SPA 15
 

j

CONSOLIDATED CHECKLIST 

for the • Wood Preserving Listings 

as of June 30, 1994 

. Note: 1) This checklist consolidates the changes to the Federal code addressed by the following 

Wood Preserving Listings checklists: 

• Revision Checklist 82 [55 FR 50450 (December 6, 1990)]; 

• Revision Checklist 91 [56 FR 27332 (June 13, 1991)]; 

• Revision Checklist 92 [56 FR 30192 (July 1, 1991)]; 

• Revision Checklist 101 [57 FR 5859 (February 18, 1992)]; and 

• Revision Checklist 120 [57 FR 61492 (December 24,1992)]. 

No final rules were promulgated between January 1, 1993, and June 30, 1994, that affected the 

Wood Preserving Listings rule. Therefore, this consolidated checklist is identical to that of 

December 31, 1992. 

• 

2) This consolidated checklist adds, to the list of wastes from non-specific sources, three broad 

categories of wastes from wood preserving processes that use chlorophenolic, creosote, and/or 

inorganic (arsenical and chromium) preservatives. These wastes, F032, F034 and F035, include 

wastewaters, process residuals, preservative drippage and spent formulations. The listing of 

F032· and the perrnittinq and interim status standards applicable to drip pads handling this waste 

are promulgated pursuant to HSWA. The listings of F034 and F035, the permitting and interim 

standards for drip pads that handle F034 and F035 wastes, and the addition of a test method to 

Appendix IIi of Part 261 are non-HSWA provisions. EPA will implement the addition of F032 to 

the list of hazardous wastes from non-specific sources in authorized States until the States 

modify their programs and such modifications are approved by. EPA. The.non-HSWA 

requirements are applicable only in those States that do not have interim or final authorization. In 

. authorized States, the non-HSWA requirements will not be applicable until the States revise their 

programs to adopt equivalent requirements under State law, unless the wastes are designated as 

hazardous due to the Toxicity Characteristic. which would allow an owner or operator to comply 

with the drip pad standards administered under Federal law. 

3) Note that double lines are used on the checklists to indicate the beginning and ending of 

optional provisions with subparagraphs or requirements that must all be adopted if the optional 

provision is adopted. 

• DCWPl94J.15 - Revised: 09130/94

Page 1 of 45 Printed; 715/96 
C 

SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving listings . as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST . ANALOGOUS STATE EQUIV- STRIN- STAIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITA TION CITATION ALENT GENT GENT SCOPE 

PART 260 - HAZARDOUS WASTE MANAGEMENT SYSTEM: GENERAL
 

SUBPART B - DEFINITIONS
 

DEFINITIONS WAC 173-303
 

add "drip pad" in 

alphabetical order 82 260.10 040 X 

PART 261 -IDENTIFICATION AND LISTING OF HAZARDOUS WASTE
 

SUBPART A - GENERAL
 

1 EXCLUSIONS
 

t Spent Wood Preserving Solutions and Wastewaters 

add new paragraph 

which excludes as a 

solid waste spent 

wood preserving 

solutions that have 

been reclaimed and 

are reused for their 

original intended 

purpose 82,92 261 .4(a)(9)(i) 071 (3)(w)(i) X 

add new paragraph 

which excludes as a 

solid waste 

wastewaters from 

the wood preserving 

process that have 

been reclaimed and 

are reused to treat 

wood 92 261.4(a)(9)(ii) 071 (3)(w)(ii) X 

2 

3 

HAZARDOUS WASTES FROM NON-SPECIFIC SOURCES 

add the waste codes 

nF032a , nF034n and 

"F035 n in 

alphanumeric order to 

list as shown below: 

82, t91, 

t120 261.31 (a) 9904 X 

-: 

DCWPL94J.15 • Revised: 09130/94

Page 2 of 45 Printed: 715/96 

c 
• • 

•

·

SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listinqs 

as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRlN- STIUN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

Industry and EPA Hazardous waste Hazard 

hazardous waste code 

No . 

•
 

• * • • • * 

F032	 Wastewaters (except those that have not come into contact with process 

contaminants), process residuals, preservative drippage, and spent formulations from 

wood preserving processes generated at plants that currently use or have previously 

used chlorophenolic formulations (except potentially cross-contaminated wastes that 

have had the F032 waste code deleted in accordance with § 261.35 of this chapter or 

potentiaily cross-contaminated wastes that are otherwise currently regulated as 

hazardous wastes (i.e., F034 or F03S), and where the generator does not resume or 

initiate use of chlorophenolic formulations). This listing does not include K001 bottom 

sediment sludge from the treatment of wastewater from wood preserving processes that 

use creosote and/or pentachlorophenol. 

F034	 Wastewaters (except those that have not come into contact with process 

contaminants), process residuals, preservative drippage, and spent formulations from 

wood preserving processes generated at plants that use creosote formulations. This 

listing does not include K001 bottom sediment sludge from the treatment of wastewater 

from wood preserving processes that use creosote end/or pentachlorophenol. 

F035	 Wastewaters (except those that have not come into contact with process 

contaminants), process residuals, preservative drippage, and spent formulations from 

wood preserving processes generated at plants that use inorganic preservatives 

containing arsenic or chromium. This listing does not include K001 bottom sediment 

sludge from the treatment of wastewater from wood preserving processes that use 

creo.sote and/or pentachlorophenol. 

.. 

(T) 

r 

(T) 

In 

4
 remove. the 

administrative stay 

addressed in 

Footnote 1 of the 

261 .31 table t91,120 261 .31 (a)/table No Analog )( 

•	 DCWPl.94J.15 - Revised: 09130/94 Page 3 of 45	 Printed: 715/96 
5 

SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings . as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STAIN- STAIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

DELETION OF CERTAIN HAZARDOUS WASTE CODES FOLLOWING EQUIPMENT CLEANING AND 

REPLACEMENT 

o 

wastes from wood 

preserving processes. 

at plants that do not 

resume or initiate use 

.of chlorophenolic 

preservatives will not _ 

meet the listing 

definition of F032 

once the 261 .35(b) 

and (c) requirements 

are met; wastes may 

continue to meet 

another hazardous 

waste listing 

description or exhibit 

one or more 

characteristics 82 . 261.35(a) 083(1 ) X 

generators must
 

either clean or replace
 

all specified process
 

equipment that may
 

have come into
 

contact with
 

chlorophenolic
 

formulations or
 

constituents ,
 82,92 261 ~35(b) 083("2) X

generators shall do 

one of the following: 82,92 261.35(b)(1 ) 083(2)(a) X 

prepare and follow an 

equipment cleaning 

plan; clean equipment 

in accordance with 

261'.35 92 261.35(b)(1 Hi) 083(2)(a)(i) X 

()
 

DCWPl94J.15 • RoMooed: 09130/94

Page 4 of 45 Printed: 715(96 
SPA 15
 

•
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings
 . as of June 30, 1994 (cont'd) 

FEDERAL REQUIREMENTS 

CHECKUST 

REFERENCE FEDERAL RCRA CITATION 

prepare and follow an 

equipment 

replacement plan; 

replace equipment in 

accordance with 

261.35 9"2 261.35(b)(1 )(ii) 

document cleaning 

and replacement in 

accordance with 

261.35, carried out 

after termination of 

use of chlorophenolic 

preservatives 92 261.35(bH 1)(iii) 

cleaning requirements 82,92 261.35(blC2) 

prepare and sign a 

written equipment 

Gleaning plan that 

describes: 92 261.35(blC2)(i) 

equipment to be 

cleaned .. 92 ..­ 261.35(b)(2)(iHA) 

how equipment will 

be cleaned 92 261.35(bH2)(iHB) 

solvent to be used in 

cleaning 92 261.35(bH2)(i)(C) 

how solvent rinses 

will be tested 92 261.35(b)(2)(iHD) 

how cleaning 

residues will be 

disposed 92 261.35(bH2)(i)(E) 

equipment must be 

cleaned as follows: 92 261.35(bH2Hii) 

remove all visible 

residues from process 

equipment 92 

261.35(bH2)(ii) 

(A) 

ANALOGOUS STATE 

CITATION 

083(2)(a)(ii) 

6 

083(2HaHiii) 

083(2)(b) 

• 083(2)(bHi) 

083(2)(blCilCA)· ..- . 

