United States Control Technology EPA-450/3-89-028
Environmental Protection Center June 1989
Agency Research Triangle Park NC 27711
SEPA
Evaluation of
Emission Sources from
Creosote Wood Treatment
Operations
control & technology center
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EPA-450/3-89-028
June 1989
EVALUATION OF EMISSION SOURCES
FROM CREOSOTE WOOD TREATMENT OPERATIONS
PREPARED BY:
Charles C. Vaught and Rebecca L. Nicholson
Midwest Research Institute
Suite 350
401 Harrison Oaks Boulevard
Gary, N.C. 27513
EPA Contract No. 68-02-4379
Prepared for:
Control Technology Center
U. S. Environmental Protection Agency
Research Triangle Park, NC 27711
Bruce Moore
Work Assignment Manager
Office of Air Quality Planning and Standards
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
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DISCLAIMER
This document presents the results of an engineering evaluation of
emission sources from creosote wood treatment operations. Specifically,
the document discusses the history of the wood preserving industry, the
various techniques used to preserve wood, and the air emissions associated
with the Boulton process. The EPA does not represent that this document
comprehensively sets forth all of the procedures used in wood treatment
operations, or that it describes applicable legal requirements which vary
among the States.
Mention of trade names or commercial products does not constitute
endorsement or recommendation for use.
11
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ACKNOWLEDGEMENT
This engineering assistance report for wood treatment operations was
prepared for EPA's Control Technology Center (CTC) by C. C. Vaught, and
R. L. Nicholson of Midwest Research Institute. Bruce Moore of EPA's
Office of Air Quality Planning and Standards was the Work Assignment
Manager.
m
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PREFACE
The wood treatment engineering assistance project was funded by EPA's
Control Technology Center (CTC). The CTC was established by EPA's Office
of Research and Development (ORD) and Office of Air Quality Planning and
Standards (OAQPS) to provide technical assistance to State and local air '
pollution control agencies. Three levels of assistance can be accessed
through the CTC. First, a CTC HOTLINE has been established to provide
telephone assistance on matters relating to air pollution control
technology. Second, more in-depth engineering assistance can be provided
when appropriate. Third, the CTC can provide technical guidance through
publication of technical guidance documents, development of personal
computer software, and presentation of workshops on control technology
matters.
The engineering assistance projects, such as this one, focus on
topics of national or regional interest that are identified through
contact with State and local agencies. In this case, the CTC was
contacted by the Virginia A1r Pollution Control Board with a request for
information about odor (and potential air toxics) control at creosote wood
treatment facilities. Specifically, the agency requested available
information on controls designed to limit emissions during the time the
treated wood is withdrawn from the retort and is cooled outdoors. As a
result, the EPA's Emission Standards Division (ESD) contracted with the
Midwest Research Institute (MRI) to conduct an engineering evaluation of
the wood preserving process. This report presents the results of that
evaluation. The report discusses the history of the wood preserving
industry, the various techniques used to preserve wood, and the air
emissions associated with the Boulton process.
111
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TABLE OF CONTENTS
Page
LIST OF TABLES v
SECTION 1.0 INTRODUCTION 1
SECTION 2.0 THE WOOD PRESERVING INDUSTRY—PAST AND PRESENT 2
2.1 HISTORICAL SKETCH 2
2.2 CURRENT INDUSTRY STATUS 3
SECTION 3.0 OVERVIEW OF WOOD PRESERVATION 9
3.1 WOOD PRESERVATIVES 9
3.1.1 Preservative 011s 9
3.1.1.1 Coal-Tar Creosote 12
3.1.1.2 Creosote Solutions 15
3.1.1.3 Pentachlorophenol Solutions 15
3.1.2 Waterborne Preservatives 16
3.2 CONDITIONING TREATMENTS 16
3.2.1 Steaming-and-Vacuum Process 17
3.2.2 Boulton (Boiling-Under-Vacuum) Process 18
3.2.3 Vapor-Drying Process 19
3.3 PRESSURE PROCESSES 19
3.3.1 Full-Cell Process 20
3.3.2 Modified Full-Cell Process 20
3.3.3 Empty-Cell Process 21
3.3.3.1 Rueping Process 21
3.3.3.2 Lowry Process 21
SECTION 4.0 AIR EMISSIONS AND CONTROLS 23
4.1 TREATED CHARGE 23
4.2 VACUUM SYSTEM 25
4.3 WORKING TANK BLOW BACKS 27
SECTION 5.0 CONCLUSIONS 29
SECTION 6.0 REFERENCES 34
APPENDIX A. TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM—KOPPERS
APPENDIX B. TRIP REPORTS
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LIST OF TABLES
Page
TABLE 1. PRODUCTION VOLUME OF TREATED WOOD IN THE UNITED STATES
IN 1986 4
TABLE 2. WOOD PRESERVING PLANTS IN THE UNITED STATES, BY REGION
AND STATE 5
TABLE 3. TREATED WOOD PRODUCTION, 1986 7
TABLE 4. TREATED WOOD PRODUCTION BY TYPE OF PRESERVATIVE—PRESSURE
TREATING PLANTS, 1986 8
TABLE 5. PRESERVATIVES AND MINIMUM RETENTIONS FOR VARIOUS WOOD
PRODUCTS 10
TABLE 6. PHYSICAL AND CHEMICAL PROPERTIES OF CREOSOTE 13
TABLE 7. MAJOR COMPONENTS IN CREOSOTE 14
TABLE 8. EMISSION SOURCES AND DEMONSTRATED EMISSION CONTROL
TECHNOLOGIES 30
TABLE 9. COMPARISON AND CONTRAST OF KOPPERS AND JENNISON-WRIGHT
WOOD TREATMENT PROCESSES 31
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1.0 INTRODUCTION
Wood preservation is the pressure or thermal impregnation of
chemicals into wood to a depth that will provide effective long-term
resistance to attack by fungi, insects, and marine borers. By extending
the service life of available timber, wood preservation reduces the
harvest of already stressed forestry resources, reduces operating costs in
industries such as utilities and railroads, and ensures safe working
conditions where timbers are used as support structures.
The three preservatives predominantly used in the U.S. for wood
preservation are pentachlorophenol; creosote; and aqueous formulations of
arsenic, copper, chromium or ammonia.
The wood preservation process deposits or fixes these chemicals in
the wood, and the toxic nature of the chemicals effectively prevents the
attack of living organisms on the wood. Because the chemicals are also
toxic to varying degrees to humans and aquatic organisms, their use in
industry must be carefully controlled. This document will discuss each of
the preservatives and the various processes used to treat a variety of
wood products concentrating on the use of creosote for the treatment of
crossties. Of particular concern will be the emission sources associated
with the release of odor and air toxics and the technologies currently in
use to control them.
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2.0 THE WOOD PRESERVING INDUSTRY—PAST AND PRESENT
2.1 HISTORICAL SKETCH
The need to protect wood from various forms of decay has been
recognized since ancient times. The use of chemical preservatives to
perform this function did not come into widespread use in this country
until the early 1900's. At that time, the expansion of railroad systems
throughout the country created a need for a durable, weather-resistent
material from which railroad ties could be made. Wood treatment with
creosote, an oily liquid mainly consisting of aromatic hydrocarbons, was
found to fill the need, resulting in large-scale use of creosote-treated
products.
The need for a building material that could survive in marine
environments presented another use for preserved wood. Again, creosote
was found to be effective in most instances, providing protection to
docks, underwater posts, and wharfs. However, attack by the marine borer
Limnoria trlpunctata, commonly known as "gribble," can destroy creosote-
treated wharfs. This led to the discovery that a dual treatment of copper
arsenate salts followed by creosote was successful in resisting gribble
attack.
There was also a need for a clean, more paintable product not having
the appearance or odor of creosote-treated "wood. Therefore, an intensi-
fied search for alternatives to creosote was undertaken. Two types of
preservatives were identified to achieve this: waterborne preservatives—
inorganic salts in a water carrier, and pentachlorophenol (PCP)—a
crystalline compound applied in a light oil carrier. Both provided
protection from decay while producing a product that could be used in many
applications where creosote-treated products could not.
With treated wood products successfully demonstrated, utility
companies, construction companies, steamship lines, road maintenance
organizations, and various other groups saw potential uses for treated
wood. These uses would ultimately include poles, pilings, plywood, fence
posts, guardrails, bridge structures, boardwalks, and other lumber and
timber products. New demands for treated wood created a need for more
versatile products and a much greater production capacity.
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2.2 CURRENT INDUSTRY STATUS
A recent survey of the wood preserving industry reports that 588 wood
preserving plants were in operation in 1986.: Most treatment plants (508)
used only one type of preservative: 414 treated only with waterborne
preservatives, almost all of which were arsenicals; 58 treated only with
creosote; and 36 treated only with pentachlorophenol. The other 80 active
plants used various combinations of two or more preservatives. The total
industry consumption of preservative and fire retardants in 1986 was
reported as follows:1
1. 117 plants treating with creosote solutions consumed 89.9 million
gallons of creosote and creosote-coal tar, and 16.5 million gallons of
petroleum solvent to treat 119 million ft of wood products.
