v>EPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.02(85)
TITLE: Applicability of Che RCRA Dioxin Listings Published in the
Federal Register on January 14, 1985, to Wastes from Wood
Preserving Processes Using Pentachlorophenol
APPROVAL DATE: 3-4-85
EFFECTIVE DATE: 3-4-85
ORIGINATING OFFICE:
0 FINAL
of Solid Waste
D DRAFT
STATUS:
[ ] A- Pending OMB approval
{ j B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- .In development or circulating
headquarters
REFERENCE (other documents):
OSWER OSWER OSWER
(E DIRECTIVE DIRECTIVE
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261 SUBPART D - LISTS
DOC: 9444.02(85)
Key Words:
Regulations:
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Dioxin, Listing, Wood Preserving
Applicability of the RCRA Dioxin Listings Published in the
Federal Register on January 14, 1985, to Wastes from Wood
Preserving Processes Using Pentachlorophenol
Walter. G. Talarek, American Wood Preservers Institute
1945 Gallows Road, Vienna, VA 22180
John H. Skinner, Director, Office of Solid Waste
#9444.02(85)
3-4-85
The hazardous waste listings related to pentachlorophenol promulgated on
January 14, 1985 (F021, F027, and F028), are not typically generated by the wood
preserving industry. The final dioxin rule therefore does not generally include
wastes by the wood preserving industry. Wood treatment facilities could be
covered under uhe dioxin regulations if a wood preserving facility:
makes
F021;
a derivative of pentachlorophenol: • the resulting waste would be
o makes formulations containing tri-, tetra-, or pentachlorophenol or its
derivatives: the resulting waste would be F021;
o discards unused formulations containing tri-, tetra-, or pentachloro-
phenol or its derivative: the waste would be F027.
The Agency is currently investigating whether wastes resulting from wood
preserving processes using pentachlorophenol should be listed as hazardous (or
acute hazardous) wastes and whether CDDs and CUFs should be added as consti-
tuents of concern in the wood preservation process waste already listed (K001).
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9444.02 (35
O *
CD S
« I
I W
MAR 4. 1985 *|
-.--•--. • 0 C-
Walter C. Talarek - nn
American Mood Preserrers Institute _ £
1945 Gallows Road > -
Vienna, Virginia 22180 3\
- 73
• ' . ®
Dear Mr. Talarext • -• • — ... - • • * u,^
(j\ •*.
This letter is in response to your letter dated February 14, ^ ^
1985 in which you request clarification of the dioxin listing; w '
In particular, you asked for comment regarding the applicability S
of the RCRA dioxin listings published in the Federal Register £
oa January 14, 1985 to waste* fro* wood preserving processes •'•-' -- \
using pentachlorophenol. V
. ^.. _ .-.;..,... _. . . NJ
- ::. --(.---.,-.-. -r..,-:-- ^ ar- • • — ......— • . - . - |—
As you state in your letter, the following hazardous ^
waste listings relating to pentachlorophenol were promulgated 01
on January 14, 1985i . ^
• P021t Wastes (except wastewater and spent carbon froa x-
hydrogen chloride purification) from the production or c,
•anufacturing use (as a reactant, chemical intermediate, =
or ooaponent in a formulating process) of pentachlorophenol, «•
or of intermediates used to produce its derivatives (B) 2
KJ
H^
• r027s Discarded unused formulations containing
tri-, tetra-, or pentachlorophenol or discarded unused
formulations containing compounds derived froa these
chlorophenols... (U)
• P028» Residues resulting from the incineration
or thermal treatment of soil contaminated with BPA
Hazardous Waste Nos. P020, F021, P022, r023, P026, and
P027 . (T)
(Please note that, contrary to the statement in your
letter, the latter is a 'T* not "H" waste.)
Most of these wastes are not typically generated by the
wood preserving industry. Me, therefore, generally agree
with your assessment that the final dioxin rule (published
on January 14, 198S) does not include wastes by the wood
preserving industry. However, wood treatment facilities
could be covered under the listing ift
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.
wood, preserving facility sutkee e
?T<»f oehtachlorophendl (e. q• V a eodio» or potas'aitm &~
•alt) i the waatea reeulting frooi such a process would
pr«a«nrln^ facility aak«a formal*tlona --_•:;: —-.
containing tri-»» tatra-, or pentachlorophanbl or its
tf«riTata«i vast* resulting fro* auch a proca«a) would
b« P021 waataa. . .
A wood preserving facility diacarda unused forsmlationa
containing tri-, tetra-, or pentachlorophenol or ita
'derivatives) these would be EPA hasardoua waate' •-"-—'••"••'•
90. F027.- -
fxirthermora, although aoat of the vaatea generated by the
wood preserving industry are pro ably not regulated by-the •r-'-*'-t---
January 14fvrulea^king, you are aware that we are preaently
inTeatigating whether waatea reaulting fro* wood preserriag r-—'
processes using pentachlorophenol should be listed as hazardous
(or acute hasardoua) waatea, and whether CDDa end CDFa should ^r
be added aa conatituents of concern in the wood preservation .*
process waate already listed (EPA Basardous waste K001]. Jk«---
previoualy atated, we will take appropriate regulatory action
if warranted. • .- ^ - ... - ,-. : --.-:. .-...-,. : •. . 'v.-:.,'. j:.v -.;•
I trust that thia adequately addreaaes the concerna ' ,.
expressed in your letter. Please do not hesitate to call
Matt Straus, If you have further queationa concerning thia -•-
matter, Mr. Straus can be reached at (202) 475-8551.
- Sincerely fours, "
John H. Skinner
Director
Office of Solid Waste
ccf . Belli)
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