083(2)(bHiHB) 

083(2)(bHiHC) 

083(2HbHi)(D) 

083(2)(b)(i)(E) 

083(2)(bHii) 

083(2)(bHiiHA) 

STATE ANALOG IS: 

EQUIV· 

ALENT 

LESS 

STRlNGENT 

MORE 

STRlNGENT 

BROAD 

ER IN 

SCOPE 

X 

X 

X 

X 

I 

X· 

X 

X 

X 

X 

X 

X 

• DCWPL94J.15 - Revised: 09130/94 Page 5 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings . as of June 30, 1994 (conr'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUlV- STRlN· STRIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL· RCRA CITAnON CITATION AlENT GENT GENT SCOPE 

rinse with appropriate 

solvent until no dioxin 

ordibenzofur'an 

detection in final 26'1.35(bH2Hii) 

solvent rinse 92 (B) 083(2HbHiiHB) X 

analytical 

requirements 92 261.35(bH2Hiii) 

-

083(2)(b)(iii) X 

test rinses as per 

SW-846, Method 

8290 92 

r 

261 .35(b)(2)(iii) 

(A) 083(2)(b)(iiiHA) X 

"not detected" 

defined 92 

261 .35(bH2Hiii) 

(B) 083(2HbHiiiHB) X 

generator manages 

cleaning process 

residues as F032 

waste 92 261.35(bH2Hiv) 083(2HbHiv) X 

replacement 

requirements 82,92 261.35(bH3) 083(2Hc) X 

prepare and sign ,­

written equipment 

replacement plan that 

describes: 92 261.35(bH3Hi) 083(2HcHi) X 

equipment to be 

replaced 92 261.35(bH3HiHA) 083(2HcHiHA) X 

how equipment will 

be replaced 92 261.35(bH3HiHB) 083(2)(cHiHB) X 

how equipment will 

be disposed 92 261.35(bH3HiHC) 083(2HcHiHC) X 

generator must 

manage discarded 

equipment as F032 

waste 92 261.35(bH3)(ii) 083(2)(cHii) X 

documentation 

requirements 92 261.35(bH4) 083(2Hd) X 

DCWPl.94J.15 - Revised: 09130/94

Page 6 of 45 Printed: 715/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) 

• 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUlV- STRlN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

document previous 

equipment cleaning 

andlor replacement 

performed in 

accordance with 

261.35 and occurred 

after cessation of 

chlorophenolic 

preservative use 92 261 .35(b)(4)(i) 083(2)(d) X 

documentation that 

must be maintained 

as part of the 

.facility's operating 

record 82 261."35(c) 083(3) X 

name and address of 

the facility . 82 261.35(c)(1 ) 083(3)(a) X 

formulati ons ." . .., . 

previously used and 

the date on which 

their use ceased in . - each process at the 

plant 82 261 .35(c)(2) 083(3)(b) X 

formulations currently 

used in each process 

at the plant 82 261.35(c)(3) 083(3)(c) X 

equipment cleaning or 

replacement plan 82 261.35(c)(4) " 083(3)(d) X 

name and address of 

any persons who 

conducted the 

cleaning and 

replacement 82 261.35(c)(5) 083(3)(e) X 

dates on which 

cleaning and 

replacement were 

accomplished 82 261.35(c)(6) 083(3)(f) X 

• DCWPl94.I.15 - Revised: 09130/94

Page 7 of 45 Printed: 715196 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving listings 

as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

FEDERAL REQUIREMENTS 

CHEClCUST 

REFERENCE FEDERAL RCRA CITATION 

ANALOGOUS STATE 

CITATION 

EQUIV· 

ALENT 

LESS 

STRlN· 

GENT 

MORE 

STRlN· 

GENT 

BROAD 

ERIN 

SCOPE 

dates of sampling and 

testing 82 261.35(c)(7) 083(3)(g) X 

description of sample 

handling and 

preparation 

techniques 8~ 261.35(c)(8) 083(3)(h) X 

description of the 

tests performed, the 

date, and the results 

of the tests 82 261.35(c)(9) 083(3)(i) X 

name and model 

numbers of the 

instrument(s) used in 

performing the tests 82 261.35(c)( 10) 083(3)(j) X 

QA/OC 

documentation 82 261.35(cH11 ) 083(3)(k) X , 

siqned certification 

statement .. 82 261 .35(c)( 12) 083(3)(1) X 

APPENDIX 11\ TO PART 261'
 

CHEMICAL ANALYSIS TEST METHODS
 

add-the compound, 

"Benzo(k) 

fluoranthene" ,in 

alphabetical order, to 

Table 1 82 

Table 1, 

Appendix III 110(3)(f) X 

() 

DCWPL94J.15 - Revised: 09/30194

Page 8 of 45 Printed: 715/96 
• • • • • • • 

• • • • • • • 

• • • • • • 

• • • • • • 

• 

SPA 15 

CONSOLIDATED CHECKLIST: W'ood Preserving Listings 

as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV-. STR/N- STR/N· ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT 'GENT GENT SCOPE 

TABLE 1. -- ANALYSIS METHODS FOR
 

ORGANIC CHEMICALS CONTAINED IN SW-846
 

Compound	 Method Nos• 

Benzo(k) fluoranthene	 _ 8100.8250,8270,8310 

APPENDIX VII TO PART 261
 

BASIS FOR LISTING HAZARDOUS WASTE
 

add "F032", "F034", 

and "F03S" to list in 

alphanumeric order as 

shown below. 82 Appendix VII. 082(4) X

• EPA hazardous Hazardous constituents 

waste No. for which listed 

F032	 Benz(a)anthracene, benzo(a)pyrene, dibenz(a,h)-anthracene, indeno(1,2,3-cdlpyrene, 

pentachlorophenol, arsenic, chromium. tetra-, penta-, hexa-, heptachlorodibenzo-pdioxins, tetra-, penta-, hexa-, heptachlorodibenzofurans. • 

F034	 Benz(a)anthracene, benzo(k)fluoranthene, benzo(a)pyrene, dibenz(a,h)anthracene, 

indeno(1,2,3-cd)pyrene. naphthalene, arsenic. chromium. 

F035	 Arsenic, chromium, lead. 

APPENDIX VIII TO PART 261
 

HAZARDOUS CONSTITUENTS
 

add the specified 

hazardous 

constituents in 

alphabetical order as 

shown below: 82 Appendix VIII 990S X 

•	 DCWPL94J,15 - Reviead: 09130/94 Page 9 of 45	 Printed: 715/96 
• • • • • • • 

• • • • • • • • 

• • • • • • • • 

SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings. . as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STAlN- STRIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITAnON CITAnON AlENT GENT GENT· SCOPE 

Chemical Chemical 

abstracts . abstracts Hazardous 

Common Name name .No. waste No. 

Benzolklfluoranthene ................. Same 207-08-9
 

Heptachlorodibenzofurans ..............
 Heptachlorodibenzo-p-dioxins ...........
 

PART 262 - STANDARDS APPLICABLE TO GENERATORS OF HAZARDOUS WASTE
 

SUBPART C - PRE-TRANSPORT REQUIREMENTS
 

7,8 ACCUMULATION TIME . 

9
 

the waste is placed: 92 262.34(aH1 ) 200(1 Hb) X 

in containers and 

generator complies 

with Subpart I of Part 

265; and/or 92 262.34(a)( 1Hi) 200(1 )(b)(i) X 

J 

in tanks and 

generator complies 

with Subpart J of 

Part 265, except 

265. 197(c) and 

265.200; and/or 92 262:34(aH 1Hii) 200(1 Hb)(ii) X 

on drip pads and 

generator complies 

with Subpart W of 

Part 265 and 

maintains following 

records: t82,92 262.34(aH1 Hiii) zoot 1HbHiii) X 

()
 

DCWPl94J.15 - Revised: 09130/94 Page 10 of 45 Printed: 715/96 
•• 

SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Ustings . as of June .30, 1994 (cont'd) 

9 

9 

• 9 

STATE ANAlOG IS: 

LESS MORE BROAD 

CHECKUST ANAlOGOUS STATE EQUIV· STRlN· STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA ClTATION CITATION ALENT GENT GENT SCOPE 

description of 

procedures to ensure 

all wastes are 

removed from drip 

pad and associated 

collection system at 

least once every 90 262.34(a)(1 )(iii) 

days t82,92 (A) 200( 1)(b)(iii)(A) X 

documentation of " 

" each waste removal, 

including quantity, 

date and time of 

removal; generator 

exempt from 

Subparts G and H of 

Part 265, except ,~

265.111 and 262.34(a)( 1)(iii) 

265.114 t82,92 (B) 200( 1)(b)(iii)(B) X 

date each period of 

accumulation begins 

is marked and visible 82,92 262.34(a)(2) 200(1)(c) X 

PART 264 - STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS WASTE
 

TREATMENT, STORAGE AND DISPOSAL FACILITIES
 

SUBPART J - TANK SYSTEMS
 

APPLICABILITY
 

add reference to 

paragraph (c) 82 264.190 640(1 ) X 

add new paragraph 

subjecting tanks, 

sumps and other 

collection devices 

used in conjunction 

with Subpart Wregulated drip pads to 

Part 264, Subpart J 

requirements 82 264.190(c) 640(1 )(d) ,X 

DCWPl94J.15 - Revised: 09130/94

Page 11 of 45 Printed: 715/96 
10 

SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Ustings . as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRlN- STAIN- ERIN 

FEPERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

SUBPART W - DRIP PADS 

APPLICABILITY
 

Subpart W applies to 

owners and operators 

of facilities that use 

new or existing drip 

pads to convey 

treated· wood 

drippage, 

precipitation, and/or 

surface water run-off 

to an associated 

collection system; 

existing drip pads 

defined; applicability 

of 264.573{bH3) leak 

collection system 82,92, 

requirement 120 

owner or operator of 

certain drip pads 

inside or under a 

structure not subject 

to 264.573(e) or 

264.573(f) 

regulations, as 

appropriate 82,92 

Subpart W 

requirements not 

applicable to 

management of 

infrequent, incidental 

drippage in storage 

yards provided: 120 

.. . ... .".,-. 