2. 96 plants treating with pentachlorophenol consumed 22.1 million
pounds of pentachlorophenol and 32.4 million gallons of petroleum solvent
to treat 50 million ft3 of wood products.
3. 475 plants treating with waterborne preservatives consumed
130.8 million pounds of preservative salts to treat 375 million ft3 of
wood products.
4. 79 plants treating with fire retardants consumed 24.6 million
pounds of fire retardant chemicals to treat 10 million ft3 wood
products. A more detailed products breakdown 1s presented in Table 1.
Seventy-five percent of the' wood treatment plants in the U.S. are
concentrated in two distinct regions. One area extends from east Texas to
Maryland and corresponds roughly to the natural range of southern pines,
the major species utilized. The second, smaller area is located along the
Pacific coast, where Douglas fir and western red cedar are the predominant
species. The remaining 25 percent of plants are scattered throughout the
U.S. Table 2 presents the distribution of wood preserving plants in the
U.S. in 1986 by State and region. The production of treated wood in 1986
is listed 1n Table 3 by U.S. region for 518 reporting plants. Table 4
presents the production data for pressure treating plants 1n 1986 by type
of preservative used.
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TABLE 1. PRODUCTION VOLUME OE TREATED WOOD IN THE UNITED STATES IN 1986
(ft treated xl.OOO)
Volume treated with
Products
Crosstles
Switch and bridge ties
Poles
Piling
Fence posts
Lumber
Timbers
Plywood
Other products
All products— 1986
Creosote
solutions
79.858
5,907
16,196
5,342
1,674
3.517
2,893
—
3,362
118.749
Penta-
chlorophenol
585
—
42.003
237
1.647
2,778
878
34
1.322
49.484
Waterborne
preservatives
—
—
15,142
4,903
14,020
285.718
28.389
4.924
22,362
375.458
F1re
retardants
—
—
—
—
—
5.862
119
4,344
87
10,412
All
chemicals
80.443
5.907
73,341
10,482
17,341
297.875
32.279
9,302
27.133
554.103
aCreosote, creosote-coal tar, and creosote-petroleum.
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TABLE 2. WOOD PRESERVING PLANTS IN THE UNITED STATES,
BY REGION AND STATE
Active plants, 1986
Northeast
Connecticut
Maine
Maryland
Massachusetts
New Hampshire
New Jersey
New York
Pennsylvania
Rhode Island
Vermont
West Virginia
TOTAL
North Central
1 1 1 inois
Indiana
Iowa
Kansas
Kentucky
Michigan
Minnesota
Missouri
Nebraska
North Dakota
Ohio
Wisconsin
TOTAL
Southeast
Florida
Georgia
North Carol ina
South Carol ina
Virginia
Puerto Rico
TOTAL
South Central
A 1 abama
Arkansas
Louisiana
Mississippi
Oklahoma
Tennessee
Texas
TOTAL
Rocky Mountain
Arizona
Colorado
Idaho
Montana
New Mexico
South Dakota
Utah
Wyoming
TOTAL
Pressure
1
1
9
4
1
4
10
21
1
12
5*
12
10
1
1
10
14
6
13
2
1
11
9*
38
55
31
15
30
5
T75
52
21
26
26
3
8
32
T55
1
7
5
3
1
5
2
3
27
Nonpressure
1
T
1
2
4
7
1
1
2
1
T
3
2
1
5
Total Inactive, 1986 New plants, 1987
1
1
9
4
1
4
10
21
1
1
13 1
57 2 o
12 2
10 i
1
i
10
15 1
8 1
17 1
2
1
11 1
13 1
TOT 3 5
38 1
55 2
32 1
15
31 1
5
T75 2 *
52 1
21
26 1
26
3
8
33
T55 ' 2 5
1
7
8
5
1
5
3
3
33
(continued)
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TABLE 2. (continued)
Active plants, 1986
Pacific Coast
California
Oregon
Wash I ngton
Hawai I
TOTAL
UNITED STATES
Pressure
14
9
13
7
43
570
Nonpressure
1a
T
18
Total
14
,!«
7
w
588
Inactive, 1986 New plants, 1987
1
5 T
9 16
aIncludes one plant located in British Columbia.
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TABLE 3. TREATED, WOOD PRODUCTION, 1986
(ft xl.OOO)
Region
Northeast
North Central
Southeast
South Central
Rocky Mountain
Pacific Coast
All Regions
No. of
plants
reporting
54
87
164
144
27
42
518b
Volume treated with
All
chemicals
46,661
72,637
165,084
155.891
9,665
53,746
503.681
Creosote
solutions*
11.245
21,159
14,906
50,097
1,585
10,986
109,977
Penta-
chlorophenol
769
6,125
8,172
18,633
2,849
10,213
46.761
Waterborne
preservatives
33,357
43,949
138,584
85,344
5,042
31,228
337,503
F1re
retardants
1,290
1,404
3,422
1,817
189
1,319
9.440
Note: Components may not add to totals, due to rounding.
^Creosote, creosote-coal tar, and creosote-petroleum.
"Includes 500 pressure-treating plants and 18 nonpressure-treatlng plants.
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TABLE 4. TREATED WOOD PRODUCTION BY TYPE OF PRESERVATIVE—PRESSURE TREATING PLANTS, 19861
oo
Plants treating with
Creosote
Creosote/pen ta
Creosote/water
Penta/water
Penta
Water
Water/FR
Creosote/penta/Mater
ALL PLANTS
No. of
plants
SI
15
15
19
17
299
62
19
497
No. of
retorts
134
44
44
45
23
391
126
90
897
Retorts
void, ft3
634,014
212,500
125.076
136,691
56,308
661 ,653
220,828
412,849
2,459,919
Vo 1 ume
of wood
treated, ft3
70,927,939
20,777,172
19,372,768
23,193,569
5,639,070
228,256,413
78,620,169
44,219.047
491,006,147
Volume treated with (ft3x 1,000)
Creosote
70,928
8,707
1 1 ,977
~
--
~
—
18,357
109,969
Penta
___
12,070
—
9.426
5,639
—
—
13,725
40.861
Water
__
~
7,120
13,576
~
228,256
70,422
11,363
330,736
FR°
_ ,_
—
276
192
~
~
8.198
774
9.440
Volume
treated
per ft3
cyl Inder
volume
111.9
97.8
154.9
169.7
100.1
345.0
356.0
107.1
Note: Nonpressure plants are excluded.
BFR = fire retardant.
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3.0 OVERVIEW OF WOOD PRESERVATION
This chapter discusses the types of preservatives used to treat
various wood products and the processes by which these preservatives are
applied. The wood treatment process generally has two stages, a
conditioning stage that serves to remove moisture from the wood (which
allows for greater penetration of preservative) followed by a treatment
stage during which the preservative is forced into the wood, usually by
means of pressure.
3.1 WOOD PRESERVATIVES
Wood preservatives fall into two general classes: oils, such as
creosote and petroleum solutions of pentachlorophenol, and waterborne
salts that are applied as water solutions. Preservatives vary greatly in
effectiveness and in suitability for different purposes and use
conditions. The effectiveness of any preservative depends not only upon
Its composition but also upon the quantity injected into the wood, the
depth of penetration, and the conditions to which the treated material 1s
exposed in service.2
Table 5 shows the types of preservative oils and waterborne salts
that are used to treat various types of wood products and the minimum
required preservative retention (pounds of preservative per cubic foot of
wood) for each product/preservative combination. Although the majority of
wood products are treated with waterborne preservatives, this report is
concerned with the odors that are emitted when creosote or creosote
solutions are used. Therefore, the following discussions focus primarily
on creosote and creosote solutions and the types of wood treatment
processes that use these preservative oils.
3.1.1 Preservative 011s
Creosote and solutions with heavier, less volatile petroleum oils
often help protect wood from weathering but may adversely Influence its
cleanliness, odor, color, paintabllity, and fire resistance. Volatile
oils or solvents with oilborne preservatives, if removed after treatment,
leave the wood cleaner than the heavier oils but may not provide as much
protection.
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TABLE 5. PRESERVATIVES AND MINIMUM RETENTIONS FOR VARIOUS MOOD PRODUCTS
fcurn
A.
