and operated
in accordance with
one of the following:
all of the
requirements of
264.573 (except
264.573(a)(4».
264.574 and
264.575
all of the
requirements of
264.573 (except
264.573(5)),
264.574 and
264.575
82,92,
120
120
120
264.572
264.572(8)
264.572(b)
13 DESIGN AND OPERATING REQUIREMENTS
drip pads must:
be constructed of
non-earthen
materials, excluding
wood and non-
structurally supported
asphalt
be sloped for free-
drainage to the
associated collection
system
have a curb or berm
around the perimeter
82,92
82,92
82,92
82,92
264.573(a)
264.573(a)(1)
264.573(a)(2)
264.573(8X3)
Page 15 of 45
DCWPL94J.15
ft«v«d: 09/3O/94
Wnttd: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
14, hydraulic conductivity
15, requirements;
1 6 maintain surface free
of cracks and gaps;
sealing material must
be chemically
compatible with
preservatives that
contact pad;
requirements apply to
existing drip pads and
drip pads of
owners/operators
electing to comply
with 264.572(a)
14 owner or operator
must obtain and keep
at the facility written
assessment of drip
pad certified by
independent qualified
registered engineer;
assessment must
attest to results of
evaluation;
assessment must be
reviewed, updated
and recertified
annually; evaluation
must document
extent to which drip
pad meets 264.573
(except 264.573(b))
design and operating
standards
1 7 remove notes
regarding
administrative stays
for new and existing
drip pads
**
CHECKLIST
REFERENCE
82,92,
120
^
120
t91,92.
t101.
120
FEDERAL RCRA CITATION
264.573(a)(4)(i)
•
264.573(a)(4)(ii)
264.573(a)(4)/
notes
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRM-
GENT
MORI
STHN-
GENT
BROADEN
IN SCOPE
_
A
w
A, —
Page 16 of 45
DCWFLMJ.15
09/30/94
PrinMd: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
18 be of sufficient
structural strength
and thickness to
meet specified
conditions
1 9 if owner/operator
elects to comply with
§ 264.572
264.573(b)(1)(iii)
264.573(b)(2)
264.573(b){2)(i)
264.573(b)(2)(i)
(A)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BAOAOER
IN SCOPE
Page 17 of 45
DCWFL94J.1S • RmiiMd 09/30/94
PnnMd 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REOMREMENTS
of sufficient strength
and thickness to
prevent collapse
designed and
operated to function
without clogging
through the
ischeduled closure of
the drip pad; and
designed to detect
drip pad failure or the
release of hazardous
waste or
accumulated liquid at
the earliest
practicable time
leakage collection
system immediately
above the liner
designed,
constructed,
maintained and
operated to collect
leakage from below
the drip pad; date,
time and quantity of
leakage collected
must be documented
in operating log
maintenance of drip
pads; note regarding
remedial action
convey, drain, and
collect liquid resulting
fror opage or
prec tion in order
to p M run-off
»
CHECKLIST
rMfrtiftiiiT
W^M umwc
82,92
82,92
82,92
120
82,92
82,92 ;
FEDERAL KM CITATION
264.573(b)(2)(i)
(B)
264.573(b)(2Kii)
264.573(b)(2)(iit)
264.573(b)(3)
264.573(0
264.573(d)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STUB*.
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
•
Page 18 of 45
DCWPL94J.1S
09/30194
Printed: 12/22/9*
-------
OSWER DIRECTIVE NO. 9641.00-21
; SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
run-on control system
requirements
run-off management
system requirements,
unless system is
protected by a
structure, as
described in
264.570(b)
evaluation of drip pad
for compliance with
264.573(aHf)
requirements; design
certification required
removal of drippage
and accumulated
precipitation from
associated collection
system as necessary
to prevent overflow
onto the drip pad
thorough cleaning of
drip pad surface in a
manner and
frequency to meet
specified conditions;
documentation of
date, time and
cleaning procedure in
facility's operating
log; owner/operator
must determine
whether residues are
hazardous under
262.11 and, if so,
manage them
according to Parts
261-268, 270 and
RCRA §3010
CHECXUST
REFERENCE
82,92
82,92
82,92
82,92
82,92,
120
.
FEDERAL ROW CITATION
264.573(e)
264.573(f)
264.573(g)
,
264.573(h)
.