.­

264.570(a) 

.. ._... 

675(1 Ha) X 

675(1Hb) X 

675(1 Hc) X 

o 

264.570(b) 

264.570(c) 

()
 

DCWPL94J.15 - Revised: 09130194 Page 120f 45 Printed: 715/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

. as of June 30, 1994 (cont'd) 

STATE ANAlOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STAIN- STAlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

owner or operator 

maintains and 264.570(c)(1 ) 675(1 )(c) X . complies with a 

written contingency 

plan describing how 264.570(c)( 1Hi) 675( 1)(cHi) X 

owner or operator 

will respond 

immediately to 264.570(cH1 Hii) 675(1 )(cHij) X 

discharge of ~.~ -

infrequent and 

incidental drippage; 264.570(c)(1 Hiii) 675( 1)(cHiii) X 

at a minimum, what 

the continqencv plan 

must describe 120 264.570(c)(1 Hiv) 675{ 1)(cHiv) X 

ASSESSMENT OF EXISTING DRIP PAD INTEGRITY
 

•
 

evaluation of existing 

drip pads; by June 6, . 

1991, written 

assessment obtained 

and kept on file; 

annual review, 

update and 

recertification 

required until 

2a4.573 standards 

are met, except 

264.573(b) standards 

for liners and leak 

detection systems 

82,92, 

120 

... 

264.571 (a) 675(2Ha) X 

• DCWPL94J.15 - Revised: 09130/94

Page 13 of 45 Printed: 715/96 
SPA 15 

CONSOLIDAtED CHECKLIST: Wood Preserving Ustings 

as of June 30, 1994 (cont'd) 

.. 

11, 

12 

12 

_.. 

STATEANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUlV- STRlN· STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

development of 

written plan for 

upgrading, repairing 

and modifying drip 

.pad to meet 

264.573(b) 

requirements; 

submittal of plan to 

Regional - .. . ._. 

Administrator no later 

than 2 years before 

completion of 

modifications; written 

plan documentation, 

review and 

certification 82,92, 

requirements 120 264.571Ib) 675(2)(b) X 

264.571 (b)(1) 

.J 

264.571 (b)(2) 

removed 82,120 264.571 (b)(3) 

submittal of required 

drawings and 

certification to 

Regional 

Administrator or 

State Director upon 

completion of all 

upgrades, repairs, 

and modifications 82,92 264.57f{c) . - 675(2)(c) X 

.. 

if drip pad found to 

be leaking or unfit for 

use, compliance with 

264.573Im) 

provisions or close 

drip pad in 

accordance with 

264.575 82,92 264.571 (d) 675(2)(d) X 

() 

DCWPl.94J.15 - Revised: 09130/94 Page 14 of 45 Print~ 715/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE eQUIV- STRlN- STRlN- ERINFEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

13 DESIGN AND INSTALLATION OF NEW DRIP PADS
 

owners and operators 

of new drip pads 

must ensure that the 

pads are designed, 

installed and operated 

in accordance with 

one of the following: 

-82,92, 

120 264.572 . 675(3) X 

all of the 

requirements of 

264.573 (except 

264.573(a)(4», 

264.574 and 

264.575 ­ 120 264.572(a) 675(3)(a) X 

all of the 

requirements of 

264.573 (except 

264.573(b», 

264.574 and 

264.575 120 264.572(b) 

-­

675(3)(b) X 

•
 

13 DESIGN AND OPERATING REQUIREMENTS
 

drip pads must: 82,92 264.573(a) 675(4)(a) X 

be constructed of 

non-earthen 

materials, excluding 

wood and nonstructurally supported 

asphalt 82;92 264.573(a)(1 ) 675(4)(a)(i) X 

be sloped for freedrainage to the 

associated collection 

system 82,92 264.573(a)(2) 675(4)(a)(ii) X 

have a curb or berm 

around the perimeter 82,92 264.573(a)(3) 675(4)(a)(iii) X 

• DCWPl94J.15 - Revised: 09130/94

Page 15 of 45 Printed: 715/96 
SPA 15
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings . as of June 30, 1994 (cont'd) o 

o
 

14, 

15, 

16 

14 

17 

STATE ANALOG IS: 

teSS MORE BROAD 

CHECKlIST ANALOGOUS STATE EQUIV- STRlN- STRlN- Ell IN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

hydraulic conductivity 

. requirements; 

maintain surface free 

of cracks and gaps; 

sealing material must 

be chemically -_. 

compatible with 

preservatives that 

contact pad; -

requirements apply to 

existing drip pads and 

drip pads of 

owners/operators 

electing to comply 82,92, 

with 264.572(a) 120 264.573(a)(4)(i) 675(4)(a)(iv)(A) X 

owner or operator 

must obtain and keep 

at the facility written 

assessment of drip 

pad certified by 

independent qualified 

registered engineer; 

assessment must 

attest to results of 

evaluation; 

assessment must be 

reviewed, updated 

and recertified 

annually; evaluation 

must document 

extent to which drip 

pad meets 264.573 

(except 264.573(b» 

design and operating 

standards 

- ..-

120 

.. -

264.573(a)(4)(ii) 675(4)(a)(iv)(B) X 

remove notes 

regarding '. 

administrative stays t91,92, 

. for new and existing 

drip pads 

t101, 

120 

264.573(a)(4)/ 

notes X 

r: 

DCWPL94J,15 • Revised: 09130/94 Page 160f 45 Printed: 715/96 
SPA 15
 

•

· CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) 

18 

19 

• 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STRIN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

be of sufficient 

structural strength 

and thickness to 

meet specified 

conditions 82,92 264.573(aH5) 675(4HaHv) X 

if owner/operator 

elects to comply with 

f-264.572(b) instead 

of § 264.572(a), the 82,92, 

drip pad must have: 120 264.573(b) 675(4)(b) X 

a svnthetic liner that 

meets certain design, 

construction and 

installation -­ 'specifications 82,92 264.573(bH1 ) 675(4HbHi) X 

specific requirements 

for liner construction 

materials 82,92 

•.. 

264.573(b)(1 Hi) 675(4HbHi)(A) X 

foundation or base 

requirements 82,92 

.. . . 

264.573(b)(1 )(ii) 675(4)(bHi)(B) X 

liner must cover all .. -

surrounding earth 

that could come into 

contact with the , 

waste or leakage 82,92 ' 264.573(b)(1 )(Hi) 675'(4)(b)(i)(C) X 

leakage detection 

system immediately 

above the liner; 

detection system 

must be: 82,92 264.573(b)(2) 675(4)(b)(ii) X 

constructed of 

materials that are: 82,92 264.573(b)(2)(i) 675 (4)(b)(ii)(A) X 

chemically resistant 

to relevant waste and 264.573(b)(2)(i) 

leakage 82,92 (A) 675(4)(b)(ii)(AHI) X 

• DCWPL94J.15 - ReviHd: 09130194 

Page 17 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings . as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

L£SS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STRlN- STRIN- ER IN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

of sufficient strength 

and thickness to 264.573(bH2)(i) 

prevent collapse 82,92 (B) 675(4Hb)(iil(A)(II) X 

designed and 

operated to function " 

without clogging 

through the 

scheduled closure of 

the drip pad; and 82,92 264.573(bH2Hiil 675(4)(bHii)(BI X 

designed to detect 

drip pad failure or the 

release of hazardous 

waste or 

accumulated liquid at 

the earliest 

practicable time 82,92 264.573(bH2){iii) 675(4HbHii)(C) X 

leakage collection 

system immediately 

above the liner 

designed, 

constructed, 

maintained and 

operated to collect 

leakage from below 

the drip pad; date, 

time and quantity of 

leakage collected 

must be documented 

in operating log 

.' 

