Wood Treatment Sector

Background:

The EPA Region 7 RCRA Program chose the wood treatment sector as part of the RCRA Permit Evader Universe for inspection during Fiscal Year 2000. As part of these inspections, environmental samples were collected to provide information concerning whether or not releases of hazardous wastes had occurred.

As a result of the RCRA inspections performed at the EPA R7 wood treatment facilities during FY2000, it was determined that most of the facilities had significant noncompliance issues. Violations observed at the facilities included but were not limited to:

• failure to make hazardous waste determinations (40 CFR 262.11);
  
• failure to notify of hazardous waste activity (40 CFR 262.12(a));
  
• illegal treatment, storage, and/or disposal of hazardous wastes (RCRA §3005, 40 CFR 262.34(a) and (b));
  
• failure to handle hazardous wastes in such a manner as to minimize the possibility of release into the environment (40 CFR 265.31); and/or
  
• failure to comply with drip pad regulations (40 CFR 265 Subpart W).