B
c
d pioducl end twvic* canaaian
Ttoa (crossUes and switch Das)
LunUMi. plywood, and structural
Umbais (Induduig glued
lamlnalad)
(1) Fw usa In coastal walaia:
lumbar (under 6 to Me*)
Timbers (S In or thicker):
Southern pina
Coast Douglas- In and
western hemlock
Plywood
(2) For use In fresh water, in
contact with ground, or lor
Important structural members
. not bt contact with ground or
water
Glued laminated timbers 01
laminates
(3) For other uses hot in contact
with ground or water '
Piles
(1) For usa in coastal waters:
Southern plna
Coast Douglas In
Ma terborhe
preservatives
Preservative oils ciwonuud
CIMM**- CiMMOte- PtnUchkxoptwnal Acid Amman- capper
Co*lu» c*«ll«» p«MMn copp*i mat aiMiul*
a«oul* Kdunon MtuUan InhMvy InlgM InvataM* cinanuu capfMi l|rp«il.
(WraMum pMalMn ioMnli WMDM* • II. « III
7-10 7-10 7-10 035-.60 _____
20-25 ______ 2.60 250
20-25 ______ 250 250
20-25 — — — — — — 2 50 250
25 — — — — — — 250 250
7-12 7-12 7-12 .50-.60 .62-75 62-75 - 60 60
6-12 6-12 6-12 .60 .75 75 — 60 bO
6-12 6-12 6-12 .30-.40 .30-40 30-40 025 050 250 250
25 25 — — — — - 250 250
22— — — — — — 2502 SO
(2) Fix land or Iresh-water use:
Souther'-, and other pines
Douglas-lir and western
12
17
12
17
12
17
60 -
65 -
ao
too
BO
I DO
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TABLE 5. (continued)
Water borne
preservatives
Preservative oils o»omai«i
Font ol piodud end unfc* condUon
0 Potaa (ullUy)
E
F.
Southern end ponderoaa
plna
Had pine
Jack and todgapole plna
Coasl DoughM-Or
Interior Douglas-lii and
waalei n larch
WaslMn radcadar
Wat lam ladcadat. northain
wttfe-cedar. AhukaXMlaT.
todgapola pina nhatmaf '
01 not anti-cold process)
Poles (buiUiiig. round)
Posts (round)
Fence
BuHdbig
MfllE- iiiiMannan lailii^tMit aM« atanaai aiM-tail
f^J I B . WBanaWmm IfMOMavlinv M Pav«6J ••baud
iMtkcdlon* rfntJd ta idMad k> k» u>4
CiMMoto- Gieoiel*-
OMMto tokiiion »OUton tal
pai
90 — —
tas - -
160 - —
120 — —
18 — —
to - —
20 - —
12-135 — —
867
12 — . —
rUnmUjfOpnvllQI Wfcaii •*iiw»aiw»i •MVt •
1 ' • cappM
liMwy In I0N InvotoMv ttnmtt
«I.Mh pMalMn iJ^MiH i
.48 .56 56 —
.68 .69 89 —
.80 100 100 —
.60 .75 .75 —
.80 1.00 100 —
.60 1.00 100 —
1.0 — - -
.60 — - —
30 .38 .38 .SO
.60 — - —
. Id BMI mm* *M Mfentton fc *•••« diMM
acal utanai*
copaw 1»P«» 1
irMMto Hall
60 60
.60 60
.60 60
.60 .60
60 60
— —
— —
.60 60
.40 40
.60 60
IkMOCtottOfl. llM CUH4»f4 8ttU4)A Ol *>'•>•
•nai «n •ovchH «td autw ton*.
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3.1.1.1 Coal Tar Creosote. Coal tar creosote, a black or brownish
oil made by distilling coal tar, is highly toxic to wood-destroying
organisms and has a long record of satisfactory use as a wood
preservative. The American Wood Preservers' Association describes
creosote, as used by the wood preservation industry, as: "a distillate of
coal tar produced by high temperature carbonization of bituminuous coal;
it consists principally of liquid and solid aromatic hydrocarbons and
contains appreciable quantities of tar acids and tar bases; it is heavier
than water, and has a continuous boiling range of at least 125°C,
beginning at about 200°C."'*
The first fractions from coal tar distillation contain the light (or
low molecular weight) oils, and the residue left after completion of the
process is the pitch. The higher boiling point liquid fraction recovered
between these two general classes of materials is creosote. Relative
concentrations of creosote components can vary because the character of
the tar, details of the distillation process, and proportion of distillate
included in the creosote fraction all influence the composition of the
creosote. Table 6 summarizes the chemical and physical properties of
creosote, and Table 7 lists the major components of creosote.
Most of the 200 or more compounds in creosote are polycyclic aromatic
hydrocarbons (PAH's). Only a limited number of these compounds (less than
20) are present in amounts greater than 1 percent. The major polycyclic
aromatic hydrocarbons in creosote listed in Table 7 generally comprise at
least 75 percent of the creosote.
The many components in creosote complement each other in effecting
wood preservation. The lighter molecular weight PAH's in creosote are
generally more toxic to decay organisms. The heavier molecular weight
components of creosote help "retain" the lighter, more toxic components
within the wood by minimizing leaching or volatilization. The heavier
residues of creosote, when impregnated into wood, prevent moisture changes
and subsequently minimize splitting of wood.
The advantages of coal tar creosote include: (1) relative
insolubility in water and low volatility, which impart to it a great
degree of permanence under the most varied use conditions; (2) ease of
application; (3) ease with which its depth of penetration can be
12
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TABLE 6. PHYSICAL AND CHEMICAL PROPERTIES OF CREOSOTE'
Identification
Common:
Synonym:
CAS Registry No.:
Creosote oil
Coal tar creosote
8001-58-9
Physical and chemical properties
Physical state:
Solubility:
Specific gravity:
Vapor pressure:
Boiling point:
Odor:
Vapor density:
Appearance:
Melting point:
Flash point:
Explosive limits:
Liquid
Insoluble in water. Soluble in alcohol,
benzene, and toluene
1.05-1.09 at 15°C (sinks in fresh and
marine waters)
Variable
200° to 540 °C
Acrid, tarry aromatic
Variable
Yellow to black oily liquid with sharp,
smoky or tarry odor
Varies (-60° to -20°C)
>74°C-combustible liquid
Variable, 1 to 7 percent
Hazard data
Fire
Extinguishing data:
Fire behavior:
Ignition temperature:
Burning rate:
Reactivity
With water:
With common materials:
Stability:
Use dry chemical, foam, or carbon
dioxide. Use water to cool fire-exposed
containers
Forms irritating heavy black smoke
Variable, typically 400°C
4 mm/min
No reaction, insoluble
May react with oxidizing agents or strong
acids
Stable
13
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TABLE 7. MAJOR COMPONENTS IN CREOSOTE6
Component
Naphthalene
2-Methy 1 naphtha 1 ene
1 -Methy 1 naphtha 1 ene
Biphenyl
0 iraethy 1 naphtha 1 enes
Acenaphthalene
Oibenzofuran
F 1 uorene
Methy 1 f 1 uorenes
Phenanthrene
Anthracene
Carbazo 1 e
Methy 1 phenanthrenes
Methy 1 anthracenes
Fluoranthene
Pyrene
Benzof 1 uorenes
Chrysene
Whole
creosote,
percent
3.0
1.2
0.9
0.8
2.0
9.0
5.0
10.0
3.0
21.0
2.0
2.0
3.0
4.0
10.0
8.5
2.0
3.0
90.4
Boiling
point, 'C.760b
218
241.05
244.64
255.9
268
279
287
293-295
318
340
340
355
354-355
360
382
393
413
448
Melting
point, "Cb
80.55
24.58
-22
71
-18-104
96.2
86-87
116-117
46-47
101
216.2-0.4
247-248
65-123
81.5-209.5
in
156
189-190
255-256
Molecular
weight
128.2
142.2
142.2
154.2
156.2
156.2
168.2
166.2
180.2
178.2
178.2
167.2
192.2
192.2
202.3
202.3
216.3
228.3
^Approximate pet. +0.7 percent.
"values from Handbook of Chemistry and Physics, 1971-72, 52nd ed., Chemical Rubber Publishing
Company, Cleveland, Ohio.
14
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determined; and (4) general availability and relative low cost (when
purchased in wholesale quantities). Some disadvantages of coal tar
creosote are: (1) creosote-treated wood usually cannot be painted
satisfactorily, (2) the odor of creosote-treated wood is unpleasant to
some persons, (3) creosote vapors are harmful to growing plants, and
(4) creosote-treated wood can cause skin irritation or burns when it is
handled.3
3.1.1.2 Creosote Solutions. Either coal tar or petroleum oil can be
mixed with coal tar creosote, in various proportions, to lower
preservative costs. The creosote solutions have a satisfactory record of
performance, particularly for crossties where they have been most commonly
used.3 Mixtures of coal tar and coal tar creosote commonly contain about
20 to 50 percent tar by volume. In general, mixtures of coal tar
creosote and petroleum may contain 30 to 70 percent petroleum by volume,
but the content is usually about 50 percent.2 (For crossties and
switchties, the tar content is about 40 to 50 percent.)3 Creosote-coal
tar solutions penetrate the wood with greater difficulty because they
generally are more viscous than straight creosote. However, high
temperatures and pressures during treatment, when they can safely be used,
will often improve penetration of high viscosity solutions.
