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

UCHWAGUCHWAG

May 30, 2008May 30, 2008

Alternative Management Alternative Management StandardsStandards

Less regulated than Haz Wastes & Less regulated than Haz Wastes & not UWnot UW Definition/ identificationDefinition/ identification LabelingLabeling Accumulation storageAccumulation storage DisposalDisposal Tracking ShipmentsTracking Shipments Reporting/notificationReporting/notification TrainingTraining

Definition / IdentificationDefinition / Identification

means wood that has been treated means wood that has been treated with a chemical preservativewith a chemical preservative

creosote, pentachlorophenol, copper creosote, pentachlorophenol, copper azole (CA-B), copper boron azole azole (CA-B), copper boron azole (CBA), chromated copper arsenate (CBA), chromated copper arsenate (CCA), ammoniacal copper zinc (CCA), ammoniacal copper zinc arsenate (ACZA), copper naphthenate, arsenate (ACZA), copper naphthenate, and alkaline copper quaternary (ACQ)and alkaline copper quaternary (ACQ)

DTSC Haz Waste DTSC Haz Waste CharacterizationCharacterization

All 20 samples of CA-B & ACQ All 20 samples of CA-B & ACQ exceeded Calif toxicity for copperexceeded Calif toxicity for copper

CA-B Hem Fir failed for 96-hr LC50CA-B Hem Fir failed for 96-hr LC50 Studies on other TWW underwayStudies on other TWW underway

LabelingLabeling

TWW generated, accumulated, stored, or TWW generated, accumulated, stored, or transported within California shall be clearly transported within California shall be clearly marked and visible for inspection. The TWW shall marked and visible for inspection. The TWW shall be labeled or marked with the following:be labeled or marked with the following:

TREATED WOOD WASTE - Do not burn or scavenge.TREATED WOOD WASTE - Do not burn or scavenge.TWW Handler Name and Address:_________________TWW Handler Name and Address:___________________________________________________________________________________________________________Accumulation Date:_____________________________Accumulation Date:_____________________________

Accumulation & StorageAccumulation & Storage

TWW shall be stored in a manner that prevents TWW shall be stored in a manner that prevents unauthorized access and minimizes release to the unauthorized access and minimizes release to the environment. Storage method determines time environment. Storage method determines time allowed to accumulate onsite:allowed to accumulate onsite:

Block and Tarp Method: TWW is elevated to prevent Block and Tarp Method: TWW is elevated to prevent contact with the soil and covered to protect from contact with the soil and covered to protect from precipitation. TWW must be disposed of within 90 precipitation. TWW must be disposed of within 90 days of generation.days of generation.

Containerized or Storage Building Method: Stored in Containerized or Storage Building Method: Stored in a building or container that prevents release of a building or container that prevents release of TWW materials to the environment with no contact TWW materials to the environment with no contact with soil or water. TWW must be disposed of within with soil or water. TWW must be disposed of within 1 year of generation.1 year of generation.

DisposalDisposal

TWW must not be placed in the regular TWW must not be placed in the regular trash!trash!

TWW shall be disposed in either a Class TWW shall be disposed in either a Class I hazardous waste landfill, or in a I hazardous waste landfill, or in a composite-lined portion of a solid waste composite-lined portion of a solid waste landfill unit that meets all requirementslandfill unit that meets all requirements

When cutting/sawing TWW, the small When cutting/sawing TWW, the small pieces and sawdust shall be captured pieces and sawdust shall be captured and managed as TWW.and managed as TWW.

Tracking ShipmentsTracking Shipments

No need for HW TransporterNo need for HW Transporter Records of all TWW shipments to disposal Records of all TWW shipments to disposal

facilities must be kept for 3 years by the facilities must be kept for 3 years by the generator. The record may take the form of a generator. The record may take the form of a log, invoice, manifest, bill of lading or receipt log, invoice, manifest, bill of lading or receipt form a TWW facility. The record shall include:form a TWW facility. The record shall include: 1. Name and address of the TWW disposal facility1. Name and address of the TWW disposal facility 2. Weight or estimated weight of TWW2. Weight or estimated weight of TWW 3. Date the shipment of TWW left the generator.3. Date the shipment of TWW left the generator.

NotificationNotification

Notify DTSC if you exceed 10,000 lbs. Notify DTSC if you exceed 10,000 lbs. in a calender year.in a calender year.

Obtain identification # if exceed Obtain identification # if exceed 10,000 lbs/yr10,000 lbs/yr

TrainingTraining

All employees handling TWW must All employees handling TWW must be trained in identification and all of be trained in identification and all of the previous slides…blah, blah ,blahthe previous slides…blah, blah ,blah

Other views?Other views?

http://http://www.woodpreservativescience.org/rewww.woodpreservativescience.org/report_arsenic_in_the_diet.shtmlport_arsenic_in_the_diet.shtml