264.573(0
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
m SCOPE
Page 19 of 45
DCWPL94J 15
RtvMd 09/30/94
Prnntdr 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
minimize tracking of
hazardous waste or
constituents off the
drip pad
after removal from
treatment vessel,
treated wood from
pressure and non-
pressure processes
must be held on pad
until drippage has
ceased;
documentation
required
collection and holding
unite for run-on and
run-off control
systems emptied or
otherwise managed
as soon as possible
after storms to
maintain design
capacity
throughout the active
life of the drip pad
and as specified in
the permit, repair of
detected condition
that may have caused
or has caused a
release of hazardous
waste within a
reasonable period of
time, in accordance
with the following
procedures:
CHECKLIST
REFERENCE
82,92
82,92
82,92
82,92
_
FEDERAL RCHA CITATION
264.573(j)
-
264.573(10
264.573(1)
264.573(m)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STUN-
GENT
,
1
MORE
STUN-
GENT
BROADER
IN SCOPE
t
1
>.
Page 20 of 45
DCWPLS4J.15 - RtvMd: 09/30/94
Pnm»d: 12/22/94
-------
OSWER DIRECTIVE NO.
9541 .00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
upon detection of a
condition that may
have caused or has
caused a release of
hazardous waste, the
owner must:
enter discovery in the
facility operating log
immediately remove
from service affected
portion of drip pad
determine steps to
repair drip pad and
clean up any leakage;
establish schedule for
repairs
notify Regional
Administrator within
24 hours after
discovery; provide
'written notice as
specified within 1 0
working days
review, determination
and notification by
Regional
Administrator
20 written notification to
Regional
Administrator and
certification of
compliance with
264.573(m){1){iv)
after repairs and
clean up
,*
CHECKLIST
REFERENCE
82,92
82,92
82,92
82,92
82,92
82,92
82,92
FEDERAL RCRA CITATION
264.573(m)(1)
264.573{m)(1)(i)
264.573(m)(1)(ii)
264.573(m)(1)(iii)
264.573(m)(1)
(iv)
264.573(m)(2)
264.573(m)(3)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STMM.
GENT
BROADER
IN SCOPE
Page 21 of 45
DCWL94J.1S . R.v
09/30/94
Printed: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
should a permit be
necessary. Regional
Administrator will
specify in the permit
all design and
operating practices
necessary to ensure
that 264.573
requirements are met
documentation in
operating log, as
specified, of past
operating and waste
handling practices
/
CHECKLIST
REFERENCE
82,92
82,92
FEDERAL RCHA CITATION
264.573(n)
264.573(0)
ANALOGOUS STATE
CITATION
•
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
13 INSPECTIONS
inspection of liners
and cover systems
for uniformity.
damage and
imperfections during
construction or
installation;
inspection and
certification of liners
to meet 264.573
requirements;
maintenance of
certification as part
of the facility
operating record;
inspection of liners
and covers after
installation
drip pad must be
inspected weekly and
after storms to detect
evidence of any of
the following:
82,92
82,92
264.574(a)
264.574(b)
*
•^a^f
-
___,
Page 22 of 45
DCWFLS4J.1S
Ftovind: O9/3O/S4
Printed: 12/22/84
-------
OSWER DIRECTIVE NO. 9841.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
deterioration,
malfunctions or
improper operation of
run-on and run-off
control systems
presence of leakage
in and proper
functioning of leak
detection system
deterioration or
cracking of drip pad
surface; note
regarding remedial
action
. CHECKLIST
REFERENCE
82,92
82,92
82,92
--
FEDERAL RCRA CITATION
264.574(b)(1)
264.574(b)(2)
264.574(b)(3)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
13 CLOSURE
at closure, removal
and decontamination
requirements;
management as
hazardous waste
conditions under
which owner or
operator must close
facility and perform
post-closure care in
accordance with
264.310
requirements; for
permitted units.