Creosote petroleum solutions and creosote-coal tar solutions help to
reduce checking (splitting) and weathering of the treated wood.
Frequently posts and ties treated with standard formulations of these
solutions performed better than those similarly treated with straight coal
tar creosote.3
3.1.1.3 P;ntach1oropheno1 Solutions. There are several types of
pentachlorophenol solutions used in wood preservation: mineral spirits,
heavy petroleum oils, and liquid petroleum gas are all solvents that can
be used with pentachlorophenol for wood treatment. Pentachlorophenol
solutions generally contain 7.5 percent (by weight) of this chemical
although solutions with volatile solvents may contain lower or higher
concentrations.
The performance of pentachlorophenol and the properties of the
treated wood are influenced by the properties of the solvent used. Heavy
petroleum solvents are preferable for maximum protection, particularly
15
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where the treated wood 1s used 1n contact with the ground. The heavy oils
remain 1n the wood for a long time and do not usually provide a clean or
paintable surface. Therefore, volatile solvents, such as liquified
petroleum gas and methylene chloride, are used with pentachlorophenol when
the natural appearance of the wood must be retained and the treated wood
requires a paint coating or other finish.
3.1.2 Waterfaorne Preservatives
Standard wood preservatives used in water solution include acid
copper chromate, ammoniacal copper arsenate, chromated copper arsenate
(Types I, II, and III), chromated zinc chloride, and fluorchrome arsenate
phenol. Waterborne preservatives leave the wood surface comparatively
clean, paintable, and free from objectionable odor. Typically, they must
be used at low treating temperatures (100° to 150°F) because they are
unstable at higher temperatures.3
The chromated zinc chloride and fluorchrome arsenate phenol
formulations are not as leach resistant as other waterborne preservatives
or oils and, therefore, are recommended for above-ground, light-duty uses
only. The anaoniacal copper arsenate and chromated copper arsenate
formulations are included in specifications for such items as building
foundations, building poles, utility poles, marine piles, and piles for
land and fresh water use.3
3.2 CONDITIONING TREATMENTS
With most wood treating methods, the presence of significant amounts
of free water in the wood cell cavities may retard or even prevent the
entrance of the preservative liquid.7 Therefore, the moisture content of
the wood must be reduced prior to treatment. Moisture reduction can be
accomplished by using artificial conditioning treatments or by allowing
the wood to air-season (I.e., storing the untreated wood outdoors in
piles). Unseasoned wood that is exposed to the open air, but protected
from rain, will gradually dry out until it comes into approximate
equilibrium with the relative humidity of the air. Frequently, timbers
must be treated without waiting for them to air-season because of
unfavorable climatic conditions or because rush orders make it necessary
to treat the wood immediately.7
16
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Wood 1s conditioned by one of the following three primary methods:
(1) stearaing-and-vacuum, (2) bo11ing-under-vacuum (commonly referred to as
the Boulton process), and (3) vapor drying. These conditioning treatments
remove a substantial amount of moisture from the wood and also heat the
wood to a more favorable treating temperature.2 The steaming-and-vacuum
process is employed mainly for southern pine, while the Boulton or
boillng-under-vacuum process is used for Douglas fir and sometimes for
hardwoods. Vapor drying is used for seasoning railroad ties and other
products.3
3.2.1 Steaming-and-Vacuum Process
In the steaming process, the wood is steamed in the treating cylinder
(retort) for several hours, usually at a maximum temperature of 245°F.3
When the steaming is completed, a vacuum is immediately applied. During
the steaming period, there is practically no reduction in the moisture
content of the wood. In fact, some water actually is added by condensa-
tion in the early part of the steaming period when the wood is cold.2
When the steaming is discontinued and a vacuum is applied, the
boiling point is lowered and part of the water in the wood, especially
that near the surface, is forced out mechanically by the steam generated
in the wood cells or is evaporated during the vacuum period. Most of the
water removed by the vacuum after steaming 1s taken out during the early
part of the vacuum period when the wood is hottest and evaporation is most
rapid. From the standpoint of moisture removal, there is little need to
continue the vacuum much longer than 2 hours.
Among the principal advantages of steaming are: steam heats the wood
faster than any of the other heating mediums; it is easily applied and
requires no special equipment; the temperature can be controlled easily;
and the wood is left clean after steaming is completed.2
The principal disadvantages are: wood surfaces are exposed to the
actual steam temperature during the entire steaming period (which could
damage temperature-sensitive woods); only a limited amount of moisture can
be removed during the entire steaming period; and it is generally
necessary to use considerably higher temperatures than would be needed,
for example, in the use of the Boulton process.
17
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3.2.2 Boulton (Boiling-Under-Vacuum) Process
In the Boulton process, the treating cylinder 1s filled with hot
preservative oil so that all the timbers are covered (although some
unfilled space may be left above the oil surface). The preservative is
then kept heated while a vacuum is applied. In this case, the oil serves
to keep the wood hot while the vacuum lowers the boiling point of the
water in the wood and causes part of the water to evaporate.2 The
evaporated moisture and some of the accompanying vapors from the oil pass
through a condenser. The condensate can then be weighed or measured to
determine how much water has been removed from the charge, and the
volatile oils evaporated from the creosote and condensed with the water
may be separated from the water and returned to the preservative tank.2
The vacuum during the boiling period usually reaches 22 inches or
more, and the entire cycle may last anywhere from 10 to 36 hours. The
average temperature of the preservative during the Boulton1z1ng cycle
typically ranges from 180° to 220°F depending upon the type of wood being
treated and Its Intended use. This temperature range, lower than that of
the steaming process, 1s a considerable advantage 1n treating woods that
are especially susceptible to Injury from high temperatures.7 In general,
the minimum, rather than the maximum, specified temperatures are used and
the boiling period 1s only as long as is necessary to prepare the timber
for subsequent Impregnation of preservative.
While originally intended for use with straight coal-tar creosote,
the Boulton process also can be employed with creosote mixtures or any
preservative oils that will not foam or cause problems during the
conditioning period. The Boulton process is entirely unsuitable for
waterborne preservatives, however, because the water in the solution would
evaporate even more readily than that in the wood.7
The chief advantages of the Boulton process are: (1) milder
temperatures are used (as compared to the steaming process) with minimum
effect on the strength and on the physical condition of the wood,' (2) the
moisture content of the wood never increases, and (3) a greater moisture
reduction can be obtained than is possible with the steaming process.2
The chief disadvantages of the Boulton process are that (1) it 1s
suitable for oil-based preservatives only, (2) 1t often costs more than
18
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air-seasoning, (3) It heats the wood more slowly than steaming or boiling
at high temperatures without vacuum, and (4) It usually requires a
considerably longer time than the steaming-and-vacuum process.
3.2.3 Vapor-Drying Process
During the vapor-drying process, the wood in the treating cylinder is
exposed to hot vapors produced by boiling an organic solvent, such as
xylene; the vapors are then condensed. As condensation takes place, the
latent heat of the solvent 1s given up and the moisture vaporizes. The
resulting mixed vapors of water and the solvent are then passed through a
condenser so the water can be separated and drained away and the solvent
recovered and reused. The best results are obtained with solvents that
have a boiling range of 280" to 320"F.3
3.3 PRESSURE PROCESSES
Most of the wood-preserving methods in use may be classified roughly
as either pressure processes, in which the wood 1s placed in a treating
cylinder or retort and Impregnated with preservative under considerable
force, or nonpressure processes, which are carried out without the use of
induced pressure. In nonpressure processes, the preservative 1s applied
to the wood by brushing or spraying or by dipping, soaking, or steeping
the wood 1n the preservative. However, the majority of wood treated
annually 1s impregnated by pressure methods in closed cylinders.7
Therefore, only pressure processes are discussed 1n the following
sections.
Pressure processes differ in details, but the general principle is
the same. The treatment 1s carried out 1n steel cylinders or retorts,
most within the limits of 6 to 9 feet in diameter and up to 150 feet or
more in length and are built to withstand working pressures up to
250 ps1.7 The wood 1s loaded on special tram cars and run into the
retort, which is then closed and filled with preservative. Applied
pressure forces preservative Into the wood until the desired amount has
been absorbed. Three processes, the full-cell, modified full-cell, and
empty-cell, are 1n common use.
19
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3.3.1 Full-Cell Process
The full-cell (Bethel) process is used when the retention of a
maximum quantity of preservative is desired. Timbers typically are
treated full-cell with creosote when protection against marine borers is
required. Waterborne preservatives are generally applied by the full-cell
process, and control over preservative retention is obtained by regulating
the concentration of the treating solution.3
Steps in the full-cell process are listed below:
1. The charge of wood is sealed in the treating cylinder, and a
preliminary vacuum is applied for 0.5 hour or more to remove the air from
the cylinder and as much as possible from the wood.
