Treated Wood Waste Workshop Slides - Department of Toxic ... · Department of Toxic Substances...

Department of Toxic Substances Department of Toxic Substances ControlControl 11

Treated Wood Waste Treated Wood Waste WorkshopWorkshop

Alternative Management Alternative Management StandardsStandards

March 16, 2006March 16, 2006


Treated Wood Waste (TWW)Treated Wood Waste (TWW)

Treated wood is wood that has been treated with Treated wood is wood that has been treated with a chemical preservative.a chemical preservative.

Preservatives are registered pursuant to the Preservatives are registered pursuant to the Federal Insecticide, Fungicide, and Rodenticide Federal Insecticide, Fungicide, and Rodenticide Act (FIFRA) and by the California Department of Act (FIFRA) and by the California Department of Pesticide Regulation.Pesticide Regulation.

Some commonly applied chemicals include Some commonly applied chemicals include creosote, pentachlorophenol, and chromated creosote, pentachlorophenol, and chromated copper arsenate (CCA).copper arsenate (CCA).


Sources of Treated Wood WasteSources of Treated Wood Waste

New Construction Demolition

Renovation

YardWaste


Hazardous WasteHazardous Waste

Assembly Bill 1353 addresses only TWW Assembly Bill 1353 addresses only TWW that is a hazardous wastethat is a hazardous waste

Most TWW exhibits hazardous Most TWW exhibits hazardous characteristics and is a hazardous waste characteristics and is a hazardous waste subject to California Hazardous Waste subject to California Hazardous Waste LawLaw

If TWW is not a hazardous waste, none of If TWW is not a hazardous waste, none of this appliesthis applies


Hazardous WasteHazardous WasteHazardous waste Hazardous waste findingsfindings

CCA fails TCLP for CCA fails TCLP for metalsmetals

Total concentration of Total concentration of pentachlorophenol pentachlorophenol fails toxicity testingfails toxicity testing

Creosote analysis is Creosote analysis is not consistentnot consistent


Special TWW ProvisionsSpecial TWW Provisions

Conditional exemption for TWW removed Conditional exemption for TWW removed from electric, gas, or telephone servicefrom electric, gas, or telephone service

These proposed regulations for alternative These proposed regulations for alternative management of TWW when managed in management of TWW when managed in accordance with specified standards accordance with specified standards


HSC 25150.7 HSC 25150.7 Defines Treated Wood Waste (b) & (c)Defines Treated Wood Waste (b) & (c)Conditionally exempts TWW from Conditionally exempts TWW from hazardous waste laws until January 1, hazardous waste laws until January 1, 2007 (e)2007 (e)Established requirements for wholesale Established requirements for wholesale and retail of Treated Wood products (f)and retail of Treated Wood products (f)Voids all DTSC variances for TWW (i)Voids all DTSC variances for TWW (i)


HSC 25150.7HSC 25150.7TWW must be disposed to a Class 1 TWW must be disposed to a Class 1 hazardous waste landfill or a compositehazardous waste landfill or a composite--lined landfill (d)lined landfill (d)Mandates that DTSC adopt regulations for Mandates that DTSC adopt regulations for TWW Alternative Standards (g)TWW Alternative Standards (g)Allows generators to comply either with Allows generators to comply either with TWW Alternative Standards or hazardous TWW Alternative Standards or hazardous waste laws (h)waste laws (h)This law sunsets June 1, 2012 (l)This law sunsets June 1, 2012 (l)


HSC 25150.7(g) HSC 25150.7(g) TWW Alternative Standards shallTWW Alternative Standards shall

address storage, treatment, transportation, address storage, treatment, transportation, tracking, disposal to the extent practicaltracking, disposal to the extent practicalprevent releases of hazardous constituentsprevent releases of hazardous constituentsprevent scavenging prevent scavenging prevent harmful exposure to people, aquatic life, prevent harmful exposure to people, aquatic life, and animals and animals prevent reuse unless is a FIFRA prevent reuse unless is a FIFRA ““approved useapproved use””must ensure employees trainingmust ensure employees trainingsize reduction conducted safely to prevent size reduction conducted safely to prevent releasesreleasessawdust and other particles must be captured sawdust and other particles must be captured and managed as TWWand managed as TWW


TWW Alternative StandardsTWW Alternative StandardsScope and ApplicabilityScope and Applicability

Alternative management standards shall Alternative management standards shall apply only to TWW that is:apply only to TWW that is:

nonnon-- RCRARCRAhazardous solely due to preservatives hazardous solely due to preservatives

regulated under FIFRAregulated under FIFRAnot subject to utility service exemptionnot subject to utility service exemption

Is the applicability consistent with Health and Is the applicability consistent with Health and Safety Code section 25150.7?Safety Code section 25150.7?


