On August 26, 2021, EPA-Region III signed a Consent Agreement and Final Order with Jefferson Homebuilders, Inc., doing business as Culpeper Wood Preservers ( Culpeper ) for improper facility hazardous waste management methods and substandard wood preserving drip pad conditions, among other violations of regulatory requirements of the Resource Conservation and Recovery Act ( RCRA ). The agreement, which contains both a Consent Agreement and Compliance Order, initiated and resolved the matter.
The wood preserving industry utilizes expansive floor areas of concrete pads, called drip pads, to catch excess wood preservative liquid that drips from treated wood to prevent its seepage into soil or groundwater. The Facility produces preservative-treated wood for marine and other construction uses. The process formerly utilized copper chromated arsenic ( CCA ) as a wood preservative on its drip pads, until it was outlawed for commercial use circa 2003.
Since 2003, the Facility has treated wood with Micronized Copper Azole ( MCA ), a RCRA hazardous waste. The wood treatment process also generates hazardous waste from sweepings and the cleaning of the treatment cylinders and drip pads. RCRA Subtitle C regulations, include Subpart W, specific requirements for drip pads, for which Culpeper had both drip pad and record-keeping violations. The Consent Agreement and Compliance Order required Culpeper to certify that it is now in compliance and to pay a $25,930.00 penalty.