Treated Wood Waste Treated Wood Waste Workshop Workshop Alternative Management Alternative Management Standards Standards March 16, 2006 March 16, 2006 Department of Toxic Substances Department of Toxic Substances Control 1 1 Control
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). Department of Toxic Substances Department of Toxic Substances Control 2 2 Control
Sources of Treated Wood Waste Sources of Treated Wood Waste Renovation Yard Waste New Construction Demolition Department of Toxic Substances Department of Toxic Substances Control 3 3 Control
Hazardous Waste Hazardous Waste � Assembly Bill 1353 addresses only TWW � Assembly Bill 1353 addresses only TWW that is a hazardous waste that 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 Law Law � If TWW is not a hazardous waste, none of � If TWW is not a hazardous waste, none of this applies this applies Department of Toxic Substances Department of Toxic Substances Control 4 4 Control
Hazardous Waste Hazardous Waste � Hazardous waste � Hazardous waste findings findings � CCA fails TCLP for � CCA fails TCLP for metals metals � Total concentration of � Total concentration of pentachlorophenol pentachlorophenol fails toxicity testing fails toxicity testing � Creosote analysis is � Creosote analysis is not consistent not consistent Department of Toxic Substances Department of Toxic Substances Control 5 5 Control
Special TWW Provisions Special TWW Provisions � Conditional exemption for TWW removed � Conditional exemption for TWW removed from electric, gas, or telephone service from 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 Department of Toxic Substances Department of Toxic Substances Control 6 6 Control
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) Department of Toxic Substances Department of Toxic Substances Control 7 7 Control
HSC 25150.7 HSC 25150.7 � TWW must be disposed to a Class 1 � TWW must be disposed to a Class 1 hazardous waste landfill or a composite- - hazardous 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) Department of Toxic Substances Department of Toxic Substances Control 8 8 Control
HSC 25150.7(g) HSC 25150.7(g) TWW Alternative Standards shall TWW Alternative Standards shall � address storage, treatment, transportation, � address storage, treatment, transportation, tracking, disposal to the extent practical tracking, disposal to the extent practical � prevent releases of hazardous constituents � prevent releases of hazardous constituents � prevent 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 use approved use” ” � must ensure employees training � must ensure employees training � size reduction conducted safely to prevent � size reduction conducted safely to prevent releases releases � sawdust and other particles must be captured � sawdust and other particles must be captured and managed as TWW and managed as TWW Department of Toxic Substances Department of Toxic Substances Control 9 9 Control
TWW Alternative Standards TWW Alternative Standards Scope and Applicability Scope and Applicability Alternative management standards shall Alternative management standards shall apply only to TWW that is: apply only to TWW that is: � non � non- - RCRA RCRA � hazardous solely due to preservatives � hazardous solely due to preservatives regulated under FIFRA regulated under FIFRA � not subject to utility service exemption � not 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? Department of Toxic Substances Department of Toxic Substances Control 10 10 Control
TWW Alternative Standards TWW Alternative Standards Prohibited Activities Prohibited Activities TWW managed under the alternative management TWW managed under the alternative management standards shall not be: standards shall not be: � Burned � Burned � Scavenged � Scavenged � Stored in contact with the ground � Stored in contact with the ground � Disposed, treated, or reused except as specified � Disposed, 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? Department of Toxic Substances Department of Toxic Substances Control 11 11 Control
TWW Alternative Standards TWW Alternative Standards Definitions Definitions � “ � “Agent Agent” ” � “ � “Resizing Resizing” ” � “ � “Treated wood Treated wood” ” � “ � “TWW TWW” ” � “ � “TWW consolidation site TWW consolidation site” ” � “ � “TWW remote site TWW remote site” ” � “ � “Unit Unit” ” Are other definitions needed? Are other definitions needed? Department of Toxic Substances Department of Toxic Substances Control 12 12 Control
TWW Alternative Standards TWW Alternative Standards Labeling Labeling 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 specified specified � Label must be applied on the first day of � Label must be applied on the first day of generation/accumulation generation/accumulation � Name, address, date that generation/ � Name, address, date that generation/ accumulation commenced, and manifest accumulation commenced, and manifest number on each label number on each label Department of Toxic Substances Department of Toxic Substances Control 13 13 Control
TWW Alternative Standards TWW Alternative Standards Labeling Labeling 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? Department of Toxic Substances Department of Toxic Substances Control 14 14 Control
TWW Alternative Standards TWW Alternative Standards Accumulation Accumulation � Releases to environment are prevented to � Releases to environment are prevented to the extent practical the extent practical � Access is controlled � Access is controlled � Accumulation limited to 90 days � Accumulation limited to 90 days � Self inspection required � Self inspection required � Generator may hire another party if both � Generator may hire another party if both comply with standards comply with standards � Businesses handling TWW have additional � Businesses handling TWW have additional requirements requirements Department of Toxic Substances Department of Toxic Substances Control 15 15 Control
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