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 must come with a consumer information sheet. There appears to be no recent revisit of that issue
by EPA.
A serious potential concern is EPA regulations that address "discharges" into U.S. waters
that would violate federal clean water standards. To our knowledge, however, the placement of
treated wood in the marine environment has not been challenged by the federal EPA on these
grounds nor does it appear likely based on our review of the FR. However, an oil sheen on the
water occurs when driving creosote piling in apparent violation of these regulations. This can be
mitigated by the use of oil booms or other approved means but consultation with local
environmental authorities may be advisable.
It should be noted that proper treatment "fixes" or renders insoluble the arsenical salts and
that proper procedures minimizes the bleeding of creosote from the wood. The long-term
efficiency of the preservative treatment is dependent on minimizing the leaching or bleeding of
preservatives. Some loss, however, does occur especially when the treatment process has not
adequately "fixed" the arsenical salts or there is a large amount of creosote on the wood surface.
In any case, preservative loss is greatest immediately after installation and diminishes with time.
The potential for salt leaching and creosote migration into the water is the greatest concern of
local agencies and generally is the focus of regulatory action.
In terms of EPA hazardous waste regulations, wood preservatives such as creosote and
arsenical salts to be discarded are considered hazardous wastes but treated wood products
removed from service are not. The treated wood is considered a non-RCRA solid waste and can
be placed in a landfill. A review of recent publications of the Federal Register has provided no
indication that EPA will alter the status of waste creosote-treated or arsenical salt-treated wood in
the immediate future. The EPA established an exemption for arsenical-treated wood that fails the
TCLP procedure used to define toxicity characteristic hazardous wastes. TCLP testing of
creosote-treated wood has consistently revealed that it is far below toxicity characteristic limits.
A review of recent pertinent industry publications and wood products journals revealed
that the only imminent change in federal environmental regulations that would impact the use and
disposal of treated wood products involved wood treated with pentachlorophenol (penta). Penta,
however, is not used for marine wood treatments. There has been some concern expressed,
however, that cradle-to-grave requirements for treated products may be coming. This cradle-to-
grave requirement may be related to landfill restrictions rather than a redefinition of treated wood
as hazardous waste.
Local Environmental Considerations
To determine if current practices are in the best interests of the Navy in light of current
and potential future environmental regulations is a complex question. In consideration of current
federal regulatory compliance and the economics of -wood usage, it would appear to be in the
Navy's best interest to continue wood usage for the foreseeable future. When local environmental
rules are applied there can be no generalization and it may very well be in the Navy's best interest
to not attempt to use treated wood at those sites.
It is obvious that where local environmental regulatory agencies directly impact the usage
of treated wood, local decisions must be made. These seem to be happening with increasing
frequency. For example, the Navy Public Works Center in San Diego has reported that they were
cited and threatened with fines up to $500K by the County of San Diego Department of Public
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