2. The preservative, at ambient or elevated temperature depending on
the system, is admitted to the cylinder without breaking the vacuum.
3. After the cylinder is filled, pressure is applied until the wood
will take no more preservative or until the required retention of
preservative is obtained.
4. When the pressure period is completed, the preservative is
withdrawn from the cylinder.
5. A short final vacuum may be applied to minimize dripping of
preservative from the charge.
When the wood is steamed before treatment, the preservative is
admitted at the end of the vacuum period that follows steaming. When the
timber has received preliminary conditioning by the Boulton or boiling-
under-vacuum process, the cylinder can be filled and the pressure applied
as soon as the conditioning period is completed.3
3.3.2 Modified Full-Cell Process
The modified full-cell process is basically the same as the full-cell
process except for the amount of initial vacuum. The modified full-cell
process uses lower levels of vacuum; the actual amount 1s determined by
the wood species and the final retention desired. This process is used
only on material 2 inches or less in thickness.3
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3.3.3 Empty-Cell Process
The objective of empty-cell treatment is to obtain deep penetration
with a relatively low net retention of preservative. For treatment with
oil preservatives, the empty-cell process should always be used if it will
provide the desired retention. Two empty-cell processes, the Rueping and
the Lowry, are commonly employed; both use the expansive force of
compressed air to drive out part of the preservative absorbed during the
pressure period.
3.3.3.1 Ruepinq Process. The Rueping empty-cell process has been
widely used for many years in both Europe and the United States. The
following general procedure is employed:
1. A1r under pressure is forced into the treating cylinder, which
contains the charge of wood. The air penetrates some species easily,
requiring but a few minutes' application of pressure. In the treatment of
the more resistant species, common practice is to maintain air pressure
from % to 1 hour before admitting the preservative, but the necessity for
long air-pressure periods does not seem fully established. The air
pressures employed generally range between 25 and 100 ps1 depending on the
net retention of preservative desired and the resistance of the wood.
2. After the period of preliminary air pressure, preservative is
forced Into the cylinder. As the preservative 1s pumped 1n, the air
escapes from the treating cylinder into an equalizing or Rueping tank at a
rate that keeps the pressure constant within the cylinder. When the
treating cylinder is filled with preservative, the treating pressure is
raised above that of the initial air and is maintained until the wood will
take no more preservative, or until enough has been absorbed to leave the
required retention of preservative 1n the wood after the treatment.
3. At the end of the pressure period, the preservative 1s drained
from the cylinder, and surplus preservative is removed from the wood with
a final vacuum. The amount recovered may be from 20 to 60 percent of the
gross amount Injected.3
3.3.3.2 Lowry Process. The Lowry process is often called the empty-
cell process without Initial air pressure. Preservative is admitted to
the cylinder without either an Initial air pressure or a vacuum, and the
air originally in the wood at atmospheric pressure 1s Imprisoned during
21
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the filling period. After the cylinder is filled with the preservative,
pressure is applied, and the remainder of the treatment 1s the same as
described for the Rueping treatment.3
The Lowry process has the advantage that equipment for the full-cell
process can be used without'other accessories; the Rueping process usually
requires additional equipment, such as an air compressor and an extra
cylinder or Rueping tank for the preservative, or a suitable pump to force
the preservative into the cylinder against the air pressure. Both
processes, however, are widely and successfully used.3
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4.0 AIR EMISSIONS AND CONTROLS
The operation of equipment used for treating wood with creosote
solutions results in the emission of odor-causing air contaminants and
possible air toxics. For the purposes of this study, it was not possible
to quantify emissions. However, a Toxic Chemical Release Inventory
Reporting Form (EPA Form R) completed by Koppers1 Salem, Virginia,
facility in compliance with Section 313 of Title III of the Superfund
Amendments and Reauthorization Act of 1986 was obtained and is presented
in Appendix A. Koppers reported emissions of the following in 1987:
Annual emissions, Ib/yr
Fugitive Stack
Biphenyl 280 10
Dibenzofuran 640 10
Anthracene 730 4
Naphthalene 5,900 480
The primary sources of emissions and odor have been Identified as:
1. The treated charge immediately after removal from the retort;
2. The vacuum system; and
3. Displaced air from working tank blow backs;
Information found in the literature and observations made during plant
visits (see Appendix B) aided in identifying the above sources.
4.1 TREATED CHARGE
One source reports that emissions from treated wood immediately after
removal from the retort usually exceed 60 percent opacity beyond the
opaque water vapor breakoff point and continue to exceed 40 percent
opacity for up to 20 minutes. Heat from the treated charge causes some
of the lower boiling organic compounds to volatilize as aerosols, forming
a dense white emission plume. Emissions of 60 percent opacity or more
beyond the opaque steam plume from the open end of the retort continue
only during the few minutes it takes to remove the treated wood and
recharge the retort.8 However, during a recent visit to one facility it
was noted that a charge pulled 14 hours earlier was still showing evidence
of visible emissions and odor (see Appendix B - Koppers trip report).
23
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Several techniques for controlling fugitive emission losses from
treated charges have been suggested with varying degrees of success. One
approach is to construct a ventilation hood or building to collect organic
vapors coming off the charge. The hood would need to cover the entire end
of the retort, a section of track and switches, and a complete tram or
trams. Such a structure, perhaps exceeding 150 feet in length, would
require enormous gas exhaust rates, and the associated emission control
devices would also be very large. Such hooding and ventilation systems
could be economically unfeasible for the retrofit of existing uncontrolled
plants.8
Low boiling point organics may be controlled by reducing the
temperature of the freshly treated wood. To drop the temperature of the
wood, heat must be conducted and/or convected out of the wood. Fourier's
equation provides the basic relationship that describes steady-state heat
conduction.
where:
q = heat conduction in x direction, Btu/h
A - cross-sectional area normal to heat flow, ft2
dt/dx = temperature gradient in x direction, °F/ft
k = thermal conductivity of conducting medium, Btu/h«ft«°F
The thermal conductivities of water and air at 32°F are reported as 0.343
and 0.0140, respectively.9 Thermal conductivity is moderately dependent
on temperature. Nonetheless, the thermal conductivity of water is between
20 and 25 times greater than the thermal conductivity of air in the
temperature range of 32° to 200°F. Thus, water will cool the wood ties
faster than air.
Two processes aimed at cooling the freshly treated ties using water
have been demonstrated. In the first, a manifold containing spray nozzles
is mounted a few centimeters from the open end of the retort. The nozzles
are positioned to blanket the entire opening and emerging charge with
water sprayed at about 300 gallons/minute as the charge is slowly pulled
24
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from the retort (no faster than 17 feet per minute).8 In theory, the
water spray will cool the ties and scrub and condense the escaping
vapors. In reality, this method has enjoyed limited success. While
controlling some of the initial vapors, the water spray actually does very
little to cool the ties. The ties that are stacked in the center are not
subjected to the spray so the charge as a whole is not significantly
cooled.
The second process involves using water to quench the ties while
still in the retort. Following the final vacuum and before the retort
door is opened to remove the treated ties, the retort is filled with water
to quench the ties. The water is then emptied and the ties are removed.
This water quench cycle may have to be repeated or be designed with a
circulating water system if the void volume in the retort is not great
enough to allow sufficient cooling water into the retort to cool the
ties. This system has been demonstrated to be successful in controlling
emissions from a plant treating approximately 430 air-dried ties per
charge with a void volume of approximately 15,000 gallons (see
Appendix B - Jennison-Wright trip report).
One obvious drawback to these two methods is that the contaminant 1s
merely transferred from the air to the water, resulting 1n the need for
treatment of an additional effluent stream. Facilities using these
methods to cool the ties will recycle the water and remove the insolubles
periodically. A cooling system or a large-capacity water system will be
needed to keep cooling water temperatures low to maintain the
effectiveness of the quenching system.
4.2 VACUUM SYSTEM
During the Boulton process and the final vacuum applied during the
Rueping process, volatile organics are evaporating from the creosote
solution and exiting the retort through the vacuum system. In the two
plants visited, one plant uses a reciprocating vacuum pump while the other
uses a steam jet ejector to induce a vacuum of 22 to 24 inches of mercury
on the retort. Both plants have a single-pass, water-cooled condenser in
line between the vacuum source and the retort to condense the vapors.
Koppers uses two steam jet ejectors to Induce the vacuum on the
retorts. A 4-inch steam jet is used to draw the system pressure down to
25
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between 22 and 24 Inches of mercury, usually taking between 1 and
2 hours. Ideally, once the vacuum has been obtained, the operator will
switch over to a 2-Inch steam jet to maintain the vacuum for the remainder
of the cycle to save energy. However, during periods of high steam demand
there may not be enough steam available from the plant's boiler to
maintain a 24-Inches (mercury) vacuum using the 2-inch steam jet.
