FormRGuide.
doc
5/
23/
05
Creosote
Council
III
Post
Office
Box
160
Valencia,
Pennsylvania
16059
Phone:
724­
898­
9663
e­
mail:
davidawebb@
aol.
com
May
24,
2005
Re:
Guidance
for
Reporting
Creosote
and
Polycyclic
Aromatic
Compound
Releases
to
Storm
Water
Dear
Creosote
Wood
Treater:

Last
year,
as
part
of
its
biennial
review
of
effluent
guidelines,
the
U.
S.
EPA
identified
the
wood
preserving
industry
as
a
significant
source
of
toxic
pollutants
discharged
to
storm
water.
One
of
the
major
sources,
as
reported
on
the
SARA
Section
313
Toxic
Chemical
Release
Inventory
(
TRI),
is
the
storm
water
discharge
of
polycyclic
aromatic
compounds
(
PACs)
by
creosote
wood
preserving
facilities.
Investigations
revealed
that
the
releases
reported
by
the
industry
were
not
based
on
actual
analyses
for
PACs.
They
were,
instead,
being
estimated
based
on
a
published
PAC
percentage
in
creosote
and
the
assumption
that
a
surrogate
analyte,
such
as
Oil
&
Grease,
could
be
used
to
provide
a
reliable
estimate
of
concentrations
of
creosote.
Industry
representatives
met
with
EPA
to
discuss
the
reported
releases
and
the
methods
used
to
make
the
prior
estimates.

Under
the
leadership
of
the
Southern
Pressure
Treaters'
Association
(
SPTA)
and
Creosote
Council,
the
industry
undertook
a
study
to
determine
the
actual
concentration
of
PACs
in
storm
water
at
creosote
wood
preserving
facilities.
This
study
was
presented
to
EPA,
and
the
results
of
the
study
indicated
that
the
previous
estimates
reported
on
the
TRI
reports
were
overstated
by
about
one
order
of
magnitude,
or
a
factor
of
ten.

EPA
encouraged
the
industry
to
correct
its
previous
reports
and
to
develop
a
more
accurate
and
uniform
protocol
for
estimating
and
reporting
these
releases
in
the
future.
Utilizing
the
data
from
the
storm
water
sampling
study,
factors
have
been
developed
and
are
now
available
for
use
by
the
industry
at
this
time.
Although
each
industry
member
is
responsible
for
its
own
data
submissions,
including
any
analyses
and
any
factors
it
may
rely
on,
the
Creosote
Council
believes
that
use
of
the
factors
provided
below,
in
place
of
the
previous
methods
of
estimation
referenced
above,
will
significantly
improve
the
accuracy
and
reliability
of
creosote
discharge
calculations.
The
development
of
these
factors
has
been
discussed
with
EPA,
but
no
formal
approval
has
been
sought
nor
is
it
expected.
It
is
possible
that
these
factors
may
be
adjusted
in
the
future
based
on
additional
data
or
suggestions
that
may
be
made
by
EPA.

It
is
extremely
important
that
the
industry
provide
the
most
precise
and
accurate
estimate
of
releases
possible.
If
the
effluent
guidelines
for
the
wood
preserving
industry
are
selected
for
regulatory
action,
it
is
probable
that
discharge
limits
would
be
established
that
would
require
capture
and
treatment
of
all
storm
water.
Since
this
could
require
the
capture
and
treatment
of
millions
of
gallons
of
water
in
a
typical
storm
event
in
many
parts
of
the
country,
this
borders
on
an
operational
impossibility.
This
highlights
the
importance
of
providing
the
Agency
with
consistent
and
accurate
data.

The
following
approach
for
estimating
releases
of
creosote
and
polycyclic
aromatic
compounds
has
been
developed
by
knowledgeable
industry
representatives
based
on
the
data
contained
in
the
storm
water
study.
This
guidance
is
based
on
using
Oil
&
Grease
(
O&
G)
or
Total
Organic
Carbon
(
TOC)
analytical
results
as
the
basis
for
estimating
creosote
and
PAC
concentrations
in
storm
water.
In
particular,
O&
G
is
a
parameter
that
is
almost
universally
required
to
be
monitored
in
storm
water
permits
issued
to
creosote
wood
preserving
facilities.
It
is
important
that
the
analytical
method
and
the
laboratory
used
are
capable
of
obtaining
a
reasonably
low
detection
limit.
Typically,
a
detection
limit
of
5
parts
per
million
(
ppm)
or
less
can
be
achieved
for
O&
G.

