United States
Environmental Protection
Agency
Solid Waste and
Emergency Response
(OS-305)
EPA 530-F-93-006
April 1993
Office of Solid Waste
4ğERf\ Environmental
Fact Sheet
The Environmental Protection Agency (EPA) has proposed to list as
"hazardous' certain wastes from wood surface protection operations that
use protectant containing a concentration of pentachtorophermte greater
than 0.1 parts per million (ppm). EPA is requesting public comment on the
proposal.
Background
Freshly cut lumber is often treated with a surface protectant in
order to temporarily prevent sapstain. Some protectant formulations
used in the lumber Industry contain chlorophenolic chemicals. These
particular formulations and the wastes generated by their use in the
surface protection of lumber contain dioxin and furan impurities.' In
the past, chlorophenolic formulations were used quite extensively to
protect lumber. In January 1992, production of chlorophenolics ceased
and current use is diminishing.
The 1984 Hazardous and Solid Waste Amendments require EPA to
determine whether to designate, or list," these and other wastes as
hazardous, thereby subjecting them to the waste management regula-
tions under the Resource Conservation and Recovery Act (RCRA).
EPA has issued a Notice of Proposed Rulemaking to list as
hazardous those wastes from wood surface protection operations whose
protectant formulations have a concentration of pentachlorophenate
greater than 0.1 ppm. This proposed listing includes wastes from
plants that presently use non-chlorophenolic formulations, but whose
formulations have been contaminated by previous chorophenolic use.
WOOD SURFACE
PROTECTION WASTES
PROPOSED AS HAZARDOUS
Action

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The proposed listing includes the following wastestreams: 1) any
wastewaters generated which contact protectant, 2) process residuals,
3) protectant drippage, and 4) spent formulations.
For plants using formulations containing more than 0.1 ppm
pentachlorophenate. EPA has proposed recordkeeping requirements, a
requirement to hold treated wood in the process area to allow excess
drippage of surface protectant to cease, and standards for the storage
of treated lumber in uncovered storage areas during precipitation
events
The notice also proposes testing, analysis, and recordkeeping
requirements for operators using a protectant containing less than or
equal to 0.1 ppm pentachlorophenate. Related to the testing
requirement, EPA has proposed to amend document SW-846, Test
Methods for Evaluating Solid Waste, Physical/Chemical Methods, to
include a method for detecting pentachlorophenate.
EPA is requesting public comment on this proposed rule, including
the option not to list these wastes as hazardous. The "no-list" option is
being considered because future generation of these wastes is expected
to rapidly diminish and risk analyses have shown that risk from
certain exposure pathways is relatively low, assuming the use of
chlorophenolics does not resume.
Public Comment
Comments should be submitted to EPA within 60 days of the
Federal Register notice publication date. No extensions will be
granted. For instuctions on submitting written comments, please see
the Federal Register notice. It Is available at no charge by calling the
RCRA Hotline or by visiting EPA's RCRA Information Center in
Washington, D.C.
Contact
For further information, or to order a copy of the Federal Register
notice, please call the RCRA Hotline Monday through Friday, 8:30 a.m.
to 7:30 p.m., EST. The national toll-free number is (800) 424-9346; for
the hearing impaired, it is (TDD) (800) 553-7672. In Washington, D.C..
the number is (703) 412-9810 or TOD (703) 412-3323. Or write to:
RCRA Information Center, Office of Solid Waste (OS-305), U.S. EPA,
401 M Street SW, Washington, D.C. 20460.

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