permit requirement
continues throughout
post-closure period;
drip pad is considered
a landfill and must
meet Subparts G and
H requirements of
Part 264
82,92
-
82,92
264.575{a)
264.575(b>
Page 23 of 45
DCWPL94J 15
09/30/94
Pnm«d 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving L.-ngs
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
owner or operator of
an existing drip pad
that does not comply
with the 264.573(b)
(1) liner requirements
must:
include in closure
plans for drip pad
under 264.112, a
plan for 264.575O)
compliance and a
contingent plan for
264.575(b)
compliance
prepare a contingent
post-closure plan
under 264.1 18 for
complying with
264.575(b) in case
not air contaminated
subsoils can be
practicably removed
at closure
cost estimates
calculated under
264.1 12 and
264.144 for closure
and post-closure care
of drip pad subject to
264.575(c) must
include the cost of
complying with the
contingent closure
plan and the
contingent post-
closure plan; cost of
expected closure
under 264.575(a)
need not be included
'*
CHECKLIST
REFERENCE
82,92
82,92
82,92
82,92
FEDERAL RCRA CITATION
264.575(c)(1)
~
264.575(c)(1)(i)
264.575(cM1)(ii)
264.575(0(2)
ANALOGOUS STATE
CITATION
-
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
Jj^
•P
••^fl^^— ••-
Page 24 of 45
DCWPL94J.1S
09/30/94
Printed: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
CHECKLIST
REFERENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS.
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
PART 265 - INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS
WASTE TREATMENT. STORAGE AND DISPOSAL FACILITIES
SUBPART j - TANK SYSTEMS
APPLICABILITY
add reference to
paragraph
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERALflEOUREMENTS
owner or operator of
certain drip pads
inside or under a
structure not subject
to 265.443(6) or
26 5. 443 (f)
regulations, as
appropriate
Subpart W
requirements not
applicable to
management of
infrequent, incidental
drippage in storage
yards provided:
owner or operator
maintains and
complies with a
written contingency
plan describing how
owner or operator
will respond to
discharge of
infrequent and
incidental drippage;
at a minimum, what
the contingency plan
must describe
CHECKLIST
iMTfnfiiff
HKrKT^3*WC
82
120
120
FEDERAL RCRA CITATION
265.440{b)
265.440(0
265.440(cHD
265.440(c)(1)(i)
265.440(c)(1)(ii)
265.440(c)(1)(iii)
265.440(c)(l)
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30,1994 (cont'd)
FEDERAL REQUIREMENTS
f
CHECKLIST
rWnclnENCE
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
ASSESSMENT OF EXISTING DRIP PAD INTEGRITY
evaluation of existing
drip pads; by June 6,
1991, written
assessment obtained
and kept on file;
annual review.
update and
recertification
required until
265.443 standards
are met, except for
265.443(b) standards
for liners and leak
detection systems
development of
written plan for
upgrading, repairing
and modifying drip
pad to meet
265.443(b)
requirements;
submittal of plan to
Regional
Administrator no later
than 2 years before
completion of
modifications; written
plan documentation,
review and
certification
requirements
removed
82,120
82,120
82,120
•
265. 441 (a)
265.441(b)
265.441 (b)(1)
265.441 (b)(2)
265.441 (b)(3)
21
21
Page 27 of 45
DCWPL94J 15
R*vMd: 09/30/94
Pnnwd: 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
submittal of required
drawings and
certification to
Regional
Administrator or
State Director upon
completion of all
repairs and
modifications
if drip pad found to
be leaking or unfit for
use, comply with
265.443(m)
provisions or close
drip pad in
accordance with
265.445
^ ,
CHECKLIST
HfeHbHENCE
82
82
FEDERAL RCRA CITATION
265.441 (c)
265.441 (d)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
^k
DESIGN AND INSTALLATION OF NEW DRIP PADS
owners and operators
of new drip pads
must ensure that the
pads are designed,
installed and operated
in accordance with
one of the following:
all of the applicable
requirements of
265.443 (except
265.443(a>(4»,
265.444 and
265.445
all of the applicable
requirements of
265.443 (except
265.443{b»,
265.444 and
265.445
82,
120
120
120
265.442
265.442(3)
265.442(b)
Page 28 of 45
DCWFIS4J.1S -R*»**4: 09/30/94
12/22/94
-------
I
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
CHECKLIST
OCECBCWC
ncrwnirfC
r
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
DESIGN AND OPERATING REQUIREMENTS
22.