120 

. 

. -

264.573(bH31 

_.. _... -

. . .. 

675(4Hb)(iiil 

- --­ .. .. 

X 

. maintenance of drip 

pads; note regarding 

remedial action 82,92 264.573(cl 675(4)(c) X 

convey, drain, and 

collect liquid resulting .. 

from drippage or 

precipitation in order 

to prevent run-off 82,92 264.573(dl 675(4)(d) X 

o
 

() 

0CWPL94J.15 . Revised: 09130/94' Page 18 of 45 Printed: 715196 
SPA 15
 

• ,CONSOLIDATED CHECKLIST: Wood Preserving Listings · as of June 30, 1994 (cont'dl 

• 

STATE ANAlOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STRlN- STAIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

run-on control system 

requirements 82,92 264.573(e) 675(4)(e) X 

run-off management 

system requirements, 

unless system is 

protected by a 

structure, as ... >·1 

described in .. 

264.570(b) 82,92 264.573(f) 675(4)(f) X 

evaluation of drip pad 

for compliance with 

264.573(a)-(f) 

requirements; design 

certification required 82,92 264.573(g) 675(4)(g) X 

removal of drippage 

and accumulated 

precipitation from . ­

associated collection 

system as necessary 

to prevent overflow , .. ..• .. 

onto the drip-pad 82,92 264.573(h) 675(4)(h) X 

thorough cleaning of - _. c 

drip pad surface in a 

manner and 

frequency to meet 

speclfied conditions; 

documentation of 

date, time and 

cleaning procedure in 

facility's operating 

log; owner/operator 

must determine 

whether residues are 

hazardous under 

262.11 and, if so, 

manage them 

according to Parts 

261-268,270 and 82,92, 

RCRA §3010 120 264.573(i) 675(4)(i) X

• DCWPl94J.15 • Revised: 09130/94 Page 19 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

FEDERAL REQUIREMENTS 

CHECKUST 

REFERENCE FEDERAL RCRA CITATION 

minimize tracking of 

hazardous waste or 

constituents off the 

drip pad 82,92 264.573(j) 

after . - removal from 

treatment vessel, 

treated wood from 

pressure and non­ . 

pressure processes 

must be held on pad -'. . -

until drippage has 

ceased; , 

documentation 

required 82.92 264.573(k) 

collection and holding 

units'for run-on and ..-. 

run-off control 

systems emptied or 

otherwise managed - _.. -­ -'­

as soon as possible 

after storms to .. 

maintain design -.... - - . '­ -

capacity 82.92 264.573(1) 

264.573(m) 

throughout the active 

life of the drip pad 

and as specified in 

the permit, repair of 

detected condition 

that may have caused 

or has caused a 

release of hazardous 

waste within a 

reasonable period of 

time. in accordance 

with the following 

procedures: 

.. _. 

82.92 

ANALOGOUS STATE 

CITATION' 

675(4)(j) 

675(4)(k) 

.­ .- -. ..

675(4)(1) 

675(4)(m) 

STATE ANALOG IS: 

EQUIVALENT 

LESS 

STRlNGENT 

MORE 

STRlNGENT 

BROAD 

ERIN 

SCOPE 

X 

X 

X 

X 

_.. 

C)
 

DCWPI..94J.15 - Revised: 09130/94 Page 20 of 45 Printed: 715196 
SPA 15
 " 

.

• 

CONSOLIDATED CHECKLIST: V\(ood Preserving Listings 

as of June 30, 1994 (cont'd) 

• 

20 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRIN· STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

upon detection of a 

condition that may 

have caused or has 

caused a release of 

hazardous waste, the 

owner must: 82,92 264.573(mH1 ) 675 (4)(m)(i) X 

enter discovery in the 

facility operating log 8'2,92 264.573(m)(1 Hi) 675(4Hm)(i)(A) X 

immediately remove 

from service affected 

portion of drip pad 82,92 264.573(m)(1 Hii) 675(4Hm)(i)(B) X 

determine steps to 

repair drip pad and 

clean up any leakage; 

establish schedule for 

repairs 82,92 264.573(m)(1 )(iii) 675(4HmHi)(C) X 

notify Regional 

Administrator within 

24 hours' after 

discovery; provide 

written notice as 

specified within 1O· 

working days 82,92 

, .. 

264.573(m)(1 ) 

(iv) 

.. . __._0____ ... ___

675(4)(m)(i)(D) 

-

X 

review, determination 

and notification by 

Regional 

Administrator 82,92 264.573(mH2) 675(4Hm)(ii) X 

written 'notification to 

Regional 

Administrator and 

certification of 

compliance with 

264.573(m)( 1)(iv) - after repairs and 

clean up 82,92 264.573(m)(3) 675(4HmHiiil X 

• DCWPl94J.15 - Revioed: 09130/94 'Page 21 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

l£SS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRlN- STRIN-' ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION Al£NT GENT GENT SCOPE 

should a permit be 

necessary, Regional 

Administrator will 

specify in the permit 

all design and 

operating practices 

necessary to ensure 

that 264.573 

requirements are met _ 82,92 264.573(n) 

.­

675(4)(n) X 

documentation in 

operating log, as 

specified, of past 

operating and waste 

handling practices 82,92 264.573(0) 675(4)(0)· X 

13 INSPECTIONS
 

.inspection of liners 

and cover systems 

for uniformity, 

damage and 

imperfections during 

construction or 

installation; 

inspection and 

certification of liners 

to meet 264:573 

requirements; 

maintenance of 

certification as part 

of the facility 

operating record; 

inspection of liners 

and covers after 

installation 82,92 264.574(a) 675(5)(a) X 

drip pad must be 

inspected weekly and 

after storms to detect 

evidence of any of 

the following: 82,92 264.574(b) 

.. 

675(5)(b) X 

() 

DCWPL94J.15 • Revised: .09130/94 Page 22 of 45 Printad: 715/96 

c 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings • as of June 30, 1994 tcont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKLIST ANAlOGOUS STATE EQUIV- STRlN- STRlN- ERIN 

FEDERAl REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

deterioration, 

malfunctions or 

improper operation of 

run-on and run-off 

control systems 82,92 264.574(bH1 ) 675(5HbHi) X 

presence of leakage . 

in and proper 

functioning of leak 

detection system 82;92 264.574(bH2) 675(5HbHii) X 

deterioration or 

cracking of drip pad 

surface; note 

regarding remedial 

action 82,92 264.574(bH3) 675(5HbHiii) X 

• 

13 CLOSURE 

at closure, removal 

and decontamination 

requirements; " 

management as 

hazardous waste 82,92 

. -' ~.~ . 

264.575(a) 

-

675(6)(a) X 

conditions under 

which owner or 

operator must close 

facility and perform 

post-closure care in 

accordance with 

264.310 

requirements; for 

permitted units, 

permit "requirement 

continues throughout 

post-closure period; 

drip pad is considered 

a landfill and must 

meet Subparts G and 

H requirements of 

Part 264 82,92 264.575(b) 675(6Hb) X 

• DCWPI..94J.15 • Revilled: 09130/94 Page 23 of 45 Print8d: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: .Wood Preserving Listings • 

as of June 30, 1994 (cont'dl o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STRlN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITA T'ON CITATION ALENT GENT GENT SCOPE 

owner or operator of 

an existing drip pad 

that does not comply 

with the 264.573(b) 

(1) liner requirements 

must: 82,92 264.575(c)(1 ) 675(6)(c)(i) X 

include in closure 

plans for drip pad 

under 264.112, a .. -

plan for 264.575(a) 

compliance and a 

contingent plan for 

264.575(b) 

compliance 82,92 264;575(c)(1 )(i) 675(6)(c)(i)(A) X 

prepare a contingent­

.post-closure plan 

under 264.118 for 

complying with 

... 

264.575(b) in case 

not all contaminated 

subsoils can be 

practicably removed 

at closure 82,92 264.575(c)(1 )(ji) 675(6)(c)(i)(B) X 

cost estimates 

calculated under 

264.112 and 

264.144 for closure 

and post-closure care 

of drip pad subject to 

264.575(c) must 

include the cost of 

complying with the 

contingent closure 

plan and the 

contingent postclosure plan; cost of 

expected closure 

under 264.575(a) 

need not be included 

.. 

84,92 

... .... 

.. 