Based
on
the
results
of
the
storm
water
study,
the
concentration
of
PACs
in
storm
water
is
no
more
than
0.72%
of
the
O&
G
value,
or
no
more
than
0.30%
of
the
TOC
value.
These
results
may
be
used
to
estimate
concentrations
of
PACs
in
storm
water
by
applying
the
factor
of
0.72%
to
a
measured
O&
G
concentration,
or
a
factor
of
0.30%
to
a
measured
TOC
concentration.
Although
there
is
some
TRI
guidance
which
indicates
that
if
all
of
the
storm
water
analyses
in
a
reporting
year
are
below
the
method
detection
limit
it
is
acceptable
to
report
zero
for
that
parameter,
Creosote
Council
is
aware
that
a
preferred
approach
among
members
of
our
industry
to
estimate
releases
is
to
use
a
concentration
value
equal
to
one­
half
the
detection
limit
for
those
analyses
reporting
the
concentration
as
non­
detected.

Since
the
surrogate
analytes
of
O&
G
and
TOC
will
include
many
organics
not
associated
with
creosote,
the
prior
use
of
these
parameters
as
estimates
of
creosote
has
resulted
in
the
overestimation
of
creosote
releases
to
storm
water.
Given
that
there
is
no
recognized
analytical
method
for
quantifying
creosote
in
aqueous
samples,
an
engineering
estimate
must
be
made
based
on
the
data
available.
The
product
chemistry
of
creosote
provided
by
the
American
Wood
Preservers
Institute
indicates
that
PACs
represent
a
little
less
than
10%
of
the
composition
of
creosote.
Therefore,
on
a
product
chemistry
basis,
an
estimated
creosote
release
would
be
expected
to
be
about
10
times
the
PAC
release.
However,
to
account
for
some
variability
in
constituent
solubilities
and
the
possibly
changing
chemical
makeup
of
rainfall
runoff
that
has
contacted
treated
products
based
on
the
time
period
since
the
material
was
treated,
Creosote
Council
is
aware
that
a
preferred
approach
among
members
of
our
industry
is
the
conservative
use
of
a
factor
of
20,
applied
to
the
PAC
estimate,
for
the
calculation
of
estimated
creosote
FormRGuide.
doc
5/
23/
05
concentrations.
This
results
in
a
factor
of
14.4%
(
20
x
0.72)
to
be
applied
to
the
O&
G
result,
or
6.0%
(
20
x
0.3)
to
be
applied
to
a
TOC
result,
to
estimate
creosote
concentrations.
Once
again,
many
of
our
industry
members
prefer
the
use
of
one­
half
the
detection
limit
for
all
non­
detect
values.

This
guidance
is
being
provided
at
this
time
to
enable
facilities
that
may
wish
to
do
so
to
apply
this
guidance
in
completion
of
their
TRI
reports
for
reporting
year
2004,
which
are
due
on
July
1,
2005.
Creosote
Council
will
be
providing
additional
guidance
this
summer
regarding
the
amendment
of
prior
year
reports
in
order
to
correct
the
existing
TRI
database.
This
needs
to
be
done
so
that
EPA
has
a
clear
public
record
to
support
its
determination
regarding
its
prioritization
of
industries
for
regulatory
action
under
its
effluent
guidelines
program.

If
you
have
any
technical
questions
regarding
the
guidance
contained
in
this
document,
please
contact
Martin
Rollins
of
H.
M.
Rollins
Company,
Inc.,
who
assisted
Creosote
Council
and
SPTA
in
this
effort.
He
can
be
reached
at
(
228)
832­
1738,
or
by
email
at
martinrollins@
hmrollins.
com.

If
you
have
any
comments
or
suggestions
on
this
guidance,
please
let
me
know.

Sincerely,

David
A.
Webb
Administrative
Director
Creosote
Council
III
cc:
Mr.
Lawrence
S.
Ebner,
Esq.
Creosote
Council
III
Members