Therefore, the 4-inch steam jet may remain on during the entire vacuum
cycle if the steam demand (I.e., heat for retorts, working tanks,
buildings, etc.) for the rest of the plant is high.
Odors emanating from the steam jet suggest that the single-pass,
water-cooled condenser may not be capable of condensing all of the
organics, allowing them to become entrained in the steam jet. There are
several possible solutions to eliminate this odor. The first is to
install a larger condenser capable of reducing the organic content in the
vapor further. Secondly, the vacuum system can be modified to include two
steam jet ejectors in series with a barometric (direct contact)
intercondenser between them. In this type of ejector system, the
barometric intercondensers condense the oily vapors entrained in the steam
and flush them out with the intercondensed water.10 A third option would
be to replace the steam jet ejectors with a vacuum pump and route the
exhaust vapors to an activated carbon adsorption system or to an
afterburner. Both are extremely efficient methods to remove organics from
the exhaust gas.
The steam jet ejectors should not be used with the latter two control
options. Water may preferentially adsorb onto carbon in the activated
carbon system and impede the diffusion of organics into the pore spaces.
The steam jets also will generate a larger volume of gas to be treated by
either method and lower the average Btu value of the steam, which is a
factor to consider if an afterburner is used.
Incineration of air contaminants in an afterburner is a proven method
for controlling emissions during the operation of the vacuum cycle.8 The
volume of the contaminated gaseous effluent varies from about 300 to
1,200 scfm. Precautions should be taken to keep gas velocities well above
flame propagation velocities to prevent flashback. This can be
accomplished by narrowing the throat diameter leading into the
26
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afterburner. The afterburner should be designed for an exit temperature
of 1500°F and a retention time of 0.3 seconds or more in the combustion
zone.8 Source tests have shown afterburner efficiencies of 99 percent
when operated at 1400°F exit temperature.8
Studies have shown that afterburner operating costs can be reduced by
recovering the heat from the afterburner exhaust gases. A shell-and-tube
heat exchanger can be installed at the outlet from the afterburner to heat
boiler feed water or to supplement the steam producing facilities of the
wood-treating plant.
4.3 WORKING TANK BLOW BACKS
A working tank blow back event occurs when, at the end of a treatment
cycle, the creosote solution is sent back to the work tanks. The air
displaced by the filling of the work tanks is at equilibrium with the
preservative in the tank. If 30,000 gallons of preservative fill each
retort, as is the case with Koppers, then approximately 4,000 cubic feet
of air are displaced when the solution is sent back to the work tanks.
Each of the two plants visited use a water scrubber system to control blow
back vapors. The vapors are bubbled through water and/or brought into
contact with a water spray and vented to the atmosphere. The effective-
ness of these systems as scrubbers would be expected to approach zero if
the water is allowed to reach saturation and 1s not changed periodically.
Another option for controlling blow back vapors is to incinerate them
in an afterburner. It is worth noting that in the Koppers and Jennison-
Wright treatment process, a vacuum cycle always follows a blow back to the
work tanks. As discussed in the previous section regarding the control of
vacuum system vapors, an afterburner is a proven method of controlling
emissions during the operation of the vacuum system.
It should be possible to control blow back vapors by firing the
afterburner 15 minutes earlier (the approximate time needed to empty the
retort) and ducting the blow back vapors to the afterburner. Immediately
after the blow back, the vacuum system is cut on and the exhaust vapors
are ducted to the afterburner. During the Boultonizing cycle, the
afterburner will be controlling vapors from the vacuum system and from the
blow back simultaneously.
27
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During blow backs, Koppers Indicated that 1t uses pressure built up
1n the retort to force the preservative back up through the bottom of the
work tank. Problems arise when an operator does not closely monitor how
much preservative 1s being blown back and begins to blow air up through
the working tanks. Air bubbled up through the work tanks picks up
volatile material and carries it out the vent. This scenario can be
prevented by emptying the retorts using a centrifugal pump.10
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5.0 CONCLUSIONS
The operation of equipment used for treating wood with creosote
solutions results in the emission of odor-causing air contaminants and
possible air toxics. Information found in the literature and observations
made during plant visits suggest that there are three primary sources of
air emissions at creosote wood treatment plants. Table 8 lists these
emission sources and the available techniques demonstrated to control
them.
At this time, no reliable quantitative estimates of emissions from
these sources or possible emission reductions from the respective control
devices have been made. Koppers has quantified and reported emissions of
biphenyl, dibenzofuran, anthracene, and naphthalene in its 1987 Toxic
Chemical Release Inventory Reporting Form (Appendix A) totaling over
8,000 pounds per year. Approximately 80 percent of the emissions were
reported as naphthalene.
As a result of the plant visits to Koppers and Jennison-Wright,
information is available to compare and contrast the two facilities and
make qualitative assessments of emissions. Table 9 presents a comparison
and contrast of the two plants and the methods and practices used to treat
their respective charges. In order to establish a baseline for
comparison, it is worth noting that both plants are treating railroad ties
for the same customer (Norfolk & Southern) to the same target retention of
preservative (about 8 lb/ft3), and using the same 60/40 creosote/coal tar
preservative solution. However, the plants differ in several respects.
The most noteworthy of these is that Koppers treats mostly unseasoned ties
and Jennison-Wright treats only air-dried (seasoned) ties. As a result,
Koppers has a much longer treatment cycle because it must Boultonize the
ties to remove moisture from the sapwood of the charge.
The Boulton cycle used by Koppers to condition unseasoned ties may
significantly increase the odor or air toxic release over that of a
facility treating seasoned ties not requiring moisture removal. The
following two process conditions clearly support this suggestion. First,
the Koppers process has a treatment time of approximately 24 hours, which
is two to three times longer than the time required at Jennison-Wright.
29
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Source
TABLE 8. EMISSION SOURCES AND DEMONSTRATED
EMISSION CONTROL TECHNOLOGIES
Control
Freshly treated charge
Vacuum system
Working tank blow backs
• Water spray
• Water quench
• Condenser(s)
• Afterburner
• Carbon adsorber
• Water scrubber
• Afterburner
• Carbon adsorber
30
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TABLE 9. COMPARISON AND CONTRAST OF KOPPERS AND JENNISON-WRIGHT WOOD TREATMENT PROCESSES
Koppers
Jennlson-Wright
• Customer: Norfolk and Southern Railroad
• Treats green unseasoned ties
• Treats 3.000 ties per day
• 2,670 ft3 of wood per charge
• 4,370 ft3 of void space 1n retort
• 0.61 ft3 of wood per ft of void space
• Employs Boulton and Rueplng process
• Treatment temperature 200°F
• Uses 60/40 creosote/coal tar mixture
« Preservative contains 3 percent naphthalene
« Target retention of 7 to 8 Ib creosote/ft3 wood
• Approximate 24-hour treatment cycle
• 16 to 18 hour vacuum cycle
« Vacuum source: 4-Inch steam jet ejector
° Vacuum system vapor control: single-pass
condenser
• 2 blow backs per treatment cycle
• 20,000-gallon blow back vapor scrubber
• No tie quenching system
• Norfolk and Southern Railroad
• Treats a1r-dr1ed ties
• Production rate 1s confidential
• 1,146 ft3 of wood per charge
• 2,005 ft3 of void space 1n retort
• 0.57 ft3 of wood per ft3 of void space
• Employs Rueplng process
• Treatment temperature: 205°F
• Uses 60/40 creosote/coal tar mixture
• Preservative contains 7 to 9 percent naphthalene
• Target retention of 8 Ib creosote/ft wood
• 8 to 10 hour treatment cycle
• 1 hour vacuum cycle
• Reciprocating vacuum pump
• Single-pass condenser
• 1 blow back per treatment cycle
• 500,000-gallon blow back vapor scrubber
• Water Introduced Into retort to quench ties
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The extended treatment time is the result of the addition of the 16 to
IS hour Boulton cycle. The vacuum system, identified as a major emission
source, runs continuously during the Boulton cycle. The extended
operation of this emission source creates a greater potential for the
release of odor and air toxics.
Secondly, the Boulton cycle results in an additional blow back of
preservative to the work tanks. This Increases, perhaps doubles, the
potential for odor and air toxics to be emitted. As presented in Table 9,
although Koppers has twice the number of blow backs and approximately
twice the void volume in the retort (measure of how much preservative is
transferred to and from the working tanks) as Jennison-Wright, Koppers'
20,000 gallon water scrubber system is 25 times smaller than that of
Jennison-Wright. A qualitative assessment suggests that a substantially
higher potential for emissions during blow back periods exists at Koppers.
A final comparison from Table 9 shows that the volume of wood per
volume of void space is approximately the same for the two plants.
