The US EPA has issued the following options for former CCA Treating Plants:

• Complete Closure This option allows facilities to be completely deregulated from Subpart W; meaning no handling of hazardous waste, no annual certification by Professional Engineers and no limited access of forklifts. This is the most labor intensive option and requires extensive cleaning of the drip pad and soil, water and surface sampling.
• Continued Operation This option requires facilities to do nothing; however, the facility must continue to meet all the requirements applicable to Subpart W drip pads.
• Phased (Partial) Closure This option allows facilities to be partially deregulated from Subpart W. Certain requirements such as the annual certification by a Professional Engineer will still be applicable. This option requires cleaning and limited surface sampling. Also, a complete closure will still be required in the future.

Ultimately, the State Agencies determine what criteria a facility must meet to obtain complete or partial closure of a Drip Pad. It is important to establish open communication with the State Agencies to negotiate favorable terms and obtainable goals during the closure process. Different states favor different cleaning and sampling methods, and it is important to understand the advantages and disadvantages of these methods.

A Consultant experienced in dealing with various states and utilizing different sampling techniques can help you avoid costly pitfalls many facilities face while navigating the closure maze.

• Closure of a treating facility in Georgia
  A single cylinder treating plant was closed and treating equipment moved to another facility for operation as a non-CCA treating facility. The drip pad was decontaminated and removed from regulation under Subpart W and as a hazardous waste generator, allowing use of the covered concrete for lumber storage.
• Closure of a treating facility in South Carolina
  A double cylinder treating plant was converted to a treating facility using a non-CCA treating chemical. The equipment and drip pad was decontaminated. The drip pad was removed from regulation under Subpart W allowing the use of the drip pad for lumber treated with non-CCA chemicals without hazardous waste being generated.
• Closure of a treating facility in Georgia
  A single cylinder treating plant was closed. The drip pad was decontaminated and removed from regulation under Subpart W allowing the facility to be permanently closed and sold to a company not involved in lumber treating.
• Closure of a treating facility in North Carolina
  A double cylinder treating plant was closed. The drip pad was decontaminated and removed from regulation under Subpart W allowing the facility to be permanently closed.
• Phased Closure of a treating facility in Georgia
  A single cylinder treating plant was converted to a treating facility using a non-CCA treating chemical. The equipment and drip pad was decontaminated. Significant requirements associated with Subpart W regulations were eliminated from the drip pad allowing the use of the drip pad for lumber treated with non-CCA chemicals without hazardous waste being generated.