23
drip pads must:
be constructed of
non-earthen
materials, excluding
wood and. non-
structurally supported
asphalt
be sloped to free-
drain wastes to the
associated collection
system
have a curb or berm
around the perimeter
hydraulic conductivity
requirements;
maintain surface free
of cracks and gaps;
surface material must
be chemically
compatible with
preservatives that
contact pad;
requirements apply to
existing drip pads and
drip pads of owners/
operators electing to
comply with
265.442(a)
82
82
82
82
82,120
265.443(a)
265.443(a){1)
265.443(a)(2)
265.443(a)(3)
265.443(a)(4)(i)
•
Page 29 of 45
DCWPL94J.15
09/30/94
Print** 12/22/94
-------
OSWER DIRECTIVE NO. 9541 .OO-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
22 owner or operator
must obtain and keep
at the facility a
written assessment
of drip pad certified
by independent
qualified registered
engineer; assessment
must attest to results
of evaluation;
assessment must be
reviewed, updated
and recertified
annually; evaluation
must document
extent to which drip
pad meets 265.443 -
(except 265.443(b))
design and operating
standards
24 remove notes
regarding
administrative stays
for new and existing
drip pads
be of sufficient
structural strength
and thickness to
meet specified
conditions; note
regarding structural
integrity standards
25 if an owner/operator
elects to comply with
§ 2 6 5. 44 2 (b) instead
of § 265,442{a), the
drip pad must have:
/ ,
CHECKLIST
^BCEBCfcw
WrEJUlWC
120
t91.
t101,
120
82
82,120
'.-
FEDERAL RCHA CITATION
265.443(a)(4)(ii)
265.443(a)(4)/
notes
265.443(a)(5)
265. 443 (b)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STUN-
GENT
MORE
STNN-
GENT
BROADER
IN SCOPE
^
Page 30 of 45
DCWPLS4J.1S
09/30/94
12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL ACQUIREMENTS
a synthetic liner that
meets certain
specifications
specific requirements
for liner construction
materials
foundation or base
requirements
liner must cover all
surrounding earth
that could come into
contact with the
waste or leakage
leakage detection
system immediately
above the liner;
detection system
must be:
constructed of
materials that are:
chemically resistant
to relevant waste and
leakage
of sufficient strength
and thickness to
prevent collapse
designed and
operated to function
without clogging
through scheduled
drip pad closure
**
CHECKLIST
BKCBnj/*C
^ETC^KN4*C
82
82
82
82
82
82
82
82
92
FEDERAL ROW OTATtON
2 6 5. 44 3 (bid)
265.443(b)(1)(i)
265.443(b)(1)(ii)
265.443(bH1)(iii)
265,443(b)(2)
265.443(b)(2)(i)
265.443
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Vood Preserving Listings
as of June 30, ' 3*4 (cont'd)
FEDERAL REQUIREMENTS
26 designed to detect
the failure of the drip
pad or the presence
of hazardous waste
release or
accumulated liquid at
the earliest
practicable time
leakage collection
system immediately
above the liner
designed,
constructed,
maintained and
operated to collect
leakage from below
the drip pad for
removal; date, time
and quantity of
leakage collected
must be documented
in operating tog
maintenance of drip
pads; note regarding
remedial action
convey, drain, and
collect liquid resulting
from drippage or
precipitation in order
to prevent run-off
run-on control system
requirements, unless
drip pad is protected
by a structure, as
described in
265.440(b)
CHECKUST
REFERENCE
82,92
120 .
82
82
82
FEDERAL RCHA CITATION
265.443{b)(2Miii)
i
265.443(bH3)
265.443
-------
OSWEfl DIRECTIVE NO. 9541.OO-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
run-off management
system requirements,
unless drip pad is
protected by a
structure, as
described in
265.440
-------
OSWER DIRECTIVE NO. 9641.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REOUMEMENT8
after removal from
treatment vessel.
