October
8,
2004
Mr.
Carey
A.
Johnston
4303T
USEPA
Headquarters
Ariel
Rios
Building
1200
Pennsylvania
Avenue,
N.
W.
Washington,
DC
20460
Subject:
TWPE
for
PAC
Releases
Associated
with
Creosote
Wood
Preserving
Facilities
in
SIC
Code
2491
Dear
Mr.
Johnston:

I
am
writing
you
on
behalf
of
our
membership
that
treats
with
the
wood
preservative
creosote.
As
we
have
been
monitoring
the
Effluent
Guidelines
Program,
several
issues
have
arisen.

First
issue
deals
with
the
toxic
weighting
factor
(
TWF).
In
the
Timber
Industry
memo
that
you
provided
the
industry
on
June
8,
2004,
the
TWPE
for
the
PACs
associated
with
creosote
were
apparently
calculated
on
the
basis
of
a
toxic
weighting
factor
(
TWF)
of
approximately
66.
This
is
confirmed
on
page
4­
16
of
the
Technical
Support
Document
for
the
2004
Effluent
Guideline
Program
Plan,
which
states
that
the
Agency
computed
a
TWF
of
65.78
for
the
PACs
associated
with
creosote.
We
have
been
unable
to
find
the
document
that
details
the
Agency's
computation
of
the
65.78
TWF.
Could
you
please
direct
us
to
the
source
for
this
number?

The
second
issue
concerns
PACs.
In
most,
if
not
all
cases,
the
PACs
reported
by
creosote
wood
treating
facilities
are
not
based
on
any
actual
analyses
for
polycyclic
aromatic
compounds.
In
general,
creosote
releases
are
estimated
based
on
some
surrogate
analyte,
such
as
oil
and
grease
or
total
phenols,
since
there
is
no
standard
method
for
the
quantitation
of
creosote.
We
believe
that
PAC
estimates
were
derived
from
creosote
estimates,
but
we
do
not
believe
that
everyone
who
reported
for
PACs
took
a
consistent
approach.
Most
of
the
surrogate
analyses
come
from
samples
taken
as
part
of
required
storm
water
sampling,
and
these
are
taken
in
the
first
30
minutes
of
run­
off
and
this
is
expected
to
provide
concentrations
higher
than
a
true
average
for
all
run­
off.
SOUTHERN
PRESSURE
TREATERS
ASSOCIATION
P.
O.
Box
3219
206
Beverly
Loop
Pineville,
LA
71361­
3219
TEL
318­
619­
8589
FAX
318­
767­
1388
sptala@
bellsouth.
net
CHARTERED
1954
Given
these
shortcomings
in
the
present
estimating
techniques,
the
industry
is
going
to
attempt
to
develop
storm
water
data
based
on
actual
analyses
for
PACs.
Analyses
for
the
conventional
surrogate
parameters
will
be
conducted
concurrently
so
that
a
relationship
can
be
established
upon
which
adjustments
to
prior
estimates
of
PACs
can
be
made.
The
industry
is
going
to
undertake
this
data
gathering
during
the
balance
of
2004,
and
we
should
have
data
to
share
with
the
Agency
in
early
2005.

We
are
confident
that
actual
data
coupled
with
a
technically
sound
TWF
will
demonstrate
to
the
Agency
that
the
surface
water
impacts
associated
with
this
industry
are
very
minimal
and
do
not
warrant
the
investment
of
Agency
resources
necessary
to
promulgate
revised
effluent
standards
for
the
Timber
Products
Processing
Subcategory.

We
would
be
happy
to
meet
with
you
at
any
time
to
discuss
these
issues,
but
it
may
be
most
productive
to
wait
until
our
new
data
is
available.
In
the
meantime,
we
would
appreciate
the
opportunity
to
review
the
methodology
used
to
develop
the
65.78
toxic
weighting
factor
used
by
the
Agency.

Thank
you
for
your
time
and
consideration.

Sincerely,

Carl
Johnson
Executive
Director
Southern
Pressure
Treaters
Association
P.
O.
Box
3219
Pineville,
LA
71361­
3219
Office:
318­
619­
8589
Fax:
318­
767­
1388
Email:
sptala@
bellsouth.
net