TWW Alternative StandardsTWW Alternative StandardsProhibited ActivitiesProhibited Activities

TWW managed under the alternative management TWW managed under the alternative management standards shall not be:standards shall not be:

BurnedBurnedScavengedScavengedStored in contact with the groundStored in contact with the groundDisposed, treated, or reused except as specifiedDisposed, treated, or reused except as specified

Are the prohibited activities consistent with Are the prohibited activities consistent with Health and Safety Code section 25150.7? Health and Safety Code section 25150.7?


TWW Alternative StandardsTWW Alternative StandardsDefinitionsDefinitions

““AgentAgent””““ResizingResizing””““Treated woodTreated wood””““TWWTWW””““TWW consolidation siteTWW consolidation site””““TWW remote siteTWW remote site””““UnitUnit””

Are other definitions needed?Are other definitions needed?


TWW Alternative Standards TWW Alternative Standards LabelingLabeling

The person in control of TWW shall ensure The person in control of TWW shall ensure that each unit of TWW is labeled as that each unit of TWW is labeled as specifiedspecified

Label must be applied on the first day of Label must be applied on the first day of generation/accumulationgeneration/accumulation

Name, address, date that generation/ Name, address, date that generation/ accumulation commenced, and manifest accumulation commenced, and manifest number on each labelnumber on each label


TWW Alternative Standards TWW Alternative Standards LabelingLabeling

Should label specifications be included such Should label specifications be included such as font, label size color, etc.?as font, label size color, etc.?

Should additional warnings or prohibited Should additional warnings or prohibited activities be included on the label?activities be included on the label?

Is there alternative method to communicate Is there alternative method to communicate this information? this information?


TWW Alternative StandardsTWW Alternative StandardsAccumulationAccumulation

Releases to environment are prevented to Releases to environment are prevented to the extent practicalthe extent practicalAccess is controlled Access is controlled Accumulation limited to 90 daysAccumulation limited to 90 daysSelf inspection requiredSelf inspection requiredGenerator may hire another party if both Generator may hire another party if both comply with standardscomply with standardsBusinesses handling TWW have additional Businesses handling TWW have additional requirementsrequirements



block & tarp (elevate )containerize

storage buildingcontainment pad

(surface)



How is TWW being currently managed to meet the How is TWW being currently managed to meet the statutory requirement: statutory requirement: ““prevent runprevent run--on, and runon, and run--offoff””, , ““placed on a surface sufficiently impervious to prevent placed on a surface sufficiently impervious to prevent contact and any leaching to soil or watercontact and any leaching to soil or water”” ““to the to the extent practicalextent practical””??

Are there other options that should be included in Are there other options that should be included in subsection 67386.6(a)(2)?subsection 67386.6(a)(2)?

Does the 90 days in subsection (c) provide adequate Does the 90 days in subsection (c) provide adequate time for the accumulation of TWW?time for the accumulation of TWW?

Should we revert to a performance standard based on Should we revert to a performance standard based on the statutory language?the statutory language?


TWW Alternative StandardsTWW Alternative StandardsTrainingTraining

A business handling TWW shall provide A business handling TWW shall provide training to employees that includes:training to employees that includes:

Safe handling practicesSafe handling practices

Requirements of the alternative Requirements of the alternative management standardsmanagement standards

All applicable CalOSHA requirementsAll applicable CalOSHA requirements


TWW Alternative StandardsTWW Alternative StandardsTrainingTraining

AB 1353 LanguageAB 1353 LanguageIdentifying & Identifying & Segregating Segregating –– generator knowledgegenerator knowledge–– dedicated loadsdedicated loads–– tagstags

Very difficult to separate Very difficult to separate TWW once at a landfillTWW once at a landfill


TWW Alternative StandardsTWW Alternative StandardsTransportation: GeneratorsTransportation: Generators

A person who generates TWW and offers for A person who generates TWW and offers for transport:transport:

Shall obtain an EPA identification NumberShall obtain an EPA identification NumberShall use a hazardous waste manifestShall use a hazardous waste manifestMay consolidate from offsiteMay consolidate from offsiteMay hire another party (agent) who then shares the May hire another party (agent) who then shares the

generators responsibilitiesgenerators responsibilities

Exemption: Household generated TWW may be Exemption: Household generated TWW may be transported by a resident without a hazardous transported by a resident without a hazardous waste manifestwaste manifest


TWW Alternative StandardsTWW Alternative StandardsTransportationTransportation: Transporter: Transporter

A person transporting TWW shall:A person transporting TWW shall:

Be a registered hazardous waste transporterBe a registered hazardous waste transporter

Use a hazardous waste manifestUse a hazardous waste manifest

Comply with hazardous waste discharge Comply with hazardous waste discharge requirementsrequirements

Use a TWW consolidated manifest to collect Use a TWW consolidated manifest to collect from multiple generatorsfrom multiple generators


TWW Alternative StandardsTWW Alternative StandardsTransportation: LandfillsTransportation: Landfills

Should Material Recycling Should Material Recycling Facilities (Facilities (MRFsMRFs) be ) be allowed to accept TWW?allowed to accept TWW?Procedures/paperwork?Procedures/paperwork?Issues: legal, land use, Issues: legal, land use, permitting?permitting?

