oEPA
United States
Environmental Protection
Agency
Office of
Solid Waste and
Emergency Response
DIRECTIVE NUMBER. 9502.02(35)
TITLE: Regulation of Wood Treatment Plant Drip Areas as
SWMUs
APPROVAL DATE: 6-17-85
EFFECTIVE DATE: 6-17-85
ORIGINATING OFFICE: office of Solid Waste
Q FINAL
D DRAFT
STATUS:
REFERENCE (other documents)
] A- Pending OMB approval
B- Pending AA-OSWER approval
C- For review &/or comment
D- In development or circulating
headquarters
OSWER OSWER OSWER
VE DIRECTIVE DIRECTIVE Dl
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CORRECTIVE ACTION 9502.02(85)
Key Words: Wood Preservatives, Corrective Action, SWMUs
Regulations: 40 CFR 261.33
Subject: Regulation of Wood Treatment Plant Drip Areas as SWMUs
Addressee: James C. Scarbrough, Chief Residuals Management Branch
Region IV
Originator: John Skinner, Director Office of Solid Waste
Source Doc: #9502.02(85)
Date: 6-17-85
Summary:
This memo states that ground areas at a wood treatment plant that receive
drippage from the treated wood are solid waste management units and therefore
subject to the continuing release and interim status corrective action order *
requirements of the 1984 RCRA Amendments.
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JWK7I985 '502.02 <85)
"Regulation of Wood Treatment Plant Drip Areas as Solid Waste
Management .Units
John Skinner, Director
Office of Solid Waste
James C. Scarbrough, Chief
Residuals Management Branch, Region IV
In your April 23, 1985, memo, you asked whether the ground
areas at a wood treatment plant that receive drippage from the
treated wood are solid waste management units and, therefore,
subject to the continuing release provisions of HtfSA. We
agree with you that these areas are solid waste management
units, subject to the continuing release and interim status
corrective action order requirements of the 1984 RCRA amendments.
As we understand the process, when the pressure treated
wood is removed from the treating cylinder, excess preservative
is forced out of the wood by the internal pressure still remaining
in the wood* This is commonly referred to as kick-back drippage.
The length of time over which drippage occurs varies from about
four to twenty-four hours, depending on the type of wood treated,
the series of pressure or vacuum treating cycles employed, and
the preservative solutions used. Often, a final vacuum is drawn
on the preserved wood which then delays the onset of this drippage
in by an hour or so after it is taken out of the pressure treating
^ cylinder.
o Although some of these residuals have been found to contain
£ significant concentrations of carcinogenic substances (such as
« chrysene and benso(a)pyrene), they are not currently classified
r-. as haxardous wastes under RCRA, either as discarded commercial
\ chemical products under Section 261.33 or otherwise as listed
;<£ or characteristic wastes. The Agency is now obtaining data to
tn determine whether these residuals should be listed alonq with
J3J other wastes from the wood preserving industry.
CN These, rstmiduals, however, are definitely solid wastes.
" Therefore, tfcer specif ic ground area that routinely receives
- this klcfc-teeJr drippage would be considered a "solid waste
co management vnlt* since it is a discrete area of the facility
* where waste* have been or are deliberately,""routinely, and
*J systematically placed or allowed to leak onto the land. The
•H unit is thus subject to the corrective action requirements of
H 30Q4(u), providing that the facility is seeking a RCRA permit.
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If th«- facility has int*ri» status but i« not se.kino a D«r»ife
•aforeswM^horiti** «nd.r Section 3008 (h) InTo?h.« c™
t* nqUir* n«c«...ry correct iv« maasure.?
X trust that this response is h«lpful to
saw it?: '
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JUAIJ4
RE: WIBCJ0277
MBMORAHDOM
SUBJECT: Regulatory status of wood preservative "Kickback"
emissions
FROMt John H. Skinner, Ph.D.
Director
Office of Solid Waste (WH 565)
TOt Elisabeth Maxwell
Assistant Regional Counsel
Region V
In a March 29, 1985 memo, you requested clarification of
the regulatory status of the ground area around tracks or
other areas outside of the immediate treating cylinder
Area where drippage collects from newly treated wood.!/
This area (referred to as the "kick-back drippacje area") is
a solid waste management unit, subject to the corrective
action requirements of the 1984 RCRA amendments .
As we understand the process, when the pressure treated
wood charge is removed from the treating cylinder, excess
preservative is forced out of the wood by the internal
pressure still remaining in the wood. This is commonly
referred to as kick-back drippage. Typically, a charge of
newly treated wood is allowed to rest in a specific area
while still loaded on the railroad platform car for some
time during this pressure equalisation process. In some
cases, this drippage may be partially collected in troughs
or sumps benes&h the tracks. The length of time over
which drippage; occurs varies from about four to twenty-£ our .
hours, depending on the type of wood treated; the aeries
of pressure or vacuum treating cycles employed, and the
preservative solutions used. Often, a final vacuum is
drawn on the preserved wood which then delays the onset of
this drippage by an hour or so after it is taken out of
the pressure treating cylinder.
i/ while the Agency has determined the status of this
area, we are currently evaluating other parts of wood
preserving plants to determine if these areas also
should b« classified as land-based units.
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At 3«rtp«rllood Piedmont** Waverly, ohio facility,
some of IflllgBpts'iiil is collected in troughs beside the
railroad trlppNU* periodically dredged oat manually.
Substantial msciUtSr however, also drip onto the ground.
Ths facility hassupplied analytical data demonstrating
significant cancestrations of carcinogenic substances in
these deposits (e.g., chrysene at 2500 pp» and b«nso(a)pyr«n«
at 730
Although these residuals are not currently classified
as hazardous wastes under RCRA, either as discarded ccswu»reial
chemical products under Section 261.33 or otherwise as a.
listed or characteristic wastes, the Agency is now obtaining
data to determine whether these residuals should be listed
along with other wastes from the wood preserving industry*
These residuals, however, are solid wastes. The specific
ground- ares which routinely receives this, kick-back drippage
would be considered a 'solid waste management unit," since
it is s discrete area of the facility/ where wastes have
been or ere.deliberately, routinely, and- systematically
placed or are allowed to leak onto the- land * The unit is
thus subject to the corrective action requirements of
3004(u), providing that the facility is seeking a RCBA
permit. If the facility has interim status but is not
seeking a permit, enforcement authorities under Section
300t.(h) and others can be~ used to require necessary corrective
sVeasures. ,-"'" • '• ••-•••• •• •"-,..•• - • •••-..-
emit „ MgisoU Administrators'
.-:--.-- •• - legions! Branch Chiefs
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