treated wood from
pressure and non-
pressure processes
must be held on pad
until drippage has
ceased;
documentation
required
collection and holding
units for run-on and
runoff control
systems emptied or
otherwise managed
as soon as possible
after storms to
maintain design
capacity
throughout the active
life of the drip pad
and as specified in
the permit, repair of
detected condition
that may have caused
or has caused a
release of hazardous
waste within a
reasonable period of
time, in accordance
with the following
procedures:
upon detection of a
condition that may
have caused or has
caused a release of
hazardous waste, the
owner must:
CHECKLIST
REFERENCE
82
-
82
82,92
82,92
FEDERAL RCRA CITATION
f
265.443(k)
265.443(1)
2 6 5. 443 (m)
265.443(m)(1)
ANALOGOUS STATE
CITATION
•
STATE ANALOG 1$:
EQUIV-
ALENT
LESS
STRIN-
GENT
-
MORE
STRW-
GENT
BROADER
M SCOPE
At
^^
Page 34 of 45
OCWFIMJ.IS
09/30/9*
Pnm«d 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REOUttEMENTS
entry of discovery in
the facility operating
log
immediate removal
from service of
affected portion of
drip pad
determination of
steps to repair drip
pad, remove any
leakage, and establish
schedule for clean up
and repairs
notify Regional
Administrator within
24 hours after
discovery; provide
written notice as
specified within 10
working days
review, determination
and notification by
Regional
Administrator
27 written notification to
Regional
Administrator and
certification of
compliance with
265.443(m)(1)(iv)
after repairs and
clean up
documentation in
operating log, as
specified, of past
operating and waste
handling practices
/
CHECKLIST
BftEEQBM^C
ncrcivnitC
82
82
82
82
82
82,92
82
FEDERAL ROW CITATION
265.443(m)(1)(i)
265.443(m)(1)(ii)
265.443(m)(1)(iii)
265.443(m)(1)
(iv)
265.443(m)(2)
265.443(m)(3)
265.443(n)
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
*
Page 35 of 45
DCWPL94J.15 - RaviMd: 09/30/94
Printed: 12/22/84
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
CHECKLIST
BC^EBCUOC
rKrCnEra*c ,
FEDERAL RCRA CTTATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STHN-
GENT
MORE
STRIN-
GENT
BROADER
IN SCOPE
INSPECTIONS
inspection of liners
and cover systems
for uniformity.
damage and
imperfections during
construction or
installation;
inspection and
certification of liners
to meet 265.443
requirements;
maintenance of
certification as part
of the facility
operating record;
inspection of liners
and covers after
installation
drip pad must be
inspected weekly and
after storms to detect
evidence of any of
the following:
deterioration.
malfunctions or
improper operation of
run-on and run-off
control systems
presence of leakage
in and proper
functioning of leak
detection system
deterioration or
cracking of drip pad
surface; note
regarding remedial
action
82
•
82
82
82
82
-
265.444(a)
*
265.444(b)
265.444(bM1)
265.444(b)(2)
265.444(b)(3)
*
•m
Page 36 of 45
DCWL94J.16
09/3C/94
Pnntcd 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL REQUIREMENTS
.•
CHECKLIST
D£CRKfcH*C
^Ef UlUVvC
FEDERAL RCRA CITATION
ANALOGOUS STATE
CITATION
STATE ANALOG IS:
EQUIV-
ALENT
LESS
STRIN-
GENT
MORE
STAIN-
GENT
BflOADER
IN SCOPE
CLOSURE
at closure, removal
and decontamination
requirements;
management as
hazardous waste.
closure and post-
closure care of drip
pad as a landfill under
265.310, if some
contaminated
subsoils cannot be
removed or
decontaminated; for
permitted units,
permit requirement
continues throughout
post-closure period
owner or operator of
an existing drip pad
not in compliance
with the 265.443(b)
(1) liner requirements
must:
include in the closure
plan for the drip pad
under 265. 11 2, a
plan for 265.445(8)
compliance and a
contingent plan for
265.445(b)
compliance
82
82
82
82
265.445(a)
265.445(b)
265.445(C)(1)
265.445(0(1 )(i)
Page 37 of 45
DCWPL94J 15
FUvMd 09/30/94
Pnm«d 12/22/94
-------
OSWER DIRECTIVE NO. 9541.00-21
SPA 15
CONSOLIDATED CHECKLIST: Wood Preserving Listings
as of June 30, 1994 (cont'd)
FEDERAL flEOUKMBCTS
prepare contingent
post-ctosure plan .
under 265.118 for
complying with
265.445(b) in case
not all contaminated
subsoils can be
practicably removed
at closure
cost estimates
calculated under
265. 11 2 and
265.144 for closure
and post-closure care
of drip pad subject to
265.445(c) must
include cost of
complying with
contingent closure
plan and contingent
post-closure plan;
cost of expected
closure under
265.445(a} need not
be included
CHECKLIST
REF&ENCE
82
82
;
FEDERAL RCBA CITATION
265.445