oEPA
United SIMM
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER: 9444.04(84)
TITLED Wastewater Treatment Sludges From Wood Preserving
Processes Using Creosote and/or Pentachlorophenol
APPROVAL DATE: 4-26-84
EFFECTIVE DATE: 4-26-84
ORIGINATING OFFICE: office of solid waste
CB FINAL
O DRAFT
STATUS: f I
{ ] A- Pending OMB approval
| ] B- Pending AA-OSWER approval
[ ] C- For review &/or comment
[ ] D- In development or circulating
REFERENCE (other documents):
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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PART 261 SUBPART D - LISTS
DOC: 9444.04(84)
Key Words: Wood Preserving, Wastewater treatment
•»-••—
Regulations: 40 CFR 261
Subject:
Addressee:
Originator:
Source Doc:
Date:
Summary:
Wastewater Treatment Sludges From Wood Preserving Processes
Using Creosote and/or Pentachlorophenol
Dave Dolan, Environmental Scientist, Waste Management Branch,
Region V
Gate Jenkins, Waste Identification Branch, Characterization
and Assessment Division
#9444.04(84)
4-26-84
During any wood preserving processes using creosote and/or pentachloro-
phenol, K001 wastewater treatment sludges are generated from 1) oil/water
separation, including any mechanical oil/water separation device; and 2)
thermal evaporation of wastewater.
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9444.04 (84)
APR 26 1984
Dave Dolan ' •-.* :•
Environmental Scientist
Waste Management Branch
Region V rviiV..*- ;<.tv, .'
U.S. Environmental Protection Agency
230 S. Dearborn Street --y «->-.-•
Chicago, IL 60604 » v^r-n.-ic i:..;.
Dear Dave:
• "'>*. ^ _. __- . . - - - •• •
As a result of several inquiries, we wish to clarify which
wastes generated by Bell Lumber and Pole, located in New Brighton/
Minnesota, are listed as hazardous under Part 261 of the hazardous
waste regulations implementing the Resource Conservation and
Recovery Act. At the present time, one category of wastes from
the wood preserving industry is included as a hazardous waste
from a specific source; K001 "Bottom sediaent sludge from the r~
treatment of wastewaters from wood preserving processed that use
creosote and/or pentachlorophenol*. -.--••• — .- - -,. •- --.--.
Prom process descriptions compiled by the Minnesota pollution
Control Agency, the National Institute of Occupational Saftey
and Health, and Region V during a recent plant site visit, the
following is my understanding of the current and past wasta
generation points at the Bell Lumber and Pole facility. - • i
1. Work tank/storage tank sludges. These sludges accumulate
at the bottom of vertical storage tanks for presevativw x
.solutions of pentachlorophenol. : In the past, these tanks'' " •
'.r may have been used for creosote preservative solutions. '"'''''
«•» These tanks receive reclaimed 'preservative solutions, store
ci i them, 'and in some cases' heat "the* reclaimed solutions prior '
to reuse in the wood treating tank. Currently, sludges
-Uthes* tanks ar« discharged tp7-the 'mechanical oil/water
-:»r. separator described below;;^> cAa:t t** -«^^v4.*^ A^^
-wi.*, .. ' • J
2. Mechanical oil/water separator sludges. Wastewater • _.;: __.
con tan in a ted by oil/oreservatlva -•
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discharged to a tank (31' x 6') where oil/water separation
takes place. This oil/water separation procedure treats
e*f fluent, gene rated after completetlon of the wood treating
''process. Although 'no' water is intentionally- added to this
process, a substantial amount 'of ' water is released from the
wood itself during hot' oil/preservative solution steeping.
Sone of this wastovater is emitted to the air as steam during
tha stooping process/ 'and acne is entrained in the preservative
solution or section co cna_ooctora oc tu<» wood cr^-c..;.., car.-;.
The first mechanical oil/water separation device was installed
in 1976 at "Tank 8". A steel belt oil/water separa tor /*-~- •
installed in 1980, is in current use and operated daily
-except when the ^weather is cold enough to freeze the water.
This oil/water separator daily recieves contaminated wastewater
•effluent directly from from the the treating tank. Approximately
one time. each year, bottoms from the storage/ work tanks'
are also added to the mechanical oil/water separator. '"*~10'"'"
. . _
-3. ^ Thermal dehydration/evaporation sludges. The bil/yreservativ
• solutions recovered by the mechanical oil/water separator
undergo a secondary wastewater treatment step by thermal
dehydration/evaporation. . This is currently conducted in
the ?Butt Treatment Tank". with heating coils, generating a
sludge. Other sludges may be added directly to this thermal
•dehydrator/evaporator. without first being subjected to _;^~
mechanical oil/water separation.' Thermal dehydration or "'
'evaporation of wastewater from wood preserving solutions
typically generates a sludge." - : --
•-;-
"
Before installation of the 'mechanical oil/water separation
devices, a thermal dehydration treatment was used as the
sole procedure for drying oil/preservative solutions from
the wood treating "tank. Fuel oil /used as the ^solvent for
^either creosote or "pen tachlorophenol, typically will entrain
"significant amounts of water during the wood treating process.
•- Entrained wastewater must be removed to regenerate dry
-oil/preservative solutions for good penetration Into the -
wood during the treating "process. - Thermal dehydration of
•'the used oil/preservative solutions in the past could be
assumed based on typical industrial process information,
with concomitant sludge generation. . . ,<.!" '
"*'
- From the above description of sludge generating processes,
: the mechanical oil/water separator'sludges and the thermal dehydrator
- sludges meet the K001 listing description of wastewater treatment
-sludges from wood preserving processes using creospte..and/qrj_
v'p«ntachlorophenol. -iIf .the atorag>Ttank/work t tank-sludge's/ «•„, „£.•
'mixed with.the mechanical"oil/water separator sludges_or\thermal
crdehydration/ .evaporation.!siudge*7; then 'the resulting rmlxture"w*-
^•also nust be .aanaged.as a KOOI*.'hazardous 'waste.*ciori prcci
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Page .21 of the Listing Background Document for'the Wood
Preserving'industry states "vaatewater treatment'sludges are
generated first at oil/water primary separation", 'which includes
any mechanical oil/water separation device as described for the
Bell Lumber ana Pole facility, as well as sludges from sur.je
tanks, drainage pits, etc. Cn page 21, dehydration of
oil/preservative go!-:-, icr.j a,u en pjg<3 2
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I hope this information is useful in evaluating the waste
sources pf groundwater contamination frota the landfill on the
Bell Lumber and Polo facility. 1C you have any further questions,
please do not hositate to call me.
Sincerely yours,
Gate Jenkins, Ph.D.
Waste Identification Branch (V«H 562)
Characterization and Assessment Division
cc: Matthew'A. Straus/osw
Pranc in*'Jaco f f/OSW
Steve Silverman/OGC
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