Koppers has slightly less void space per cubic foot of wood in and around
the charge (about 7 percent less). This suggests that Koppers may be able
to quench and cool the ties in a manner similar to Jennison-Wright.
However, the Koppers charge did appear hotter than the Jennison-Wright
charge (before quenching) and may require more cooling water to
appreciably lower the temperature of the charge.
32
-------
6.0 REFERENCES
1. Micklewright, J. T. Wood Preserving Statistics, 1986. A Report to
the Wood-Preserving Industry in the U.S. American Wood Preservers
Institute. January 1988.
2. Maclean, J. D. Preservative Treatment of Wood by Pressure Methods.
Agriculture Handbook No. 40. Forest Service Division, U.S.
Department of Agriculture. 1960.
3. Wood Handbook: Wood as an Engineering Material. Agriculture
Handbook No. 72. Forest Service Division, U.S. Department of
Agriculture. 1986.
4. American Wood Preservers Association. AWPA Book of Standards.
American Wood Preservers Association. Bethesda, Maryland. 1977.
5. Konasewich, D. E. and F. A. Henning. Creosote Wood Preservation
Facilities, Recommendations for Design and Operations. Envirochem
Services. EPS 2/WP/l. April 1988.
6. Lorenz, L. F. and L. R. Gjovik. Analyzing Creosote by Gas Chroma-
tography: Relationship to Creosote Specifications. Proceedings.
Sixty-Eighth Annual Meeting of the American Wood Preservers Associa-
tion. Volume 68. April 1972.
7. Hunt, G. M. and G. A. Garratt. Wood Preservation, 2nd edition.
McGraw-Hill Book Company, Inc. 1953.
8. County of Los Angeles, Air Pollution Control District. Air Pollution
Engineering Manual, Second Edition, AP-40. U. S. Environmental
Protection Agency, Research Triangle Park, N.C. 1973.
9. Bennett, C. D. and J. E. Myers. Momentum, Heat, and Mass Transfer,
2nd Edition. McGraw-Hill Book Company, pp. 249-251. 1974.
10. Best, C. W. and P. C. Gaskin. "Odor Control in Wood Preserving
Plants." American Wood-Preservers' Association, Annual
Proceedings, pp. 105-108. 1979.
33
-------
APPENDIX A.
TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM--KOPPERS
-------
.. Form Approved OMB No.: 2Q7Q-0093
(Important: Type or print; read instructions before completing form.)
Approval Expires:
01/91
Pace 1 of 5
U.S. Environmental Protection Agency -.. • ' .
BA TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM
- - - '
Section 313, Title n of The Superfund Amendments and Reauthorization Act of 1986
EPA FORM
D
PART 1. FACILITY IDENTIFICATION INFORMATION
1 1 ITM. x«x. kv VOA !•• <
13-87-01054586-9-\/A
1.
1.1 Do« Otis report contain trade
F~l Yee (Anew*- 1.2)
(Do not
t.2|
1.2 - to true a unrttaed oapy?
D
1*3
I 2. CERTIFICATION (Read and sign after completing ail sections.)
I hereby certify that I have ic vie wed the attached documents and that, to the best of my knowledge and belief, the submitted information is true
and complete and that the amounts aad values m this report are accurate based on reasonable estimates mint data available to the preoarers
of this report. ' . * '
Vfrtfanh' Mamer 'fachntC(Ll*<£ni/i(wrn'AkJ *tr ~£«iV2
Thtt report oomaln* IntormaUan lor: (check em)
i. (~1 Part of a ooMrad facility.
3.3
Rabert
Ts^^ef^ww^ii •**»— ^^— . fhMtelw^Sk ••^aai «w4^l
e^V^cIV^ f^lUniaTVr ^HWUDV AW fJBDVf
(4/2)227-
3.4
Public Contact
A. Franch
*e)
3.5
a. SIC
Lalttud*
3.6
C«g. MM. *«e.
LanQltude
3.7
Out ft BradMraet Nunb«r(i)
7\C^C
3.8
A UentltleaUan Nunbcr (RCAA LO. Na.)
3.9
TO)
.......
Whore to send eompleted forms:
U.8. Environmental Protection Agency
P.O. Bai 70206
WaeMnoton. DC2OO24-02S6
Attn: TorJe Chemical Release kwentory
Nam of AooeMng 8trMm(«) or Water Bodyd)
. P \\ter
.;» -rV
i£j
3.10
b'
MA
3.11
k^eetlon WMI Code (UK) Uentmeattan No.
1 1 1 1 1 1 1 1 1 I
4. PARENT COMPANY INFORMATION
4.1
Name o« Parent Company
AJ^QL
4.2
'S Out » Bradetreet Ma.
A-/r»l I I I ' ! _ ! I " I I
EPA Form 9350-1 (1-68)
-------
(Lnf&rtant: Typt or print; rtad f-tructions btfort computing form.)
Pag* 2 of 5
, ' •..._.„ .-' -.'••'. •• • : (Thtaapaoa tor EPA uaa only.)
- .. • EPA FORM R
' PART 0. OFF-SITE LOCATIONS TO WHICH TOXIC '
- * CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTW) . - .
Faculty Nama
A//A
Straat Addiaaa
City
Slata
• " •
County
Zip
1 III l-l 1 II
«
*
i
2. OTHER OFF-SITE LOCATIONS - Number these locations sequentially on this and any additional page of this form you use.
| | Other off-site location fijfa 1 •
1 1 1 1 1 1 1 1 1 1
Faculty Nama
Straat Addraas
aty
Stata
Q~| Other off-site location
EPA Uantlncatlon Numbar (RCRA O. No.) | (
County
Zip
1 III l-l 1 II
nmoomMRy? l~l fl
^UJIUIIIMIVT |_J I_J
Vai No-
1 1 1 1 1 1 1 1 1 1
Facility Nama ,
AJ/A
Straat Addrasa
City
Slata •' ••
| | Other off-site location
EPA Mantmeattan Numbar (RCRA O. No.) | 1
"tam"<™ A///)
aty
Stata
tt locaUon undar control of lauwtlng facility or pa
|~n Cnack H addttJonal pagat of Part 1 ara attaenad
County
Zip
1 III l-l 1 II
«rt«~ny7 n n
IMMJUHKIIMyT LJ LJ
Vat No
1 1 1 1 1 1 1 1 1 1
•'.'-•'•
County
Zip • -
1 1 1 1 l-l 1 1 1
rant company? | | | [
' - . .-- Ya§ No
"•• • *' ' .•• "-•• ." ••***• •">*" • ':
'
._-. -~ . . ..,-.•-....-?-•.••--•---•.
EPA Form 8350-1(1-65) . •._.:••_ .'.• .-.^.;//..'•-. ^; ;•'.'•_ r
-------
jcnar.t; Type or prim; r«arf ir actions btfort computing form.) -
Page 3 of s
'...•... . fTMe epaee tor B»A uae enry.)
EPA FORM R
_ PART Ul. CHEMICAL SPECIFIC INFORMATION
I. CHEMICAL IDENTITY
1.1 j j Trade Secret (Provide a generic name in
i.a CAS* \0\0\0\0\4\ I \-\Z\0\-\3
1.4 below. Attach substantiation form to this submission.)
1 (Use leading zeros if CAS number does not fin space provided.)
13 c^^orc^c..^*™ -/^^rtfta/e^ ^
Gemrto Chawntaa! Nam* (Comptot* only If 1. 1 to chattel
!•*»
MIXTURE COMPONENT IDENTTTY (Do not
2. Oewto Chamtcal Name Piu.ldad by SuppUar (Umfl tna
-.)
complete this section if you have completed Section 1.)
name to a maximum el 70 oharaetere (e.g.. numbers, tottere. epaoee. punctuation)).
3. ACnVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check an that apply.)
3.1 Manufacture: a.| | Produce
d I 1 For sale/
•'I — 1 distribution
3.2 Process: a. { |AS a reactant
r— i _
3.3 Otherwise Used: a.Q^e>esslng'aid
b. 1 1 Import c 1 1 For on-elte
•~— • L«J use/processing
^^^ »
«.j | As a byproduct f.| j Aa an knpurtty
b.j liiJiJ0^™1^1011 «.r^*««n«rtlde
•
b. I 1 As a manufacturing aid c.|| AncBary or other use
4. MAXIMUM AMOUNT OF THE CHEMICAL ON SITE AT ANY TIME DURING THE CALENDAR YEAR
[(2 \5\ (enter code)
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT
You may report releases of less than
1.000 fcs. by checking ranges under. A.I.