264.575(c)(2) 

- .­

675(6)(c)(ii) X 

-

DCWPL94J.15 • Revised: 09130/94·

Page 24 of 45 Printed: 715/96 

c 
•• 

SPA 15 

.CONSOLlDAT~D 'CHECKLlST: Wood Preserving Listings 

· as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EaulV· STRlN- STAIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEOERAL.RCRA CITATION CITATION AlENT GENT GENT .SCOP£ 

PART 265 -INTERIM STATUS STANDARDS FOR OWNERS AND OPERATORS OF HAZARDOUS
 

WASTE TREATMENT, STORAGE AND DISPOSAL FACILITIES
 

SUBPART J - TANK SYSTEMS
 

APPLICABILITY
 

add reference to 

paragraph (c) 82 265.190 400(3)(a) X 

add new paragraph 

subjecting tanks, 

sumps and other 

collection devices 

used in conjunction . 

with Subpart Wregulated drip pads to 

Part 265, Subpart J 

requirements 82 265.190(c) 400(3)(a) X

• SUBPART W - DRIP PADS 

APPLICABILITY 

Subpart W applies to 

owners and operators 

of facilities that use 

new or existing drip 

pads to convey 

treated wood 

drippage, 

precipitation, and/or 

surface water run-off 

to an associated 

collection system; 

existing drip pads 

defined; applicability 

of 265.443(b)(3) leak 

collection system 82,92, , requirement 120 265.440(a) 400(3)(a) X 

• DCWPL94J.15 • Revised: 09130194 Page 25 of 45 Printed: 715196 . 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

STATE ANAlOG IS: 

LESS MORE BROAD 

CHECKUST ANAlOGOUS STATE EQUIV- STRIN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION - CITATION ALENT GENT GENT SCOPE 

owner or operator of 

certain drip pads 

inside or under a 

structure not subject -

to 265.443(e) or 

265.443(f) _. 

regulations, as 

appropriate 82 265.440(b) 400(3Ha) X 

Subpart W 

requirements not 

applicable to 

management of 

infrequent, incidental 

drippage in storage 

yards provided: 120 265.440(c) 400(3Ha) X 

owner or operator 

maintains and 265.440(cH1 ) 400(3Ha) X 

complies with a 

written contingency 

plan describing how 

owner or operator 

265.440(cH1 Hi} 40.0(3Ha) X -­

will respond to 

discharge of 

infrequent and 

incidental drippage; 

265 .440(cH 1Hii) 400(3Ha) X 

265.440(cH1Hiii) 400(3Ha) X 

at a minimum, what 

the contingency plan 

must describe 120 265.440(cH1 Hiv) 400(3Ha) X 

() 

DCWPL94J.15 - flevised: 09130/94 Page 26 of 45 Printed: 7/5/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) 

FEDERAL REQUIREMENTS CHECKUST 

REFERENCE FEDERAL ReRA CITATION 

ANALOGOUS STATE 

CITATION 

STATE ANALOG IS: 

EQUIVAlENT 

LESS 

STRlNGENT 

MORE 

STRlNGENT 

BRQAD 

ERIN 

SCOPE 

ASSESSMENT OF EXISTING DRIP PAD INTEGRITY
 

• 

21 

21 

evaluation of existing 

drip pads; by June 6, 

1991, written 

assessment obtained 

and kept on file; 

annual review, 

update and 

recertification 

required until 

265.443 standards 

are met, except for 

265.443(b) standards 

for liners and leak 

detection systems 82,120 265.441 (a) 400 (3)(a) X 

development of 

written plan for 

upgrading, repairing 

and modifying drip 

pad to meet 

265.443(b) 

requirements; 

submittal of plan to 

Regional 

Administrator no later 

than 2 years before 

completion of 

modifications; written 

plan documentation, 

review and 

certification 

requirements 82,120 265.441 (b) 400(3)(a) X 

265.441 (b)(1) 400(3)(a) X 

265.441 (b)(2) 400(3)(a) X 

removed 82,120 265.441 (b)(3) 400(3)(a) X 

• DCWPl.94J.15 - Revised: 09130/94 Page 27 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

DESIGN AND INSTALLATION OF NEW DRIP PADS 

STATEANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUlV- STAIN- STAIN· ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

submittal of required 

drawings and -­

certification to 

Regional 0­

. -

Administrator or 

State Director upon 

completion of all 

repairs and 

modifications 82 265.441 (c) 400(3)(a) X 

if drip pad found to 

be leaking or unfit for 

use, comply with 

265.443(m) 

provisions or close 

drip pad in .. 

accordance with 

265.445 82 265.441 (d) 400(3)(a) X o
 

owners and operators 

of new drip pads 

must ensure that the 

pads are designed, 

installed and operated 

in accordance with 

one of the following: 

82, 

120 

.. -' 

265.442 

_. 

400(3)(a) X 

all of the appJicable 

requirements of 

265.443 (except 

265.443(a)(4)), 

265.444 and265.445 120 265.442(a) 400(3)(a) X 

all of the applicable 

requirements of 

265.443 (except 

265.443(b)), 

265.444 and 

265.445 120 265.442(b) 400(3)(a) X 

() 

DCWPL94J.15 • Revised: 09130/94 Page 28 of 45 Printed: 715/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1.994 (cont'dl 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRIN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITAnON CITATION ALENT GENT GENT SCOPE 

DESIGN AND OPERATING REQUIREMENTS
 

•

22, 

23 

drip pads must: 82 265.443(a) 

be constructed of 

non-earthen 

materials, excluding 

wood and non­

.structurally supported 

asphalt 82 265.443(a)(1J 400(3)(a) X 

be sloped to freedrain wastes to the 

associated collection 

system 82 265.443(a)(2) 400(3)(a) X 

have a curb or berm 

around the perimeter 82 265.443(a)(3) '400(3)(a) X 

hydraulic conductivity 

requirements; 

maintain surface free 

of cracks and gaps; 

surface material must 

be chemically 

compatible with 

preservatives that 

contact.pad: __ .... _. 

requirements apply to 

existing drip pads and 

drip pads of ownersl 

operators electing to 

comply with 

265.442(a) 82,120 

... "-- --'. 

265.443(a)(4)(i) 400(3)(a) . X 

• DCWPL94J.15 - Revised: 09130194 Page 29 of 45 Printed: 715/96 
SPA 15
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) . o 

o
 

22
 

24
 

I 

, . 

STATE ANAlOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUN- STRIN- STRIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

owner or operator 

must obtain and keep 

at the facility a 

written assessment 

of drip pad certified 

by independent 

qualified registered 

engineer; assessment 

must attest to results 

of evaluation; 

assessment must be 

reviewed, updated 

and recertified 

annually; evaluation 

must document 

extent to which drip 

pad meets 265.443 

(except 265.443(b) 

design and operating 

standards 120 

-

- -

265.443(a)(4)(ii) 400(3)(a) 

-, 

X 

remove notes 

regarding 

administrative stays t91, 

for new and' existing t1 01, 265.443(a)(4)/ 

drip pads 120 notes 400(3)(a) X 

be of sufficient 

structural strength 

and thickness to 

meet specified 

conditions; note 

regarding structural 

integrity standards 82 265.443(a)(5) 400(3)(a) X 

if an owner/operator 

elects to comply with 

§ 265.442(b) instead 

of § 265.442(a), the 

drip pad must have: 82,120 265.443(b) 400(3)(a) X 

OCWPlMJ.15 • Revised: 09130/94 Page 30 of 45 Printed: 715/96 

25 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) 

• 

26· 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANAlOGOUS STATE EQUIV- STRlN- STRJN- Eft IN· 

