Meeting
With
U.
S.
EPA
April
29,
2005
Southern
Pressure
Treaters
Association
and
Creosote
Council
III
Martin
Rollins,
P.
E.

H.
M.
Rollins
Company,
Inc.

Gulfport,
Mississippi,
Purpose
of
Meeting
°
Discuss
PAC
and
Creosote
Releases
from
Creosote
Wood
Preserving
Industry
°
Present
Data
on
Industry
Storm
Water
Analyses
°
Discuss
Development
of
Factors
to
Estimate
PAC
Releases
Historic
Industry
Data
°
PAC
and
Creosote
Releases
Based
on
Surrogate
Analyses
°
Can't
Analyze
for
"
Creosote"

°
Facilities
Don't
Analyze
Storm
Water
for
PACs
°
Surrogate
Analyte
Normally
Oil
and
Grease
°
PACs
Considered
9.5217%
of
O&
G
°
O&
G
Considered
100%
Creosote
°
Oil
and
Grease
Can
Include
Non­
Creosote
Compounds
°
Industry
Undertook
Study
to
Measure
Actual
PAC
Releases
in
Storm
Water
Industry
Study
°
Sample
Storm
Water
Throughout
Rainfall
Event
°
Analyze
for
PACs
and
Potential
Surrogates
°
Use
Methods
with
Low
PAC
Detection
Limits
°
Develop
Basis
for
Comparison
to
Earlier
Data
°
Ten
Facilities
Provided
Data
°
Most
Large
Facilities
°
Most
Facilities
with
High
Reported
PAC
Releases
Results
°
74
Storm
Water
Samples
Taken
°
37
Samples
Had
Positive
Result
for
One
or
More
PACs
°
Fluoranthene
Only
Compound
Found
in
All
37
Samples
°
Fluoranthene
78%
of
PAC
Mass
°
37
Samples
ND
for
PACs
°
Oil
and
Grease
and
TOC
Possible
Suitable
Surrogates
Results
­
Continued
°
No
Clear
Declining
Trend
with
Rainfall
Duration
°
Highest
Total
PAC
Concentration
156.6
ppb
°
O&
G
Results
­
High
19ppm­
53
NDs
°
TOC
Ranged
from
3.6
to
166
ppm
°
Ratio
of
PACs
to
O&
G
and
TOC
Based
on
Positive
PACs,
<
1.23%
and
0.13%

Respectively
Results
­
Continued
°
Ratio
of
PACs
to
O&
G
and
TOC
Based
on
ND
for
PACs,
<
0.21%
and<
0.47%

Respectively
°
Average
for
Two
Indicates
PACs
Are
<
0.72%

of
O&
G
Result
and
<
0.30%
of
TOC
Result
Summary
and
Conclusions
°
Historic
Reported
Releases
of
PACs
Are
Grossly
Overestimated
°
Overstated
By
at
Least
One
Order
of
Magnitude
°
Based
on
These
Actual
Analyses
for
PACs,

Historic
Creosote
Reported
Releases
Are
Also
Overestimated
Future
Actions
°
Guidance
Will
Be
Provided
to
Industry
to
Estimate
PAC
Releases
as
0.72%
of
Annual
Average
O&
G
Result
or
0.3%
of
Annual
Average
TOC
Result
°
If
All
Surrogate
Analytical
Results
are
ND
at
Appropriate
Method
Detection
Limits
for
a
Reporting
Year
Then
Facility
Will
Report
Zero
for
Estimated
PAC
Releases
°
Industry
May
Amend
Prior
Year
TRI
Reports
Discussion
and
Identification
of
Remaining
Issues
Thank
You
for
the
Opportunity
to
Provide
This
Input!