A landfill receiving TWW shall:A landfill receiving TWW shall:Use a hazardous waste manifestUse a hazardous waste manifestReport hazardous waste manifest discrepanciesReport hazardous waste manifest discrepancies


TWW Alternative StandardsTWW Alternative StandardsTransportationTransportation

Would alternative tracking mechanisms such Would alternative tracking mechanisms such as asbestos waste shipment records, or the as asbestos waste shipment records, or the used/waste tire manifest program be used/waste tire manifest program be appropriate for TWW?appropriate for TWW?

Describe how the generator and DTSC will be Describe how the generator and DTSC will be assured that treated wood waste was properly assured that treated wood waste was properly disposed?disposed?


TWW Alternative StandardsTWW Alternative StandardsTreatmentTreatment

Resizing and sorting/segregation are the only Resizing and sorting/segregation are the only treatment options approved as an alternative treatment options approved as an alternative management standard management standard

All other treatment of TWW must be approved in All other treatment of TWW must be approved in accordance with hazardous waste lawaccordance with hazardous waste law

When resizing, all sawdust and other particles When resizing, all sawdust and other particles must be collected and managed as TWWmust be collected and managed as TWW

Businesses treating TWW have additional Businesses treating TWW have additional training requirementstraining requirements


TWW Alternative StandardsTWW Alternative StandardsTreatmentTreatment

Is there a better method to determine what Is there a better method to determine what should be containerize in subsection (a)(2)?should be containerize in subsection (a)(2)?

What other physical activities may be What other physical activities may be necessary to facilitate the disposal of TWW?necessary to facilitate the disposal of TWW?


TWW Alternative StandardsTWW Alternative StandardsDisposalDisposal

All TWW must be disposed:All TWW must be disposed:to a hazardous waste landfill, orto a hazardous waste landfill, or

to a compositeto a composite--lined solid waste landfilllined solid waste landfill

TWW becomes solid waste if it is accepted TWW becomes solid waste if it is accepted by a landfill meeting specific requirementsby a landfill meeting specific requirements

Are the disposal requirements consistent with Are the disposal requirements consistent with Health and Safety Code section 25150.7?Health and Safety Code section 25150.7?


Additional Landfill RequirementsAdditional Landfill Requirements25150.825150.8


Additional Landfill RequirementsAdditional Landfill Requirements25150.825150.8

Provision does not sunset on 6/1/2012Provision does not sunset on 6/1/2012Landfill meets requirements under Water CodeLandfill meets requirements under Water CodeLandfill shallLandfill shall

Prevent scavengingPrevent scavengingEnsures compliance with hazardous waste laws or Ensures compliance with hazardous waste laws or these alternative standardsthese alternative standardsIf monitoring indicates a release, TWW is not longer If monitoring indicates a release, TWW is not longer placed in landfill until the release is stoppedplaced in landfill until the release is stopped


Draft TimelineDraft Timeline

Public workshopsPublic workshopsComments dueComments duePossible additional Possible additional workshopworkshopOAL submittalOAL submittal

Implementation dateImplementation date

March 16, 2006March 16, 2006March 30, 2006March 30, 2006

TBDTBDSeptember 20, 2006September 20, 2006

January 1, 2007January 1, 2007


ConclusionsConclusionsHSC HSC §§25150.7 requires DTSC to develop 25150.7 requires DTSC to develop alternative management standards by alternative management standards by January 1, 2007January 1, 2007

HSC HSC §§25150.7 places many restrictions 25150.7 places many restrictions on the form and content of the alternative on the form and content of the alternative management standardsmanagement standards

Short timeline, Short timeline, INPUT NEEDEDINPUT NEEDED

Comments due by March 30, 2006Comments due by March 30, 2006


ContactsContacts

Edward NietoEdward Nieto (916) 322(916) [email protected]@dtsc.ca.gov

Evelia RodriguezEvelia Rodriguez (916) 322(916) [email protected]@dtsc.ca.gov

William BeckmanWilliam Beckman (916) 324(916) [email protected]@dtsc.ca.gov

mailto:[email protected]



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