FEDERAL REQUIREMENTS REFERENCE FEDERAl RCRA CITAnON ClTAnON AlENT . GENT GENT SCOPE 

a synthetic liner that 

meets certain 

specifications 82 265.443(b)(1 ) 400(3)(a) X 

specific requirements 

for liner construction 

materials 82 265.443(b)(1 )(i) 400(3)(a) X 

foundation or base 

requirements 82 265.443(b)(1 )(ii) 400(3)(a) X 

liner must cover all 

surrounding earth 

that could come into 

contact with the 

waste or leakage 82 265.443(b)( 1)(iii) 400(3)(a) X 

leakage detection 

system immediately 

.above the liner; 

detection system 

. must be: 82 265.443(b)(2) 400(3)(a) X 

constructed of 

materials that are: 82 265,443(b)(2)(i) 400(3)(a) X 

chemically resistant 

to relevant waste and 265.443(b)(2)(i) 

leakage 82 (A) 400(3)(a) X 

of sufficient strength 

and thickness to 265.443(b)(2)(i) 

prevent collapse 82 (B) 400(3)(a) X 

designed and 

operated to function 

without clogging 

through scheduled 

drip pad closure 92 265.443(b)(2)(ii) 400(3)(a) X 

• OCWPI..94J.15 - Revised: 09130/94 Page 31 of 45 Printed: 715196 
26 

SPA 15
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRIN- STRlN- ER IN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

designed to detect 

the failure of the drip 

-pad or the presence 

of hazardous waste 

release or 

accumulated liquid at 

the earliest 

practicable time 82,92 265.443(b)(2)(iii) 400(3)(a) X 

leakage collection -. - -

system immediately 

above the liner 

designed, 

constructed, - -­ maintained and 

operated to collect 

leakage from below -­ the drip pad for 

removal; date, time 

-and quantity of 

leakage collected 

must be documented 

in operating log 120 265.443(b)(3) 400(3)(a) X 

maintenance of drip 

pads; note regarding 

remedial action 82 265.443(c) 400(3)(a) X 

convey, drain, and 

collect liquid resulting 

from drippage or 

precipitation in order 

to prevent run-off 82 265.443(d) 400(3)(a) X 

run-on control system 

requirements, unless 

drip pad is protected 

by a structure, as 

described in 

265.440(b) 82 265.443(e) 400(3)(a) X 

o
 

o 

DCWPL94J.15 • Revised: 09130/94

Page 32 of 45 Printed: 715196 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving listings 

as of June 30, 1994 (cont'd) 

• 

STATE ANALOG IS: 

LEss MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRlN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITAnON CITATION AlENT GENT GENT SCOPE 

run-off management 

system requirements, 

unless drip pad is 

protected by a 

structure, as 

described in 

265.440(b) 82 265.443(f) 400(3)(a) X 

evaluation of drip pad 

for compliance with 

265.443(a)-(f) 

requirements; design 

certification required 82 265.443(g) 400(3)(a) X 

removal of drippage 

and accumulated 

precipitation from 

associated collection 

system as necessary 

to prevent overflow 

onto the drip pad 82 265.443(h) 400(3)(a) X 

thorough cleaning of 

drip pad surface in a 

manner and 

frequency to meet 

specified conditions; 

documentation of 

date, time and 

cleaning procedure in 

facility's operating 

log 82,120 265.443(i) 400(3)(a) X· 

minimize tracking of 

hazardous waste or 

constituents off the 

drip pad 82 265.443(j) 400(3)(a) X 

• DCWPUl4J.15 - Revised: 09130/94 Page 33 of 45 Printed: 715/96 
SPA 15
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

FEDERAL REQUIREMENTS 

after removal from 

treatment vessel, 

treated wood from 

pressure and nonpressure processes 

must be held on pad 

until drippage has 

ceased; 

documentation 

required 

collection and holding 

units for run-on and. 

run-off control 

systems emptied or 

otherwise managed 

as soon as possible 

after storms to 

maintain design 

capacity 

throughout the active 

life of the drip pad 

and as specified in 

the permit, repair of 

detected condition 

that may have caused 

or has caused a 

release of hazardous 

waste within a 

reasonable period of 

time, in accordance 

with 'the following 

procedures: 

upon detection of a 

condition that may 

have caused or has 

caused a release of 

hazardous waste, the 

owner must: 

CHECKUST
 

REFERENCE
 

82 

82 

-" .. .­

82;92 

82,92 

as of June 30, 1994 (conr'd) o 

o
 . 

FEDERAL RellA CITATION 

265.443(k) 

265.443(1) 

_..- -, .­

265.443(m) 

265.443(m)(1 ) 

ANALOGOUS STATE 

CITATION 

400(3)(a) 

400(3)(a) 

", -_.

400(3)(a) 

400(3)(a) 

STATE ANALOG IS: 

EQUIVAlENT 

LESS 

STRlNGENT 

MORE 

·STRlN- . 

GENT 

BROAD 

ER IN 

SCOPE 

X 

X 

X 

, 

X 

DCWPL94J.15 • Revised: 09130/94 Page 34 of 45 Printed: 715/96 
•• 

SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving Listings . as of June 30, 1994 (cont'd) 

• 

27 

STATE ANALOG IS: 

LESS. MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV- STRlN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE. FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

entry of discovery in 

the facility operating 

log 82 265.443(m)( 1)(i) 400(3)(a) X 

immediate removal 

from service of 

affected portion of 

drip pad 82 265.443(m)(1 )(ii) 400(3)(a) X 

determination of 

steps to repair drip 

pad, remove any 

leakage, and establish 

schedule for clean up 

and repairs 82 265.443(m)(1 )(iii) 400(3)(a) . X 

notify Regional 

Administrator within 

24 hours after 

discovery; provide 

written notice as 

specified within 10 265.443(m)(1 ) 

working days 82 (iv) 400(3)(a) X 

review, determination 

and notification by 

Regional , .. 

Administrator 82 265.443(m)(2) 400(3)(a) 'X 

written notification to 

Regional 

Administrator and 

certification of 

compliance with 

265.443(m)( 1)(iv) 

after repairs and 

clean up 82,92 265.443(m)(3) 400(3)(a) X 

documentation in 

operating log, as 

. specified, of past 

operating and waste 

handling. practices. 82 265.443(n) 400(3)(a) X 

DCWPl94J.15 - Reviled: 09/30/94 Page 35 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHEClCLIST ANALOGOUS STATE EQUIV- STRlN- STRlN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

INSPECTIONS.
 

inspection of liners 

and cover systems 

for uniformity, 

damage and 

imperfections during 

construction or 

installation; 

inspection and 

certification of liners 

to meet 265.443 

requirements; . _. 

maintenance of 

certification as part 

of the facility 

operating record; 

inspection of liners 

and covers after 

installation 82 

drip pad must 'be 

inspected weekly and 

after storms to detect 

evidence of any of v 

the following: 82 

deterioration, 

malfunctions or 

improper operation of 

run-on and run-off 

control systems 82 

presence of leakage 

in and -proper 

functioning of leak 

detection system 82 

deterioration or 

cracking of drip pad 

surface: note 

regarding remedial 

action 82 

265.444(a) 

-. .­

265.444(b) 

265.444(b)(1 ) 

265.444(b)(2) 

265.444(bH3) 

. 

X 

.-

X 

X 

X 

X /' 

400(3)(a) o ... .. .. -,.;.. - . 

400(3)(a) 

400(3)(a) 

400(3)(a) 

400(3)(a) o 

OCWPl94J.15 • Revised: 09130/94

Page 36 of 45 Printed: 715/96 
SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood PreservingUstings · as of June 30, 1994 (cont'd) 

STATE ANALOG IS: 

LEss MORE BROAD 

CHECKUST ANALOGOUS STATE EQUlV- STRlN- STRlN- ERIN 

FEDERAl REQUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

CLOSURE
 

•
 

at closure, removal 

and decontamination 

requirements; 

management as 

hazardous waste 82 465.445(a) 400(3)(a) X 

closure and postclosure care of drip 

pad as a landfill under 

265.310, if some , 

contaminated 

subsoils cannot be 

removed or 

decontaminated; for 

permitted units, 

permit requirement 

continues throughout 

post-closure period 82 265.445(b) 400(3)(a) X 

owner or operator of 

. an existing drip pad 

not in compliance 

with the 265.443(b) 

(1) liner requirements 

must: 82 265.445(c)(1 ) 400(3)(a) X 

include in the closure 

plan for the drip pad 

under 265.112,. a 

plan 'for 265.445(a) 

compliance and a 

contingent plan for 

265.445(b) 

compliance 82 265.445(c)(1 )(i) 400(3)(a) X 

• DCWPL94J.15 • Revillecl: 09130/94 Page 37 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUN· STRlN- STRIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL ReRA CITATION CITATION AlENT GENT" GENT SCOPE 

prepare contingent 

post-closure plan 

under 265.118 for 

complying with 

265.445(b) in case 

not all contaminated 

subsoils can be " - " '" 

practicably removed 

at closure 82 265.445(c)( 1Hii) 400(3)(a) X 

cost estimates 

calculated under 

265.112 and 

265.144 for closure 

and post-closure care 

of drip pad subject to 

265.445(c) must 

include cost of 

complying with 

contingent closure 

plan and contingent 

post-closure plan; 

cost of expected 

closure under 

265.445(a) need not 

be included "82 265.445(c)(2) 400(3)(~) X ...... 

