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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