() 

0CWPl94J.15 - Revised: 09130/94 

, Page 38 of 45 Printed: 715196 

I 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (cont'd) • STATE ANALOG IS: 

l£SS MORE BROAD 

CHECICUST ANALOGOUS STATE EQUIV- STRlN- STRIN- ERIN 

FEDERAL REQUIREMENTS REFERENCE FEDERAL ReM CITATION CITATION Al£NT GENT GENT SCOPE 

PART 270 - EPA ADMINISTERED PERMIT PROGRAMS:
 

THE HAZARDOUS WASTE PERMIT PROGRAM
 

.SUBPART B - PERMIT APPLICATION
 

28 SPECIAL PART B INFORM·ATION REQUIREMENTS FOR DRIP PADS
 

•
 

•
 

additional information 

to be provided by 

owners and operators 

of hazardous waste 

treatment, storage, or 

disposal facilities that 

collect, store, or treat 

hazardous .waste on 

drip pads, except as 

otherwise provided 

by 264.1 82 

list of hazardous 

wastes placed or to 

be placed on each 

drip pad 82 

detailed plans and an 

engineering report 

describing how 

264.90(bH2) will be 

met, if an exemption 

is sought to Subpart 

F of Part 264 82 

detailed plans and an 

engineering report 

describing the design, 

construction, 

operation and 

maintenance of drip 

pad to meet 264.573 

requirements; 

submission must 

address 264.571 

items 82,92 

270.26 - - -­

270.26(a) 

270.26(b) 

270.26(c) 

Page 39 of 45 

806(4)(1) X 

, 

806(4J(1Hi) X 

806(4)(1)(ii) X 

806(4)(1)(iii) X 

DCWPl.94-l.15 - Revised: 09130/94 

Printed: 715196 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

-as of June 30, 1994 (cont'd) o 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STRlN- STRIN- ERIN 

FEDERAL REQuIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION AlENT GENT GENT SCOPE 

design characteristics 

of the drip pad 82 270.26(c)(1 ) 806(4)(I)(iii)(A) ·X 

liner system 82 270.26(c)(2) 806(4)(I)(iii)(B) X 

leakage detection 

system 82 270.26(c)(3) 806(4)(I)(iii)(C) X 

practices designed to 

maintain drip pads 82 270.26(c)(4) 806(4)(I)(iii)(D) X 

associated collection 

system 82 270.26(c)(5) 806(4)(I)(iii}(EI X 

control of run-on to 

the drip pad 82 270.26(c)(6) 806(4)(I)(iii)(F) X 

control of run-off 

from the dri p pad 82 270.26(c)(7) 806(4)(1)(iii}(G) X 

removal intervals and 

demonstration of - _..­ -' 

- . .­ " 

sufficiency to prevent 

overflow 82 270.26(c)(8) 806(4)(I)(iii)(H) X 

procedures for 

cleaning drip pad at 

least once every 

seven days; - .­ 1 -­ •••• 

- - .. 

provisions for 

documentation of 

date, time and 

cleaning procedure 82 270.26(c)(9) 806(4)(I)(iii)(1) X 

operating practices 

and procedures to 

minimize tracking of 

hazardous waste or 

waste constituents 

off the drip pad 82 270.26(c){'0) 806(4)(I)(iii)(J) X 

o
 

() 

DCWPl94J.15 - Revised: 09130194 

Page 40 of 45 Printed: 715196 
1

SPA 15
 

• 

CONSOLIDATED CHECKLIST: Wood Preserving listings 

as of June 30, 1994 (cont'dl 

• 

STATE ANALOG IS: 

LESS MORE BROAD 

CHECKUST ANALOGOUS STATE EQUIV· STAIN· STAIN- ERIN 

FEDERAL REaUIREMENTS REFERENCE FEDERAL RCRA CITATION CITATION ALENT GENT GENT SCOPE 

procedures for 

ensuring that treated 

wood from pressure 

and non-pressure 

processes is held on 

the drip pad until 

drippage has ceased: 

recordkeeping 

practices 82 270.26(cH11 ) 806(4HI)(iiiHK) X 

provisions for 

ensuring that 

collection and holding 

units for run-on and 

run-off control 

systems are emptied 

or managed as soon 

as possible after 

storms to maintain 

design capacity 82 270.26(cH12) 806(4HI)(iiiHL) X 

if treatment is carried 

out on the drip pad, 

details of process 

equipment used, and 

the nature and quality 

of residuals 82 270.26(c)(13) 806(4)(1)(iii)(M) X 

description of drip 

pad inspections to 

meet 264.573 

requirements; include 

in 270.14(bHS) 

inspection plan 82,92 270.26(c)(14) 806(4)(IHiii)(N) X 

certification that drip 

pad design meets 

264.573(a)-(f) 

requirements 82,92 270.26(cH15) 806(4)(IHiii)(0) X 

• OCWPl94J.15 . RevisBd: 09130194 

Page 41 of 45 Printed: 715/96 
SPA 15 

CONSOLIDATED CHECKLIST: Wood Preserving Listings 

as of June 30, 1994 (corrt'd) 

FEDERAL REQUIREMENTS CHECKUST 

REFERENCE FEDERAL RCRA CITA TION 

ANALOGOUS STATE 

CITATION 

STATE ANALOG IS: 

EQUIVALENT 

LESS 

STRlNGENT 

MORE 

STRINGENT 

BROAD 

ERIN 

SCOPE 

description of 

removal procedures : 

at closure under 

264.575(a); for 

waste not removed at 

closure, submittal of 

detailed plan and 

engineering report to 

describe compliance 

with 264.310(a) and ._­

(b); information 

should be included in 

closure plan and, 

where applicable, 

270.14(bH13) postclosure plan 82,92 270.26(cH16) 806(4HIHiiiHP) X 

1	 o 261.4(a)(9)(i) was originally 261.4(a)(9) on Revision Checklist 82. Revision Checklist 92 

redesignated it as 261.4(a)(9)(i) and added a new paragraph designated as 261.4(a)(9)(ii). 

2	 Note the Federal Register 56 FR 27732 (June 13, 1991; Revision Checklist 91) incorrectly 

refers to 261.31 rather than to 261.31 (a) as the place where the list of hazardous wastes 

from non-specific sources can be found. Revision Checklist 81 redesignated 261.31 as 

261.31(a) and added 261.31(b). 

3	 Waste codes F032, F034, and F035 were added to the table in 261.31(a) by Revision 

Checklist 82. Revision Checklist 91 (56 FR 27332; June 13, 1991) addressed an 

administrative. stay of these listings. Revision Checklist '120 (57 FR 61492; December 24, 

1992) terminated the June 13, 1991 administrative stay by amending the listings. For the 

States that did not adopt the June 13, 1991 administrative stay, the Revision Checklist 120 

changes to these listings represent a narrowing of the F032, F034, and F035 listings. Thus, 

the Revision Checklist 120 changes are optional for States that did not adopt the 

administrative stay. For those States that did adopt the June 13, 1991 administrative stay, 

the wording added by the stay (i.e., the parenthetical note concerning the stay) should be 

removed and be replaced with the wording presented in the December 24, 1992 rule (Revision 

Checklist 120) and in this consolidated checklist. 

4	 Only those States that added the administrative stay addressed by the June 13, 1992 rule (56 

FR 27332; Revision Checklist 91) to their code need to make this change. 

5	 Revision Checklist 82 originally introduced §261.35 into the code. Revision Checklist 92 

made extensive formatting and word changes to 261.35(b). 

C)
 

DCWPl94J.15 - Revised: 09130/94 Page 42 of 45 . Printed: 715/96 
SPA 15
 

•	 

CONSOLIDATED CHECKLIST: Wood Preserving Ustings 

as of June 30, 1994 (cont'd) 

6 Note there is a typographical error in 261 .35(b)( 1)(iii)." "Preservations," at the end of the 

sentence, should be "preservatives." We have used the correct word on the checklist. 

7	 Note Revision Checklist 82 redesignated 262.34(a)(2)-(4) as 262.34(a)(3)-(5). Revision 

Checklist 92 changed these paragraphs back to their original numbering, i.e., 262.34(a)(2)-(4). 

Because these two changes cancelled each other out, they were not directly addressed by this 

checklist. 

8	 The technical correction for §262.34, 56 FR 30192 (July 1, 1991; Revision Checklist 9~),

contains the text ot.the introductory paragraph, 262.34(a). As no revisions were made to this 

paragraph, it has not been included in this consolidated checklist. Also, because this technical 

correction made extensive changes to this section of the code, the "Federal Requirements" 

column summarizes the requirement rather than the changes. 

• 

9 An error in the July 1, 1991 'CFR makes it appear that there are two paragraphs designated as 

262.34(a)(2) (see the editorial note in the CFR). Revision Checklist 82 originally inserted the 

first 262.34(a)(2), 262.34(a)(2)(i), 262.34(a)(2)(ii) and redesignated the old 262.34(a)(2)-(4) 

as 262.34(a)(3)-(5). However, Revision Checklist 92 redesignated 262.34(a)(3) as 

262.34(a)(2), effectively removing the first 262.34(a)(2) and incorporating these requirements 

into 262.34(a)(1) at 262.34(a)(1 )(iii) and (iii)(A)&(B). It was not the Agency's intent to 

include these requirements both at 262.34(a)(1 )(iii)(A)&(B) and at 262.34(a)(2) as is indicated 

in the July 1, 1991 CFR. The first 262.34(a)(2) in that CFR should not be in the code. 

Revision Checklist 92 also redesignated 262.34(a)(3)-(5) as 262.34(a)(2)-(4), i.e.. returned 

these subparagraphs to their original numbering prior to the redesignation by Revision 

Checklist 82. 

10 The entire text of Subpart Wof Part 264 was printed in the Federal Register (56 FR 30192; 

July 1, 1991) for Revision Checklist 92. This was done to demonstratethe numbering of 

each citation following the redesignation of sections to correspond with Subpart W, Part 265. 

Numerous paragraphs within the redesignated sections had no revisions made to them. 

Paragraphs in this consolidated checklist, where Revision Checklist 92 is indicated in the 

"Checklist Reference" column, reflect revisions to wording, internal references, or numbering 

that were addressed in Revision Checklist 92. . 

11 The Federal Register for Revision Checklist 92 (56 FR 301g6; July 1, 1991) introduced a 

typographical error by incorrectly changing "in sufficient detail" to "insufficient detail". This 

typographical error was corrected by Revision Checklist 120 (57 FR 61492; December 24, 

1992) to read "in sufficient detail". 

12 When this paragraph was revised by Revision Checklist 120, the instructions for revising it 

were unclear. According to EPA, the last sentence of 264.571 (b), which introduces the 

subparagraphs, is to be removed, as well as subparagraphs (b)(1), (2), and (3). A technical 

correction will be published in the Federal Register in the near future. 

13 Revision Checklist 92 redesignated the original 264.575 (as introduced by Revision Checklist 

82) as 264;572 and redesignated the original 264.572, 264.573 and 264.574 as 264.573, 

264.574 and 264.575, respectively. 

•	 DCWPL94J.15 - Revieed: 09130194 

Page 43 of 45	 Printed: 715196 
SPA 15
 

CONSOLIDATED CHECKLIST: Wood Preserving Listings ; 

. as of June 30, 1994 (cont'd) C' , " 

14 This paragraph was originally introduced into the Federal code as 264.572(a)(4) by 'Revision ", 

Checklist 82 and redesignated as 264.57~(a)(4) by Revision Checklist 92. Revision Checklist 

120 completely revised the paragraph by removing the old 264.573(a)(4) and replacing it with 

264.573(a)(4)(i) and 264.573(a)(4)(ii) . 

15 There are two typographical errors in this paragraph in the Federal Register for Revision 

Checklist 120; in both occurrences, "1 xl 0- 7 " should be "1 xl 0.7. " 

16 Note that the Federal Register for Revision Checklist 120 is in error. According to EPA, the 

last line of 264.573(a)(4)(i) should read" § 264.572(b) instead of § 264.572(a)" rather than 

"§ 264.572(a) instead of § 264.572(b)." As written, the code contradicts what is said in the 

264.572(a)&(b) requirements. 

17 Note that there were two administrative stays at this citation. Revision Checklist 91 (56 FR 

27332; June 13, 1991) added a note regarding an administrative stay with no ending date, for 

pads at 264.572(a)(4). However, 264.572(a)(4) was redesignated as 264.57~(a)(4) by 

revision Checklist 92. Because of this redesignation, the Revision Checklist 91 administrative 

stay was incorrectly omitted in the July 1, 1991 and July 1, 1992CFRs. Revision Checklist 

101 (57 FR 5859; February 18, 1992) added a second note addressing an administrative stay 

for existing 'drip pads at wood preserving plants until October 31, 1992. These notes were 

removed by Revision Checklist 120 (57 FR 61492; December 21, 1992) when the 

administrative stays were terminated by the Federal Register for that checklist. This same 

Federal Register does not clearly indicate that these notes regarding administrative stays be 

removed; however, according to EPA, they should be removed. A technical correction will be .: 

published in the Federal Register in the near future. ./ 

18 Note that a typographical error occurstnthetextot 264.573(a)(5) in the Federal Register 56 

FR 30196 (July 1, 1991; Revision Checklist 92); "daily perations" should be "daily 

operations" as introduced into the code by Revision Checklist 82 (55 FR 50450; December 6, 

1990). 

19 There 'is an error in the Federal Register for Revision Checklist 120 at 264.573(b). According 

to EPA, the phrase" § 264.572(b) instead of § 264.572(a)" likely should be "§ 264.572(a) 

instead of § 264.572(b)." As currently written, the code contradicts the 264.572(a)&(b) 

requirements. 

20 Note that paragraph 264.573(m)(3) was originally 264.572(m)(3) in the Federal Register 55 

FR 50450 (December 6,1990; Revision Checklist 82). This paragraph had an incorrect 

reference; "paragraph (m)(3) of this section" should be "paragraph (m)(l )(iv) of this section." 

This error was addressed by the July 1, 1991 technical corrections to the rule (56 FR 30192; 

Revision Checklist 92). 

21 When this paragraph was revised by Revision Checklist 120, the instructions for revising it 

were unclear. According to EPA, the last sentence of 265.441 (b), which introduces the 

subparagraphs, is to be removed, as well as subparagraphs (b)(1), (2), and (3). A technical 

correction will be published in the Federal Register in the near future. 

22 This paragraph was introduced into the Federal code by Revision Checklist 82 as 

265.443(a)(4). Revision Checklist 120 completely revised the paragraph by removing the old 

265.443(a)(4) and replacing it with 265.443(a)(4)(i) and 265.443(a)(4)(ii). 

DCWPl94J.15 • Revised: 09130/94 Page 44 of 45 Printed: 715/96 

0 
SPA 15
 

\ CONSOLIDATED CHECKLIST: Wood Preserving Ustings 

as of June 30, 1994 (cont'dl • 23 Note thatthe Federal Register for Revision Checklist 120 is in error. According to EPA, the 

last line of 265.443(a)(4)(i) should read" § 265.442(b) instead of § 265.442(a)" rather than 

"§ 265.442(a) instead of § 265.442(b)". As written, the"code contradicts what is said in the 

265.442(a)&(b) requirements. 

24 Revision Checklist 91 added a note regarding an administrative stay with no ending date for 

new drip pads. Revision Checklist 101 added a second note addressing an administrative stay 

for existing drip pads at wood preserving plants until October 31, 1992. These notes were 

removed by Revision Checklist 120 when the administrative stays were terminated by the 

Federal Register for that checklist. This same Federal Register does not clearly indicate that 

the notes regarding the administrative stays be removed; however, accordinqto EPA, they 

should be removed. A technical correction will be published "in the Federal Register in the near 

_future. . 

25 There appears to be an error in the Federal Register for Revision Checklist 120 at 265.443(b). 

The phrase" § 265.442(b) instead of § 265.442(a)" likely should be "§ 265.442(a) instead of 

§ 265.442(b)." As currently written, the code contradicts the 265.442(a)&(b) requirements. 

26 Revision Checklist 82 introduced the original 265.443(b)(2)(ii) into the code. Revision 

Checklist 92 redesignated the oriqina] 265.443(b)(2)(ii) as 265.443(b)(2)(iii) and added a new 

paragraph 265.443(b)(2)(ii). 

•
 

27 Note that 265.443(mH3) in the Federal Register 55 FR 50450 (December 6, 1990; Revision
 

Checklist 82) has an incorrect reference. The reference to "paragraph (m)(3) of this section"
 

should be to "paragraph (m)(1 )(iv) of this section." This error was addressed' by the July 1,
 

1990 technical corrections to the rule (56 FR 30192; Revision Checklist 92).
 

28 Note that the "Special Part B Information Required for Drip Pads" was originally at 270.22 as 

introduced into the code by Revision Checklist 82. The Boilers and Industrial Furnaces rule 

(56 FR 7134; February 21, 1991; Revision Checklist 85) inadvertently removed section 

270.22 from the code. The July 1, 1991 (56 FR 30192; Revision Checklist 92) Wood 

Preserving technical corrections notice rectified this problem by redesignating that section, as 

introduced by Revision Checklist 82, as 270.26. 

• DCWPl94J.15 - Revind: 09130/94 Page 45 of 45 Printed: 715/96