6.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Dlachargea to water 5.3.1 jfl {
(CnteV totter cods fron Ptrt 1
•action 3. 10 tor etreame(e).) |— 1
6.3.2 LJ
5.4 Underground Injection
5.5 Releases to land
f D 1"? I ^1 (.ntar m^t)
K.6.2 ID JO 15 | (enter eode)
«•«•» 1 1 -I.J fenteroodeJ
6.1a
6.2a
S.S.Ia
S.3.2a
5.3.3a
5.4a
S.S.Ia
5.5.2a
5.6.3a
A. Total Rele
(fcs/vr
A.I
Reportiig Ranges
0 1-490 600-OOT
r""1 (Cheek H addKlenal Information to provided en Part IV-SupptomenU
*
•
ue
• A.2
• 'Enter
Estimate
5400
Wo
14
' A///\'
V/A
fit/A
• 310
1*00
N/A
B. Basis of
. Estimate
(enter eode)
S.lb fg"l
••«> E
5.3.ib n
5.3.2b \~~\
s.3.sb n
6.4b Q
s.s.ib (A^|
S.5.2b [o]
5.5.3b Q
C. % From Stormwater
6.3.1C /y/f)
5.3.20
6.3.30
278375
EPA Form 9350-1 (1-*«)
-------
tPA FOKM I i, fan ill
Page 4 of s
6. TRANSFERS OF THE CHEM . IN WASTE TO OFF-SITE LOCATIONS
A.Totai Transfer*
X°!'J^tr!p?Ttf?5S^!. «H- *i~. fua/vri ...
•at !••• than 1,000 toa. by enaeMnQ
renooB under A* !•
6. 1 Discharge to POTW
Othar eff-clte location (— I
6.2 (Enter block number 1
from Part 1. Section 2.) «— 1
6.3 Other off-arte location r~~l
(Enter Mock numbar 1 I
from Part 1. Section 2.) 1— '
6.4 Othar off-alte location 1— I
(Entar Week numbar 1 1
irem Pan 1. Section 2.) *-— '
A.I
fUpuiUriu Range*
0 1-480 600-4M
•
Dfr*HA**b Iff •j4«etlju*al bifjirmAHMl !• nn«u4
IdedonP
(k
A.2
Enter
Estknat*
WA
ti/fi.
A///1
NtA
*
B. Baste of Estimate
(enter code)
e.tb D
«.2b n
e.3b D
e.4b []
C. Type of Treatment/
Disposal (enter code)
6.,c till
«.3C | | | |
••«• 1 1 1 1
ton)
7. WASTE TREATMENT METHODS AND EFFICIENCY
A. General
Wastaatream
(enter code)
Treatment
Method
(•ntor coda)
/
'
C. Range of
Influent
Concentration
Jantereode)
D. Sequential
Treatment?
(check If
applicable)
E. Treatment
Erflcwncy
Ettlmate
F. Based on
Operating
Data?
Y««
_No_
7.1.
7.1b I
7.1c
7.1.
7-1*
I I
7.2.
7.2b
7.20
7.2d
7.2e
n n
7.3b
7.3C
7.3d
7.3.
a n
7.4.
7.4b
7.40
7.4d
7.4e
G n
7.5.
7.5b
7.50
7.5d
7-5.
>•*
Q G
7.6.
| 1
7.6c
7.6d
7.6.
n
7.7.
7-Tb
7.7c
7.7d
7.7.
D
7.Sb
7.8c
7.8d
7.8.
7.B,
Q
7.9.
I I I I
7.9C
7.9d
7.9.
a n
7.10.
r7!
|
7.100-
7.10d
7.10.
a n
7.11.
n
7.11b
|
7.110
7.11.
n
7.12.
7.12C
7.12d
7.12.
n
7.13.
n
7.13.
7.13d
7.13.
n n
7.U.
7.14C
[T]
7.14d
7.14.
n
| | (Check tf addtttonsJ Mormation to provided on Part IV-Supplemental Information.)
8. OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indicate actions taken to reduce the amount of the chemical being released from th. faclty. See the Instructions for coded
Kerns and an explanation of what Information to Include.)
A. Type of
modification
(enter cod.)
•
II 1
B. Quantity of the chemical In the wastestrearh
prior to treatment/disposal
- Current Prior | Or percent
reporting year • Chang.
year(tos/yr) (bs/yr) ,
C. Index
DJZ!
D. Reason for action
(enter code)
^L-SU6
EPA Form 9350-1 (1-«8)
-------
(Important: Type or print; rtat* xfuctions befort completing form.)
Paga SefS
Ntanbaror
EPA FORM R
- . PART IV. SUPPLEMENTAL INFORMATION
Uaa tMa aactton If you need addtttonal apaca for anawara to quaattona In Parts I and III.
r or tartar this Information sequential* from prior aacttona (a.g.. D.E. F. or 6.54. 6.55).
(This •p*o» tar EPA UM only.)
ADDITIONAL INFORMATION ON FACILITY IDENTIFICATION (Part 1 - Saetlon 3)
3.5
3.7
3.8
3.9
3.10
eccoda
1 1 1
1 1 1
Dun 4 BraOlUaet Numoar(s)
J 1 - 1 1 • 1 1-1
1 1 1
111
EPA Uantmcatlon Numear(i) RCftA LO. No.)
1 1 1 1 I 1 1 1 1 1
NPDES Par mil
1 1 1
Numoar(()
1 1 I 1
1
•1
\ 1 - 1 1 1 1 - 1 1 1 1
1
1
Nam* at nacautng Straam(i) or Walar Baay(i)
BBBBBB*
—" 1 1 1 1 1 1 1 1 1
1 1 4 1 1 1 1 1
—
ADDITIONAL INFORMATION ON RELEASES TO LAND ( Part III - Section 6.S)
Ralaasas to Land
5.5 lilt (-nt-rcaa.)
5.5 | | | | (.«-«.>
5.5 I 1 i I (•nMreod.)
5.5 a
5.5 a
5.5 •
A. Total Ratoaaa
n
6. bQ
6. bQ
C. Type of Treatment/
Disposal (enter code)
.. e.l 1 I
•._..! 1
ADDITIONAL INFORMATION ON WASTE TREATMENT (Pan III - Saetlon 7}
A. Ganaral Wastaatraam
(antar coda)
7. . n
7. . n
7. . n
7. . D -
7. . n
B. Treatment
Method
(enter code)
7. b LZ
7. b LZ
7. b LZ
7. b LZ
7. b LZ
1
1
1
1
C. Ranga of
Influent
Concentration
(antar coda)
7. c
7. c
7. c
7. e.
7. c
n
n
n
n
n
D. Sequential
Traatmant?
(check If
applicable |
7. „ n
.7. - n
7. . n
7. , n
7. . n
E. Treatment
Efficiency
Estimate
7. e %
7. e %
7. e %
7. e %
7. e %
F. Based on
Operating
Data?
Yes No
7. , n
7. , n
7. , n
7. , n
7. , n
n
n
n
D
EPA Form S35CM(1-ae;
278377
-------
Form Approved OMB No.; 2070-QOQ1
M^V^ •••'••
(Important: Type or print; rtad Instructions before completing form.)
Appraw.1 P-pfc^ . 01/91
' Paoo 1 of 5
U.S. Environmental Protection Agency -...-••
oER& TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM EPA FORM
* ' ' R
Section 313. TWe • of The Superfund Amendments and Reauthorization Act of 1986 .
PART 1. FACILITY IDENTIFICATION INFORMATION
1.
1.1 Oeee tnla report contain trade oeonN MormattonT 1.2- to tMe a eanttla
| j Yee (Anewer 1.2J 1 txf^Ne (Do not anemer 1.2) . | | Y^e [
13-87-01054587-1- W
id copy? 1.3 Repertlr« Year
2. CERTIFICATION (Read aad sign after completing all sections.)
I hereby certify that I have leviewad the attached documents and that, to the best of my knowledge and belief, the submitted information is true
and complete and that the amounts aad values SB this report are accurate based on reasonable estimates nsiat data available to the Dreoarers
of this report. " . r '
Name and official title of owner /cperitcr or eerier management official
vfemfs t. Pntctetier Vice. trniderh Uamoar ~fchn
Signature /I ~ _/ W ' e
3. FACTUTY IDENTIFICATION
3.1
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
Street Addreee
Rt-.tlbO
aty Sale, m T&w no m.
State , , ^ Zip Code _
Technical Contact 1
R&bect And^^on <
Public Contact 1
MQfh A. Franch • (
a. SIC Code b, e.
Latitude I Lenottuda . .
Oe«. Mln. See. I Oeg. . Mto. See.
Dun * Bradstreet Numtaer(e) D
EPA Uentlncatlen Number (RCRA LO. No.) O-
*V^A^n^0^0^3^l^i^5^'7^7^O A///1^^ i i i i i i i
NPO6S PeinUt Number(e) I b.
*V \A\0\0\0\ /i3i3i3| • A//it \ i -i i i i i
Name of necelvtoq Stream(«) or Water Bodyd)
*• RnanrtW. f?iV?r~ •+* &>&»*)**. ft'sas- /3**u* -fo
«
)«tf> trtyrt
(o /3C/ZX
TMa report contain* Information for: (check one)
D> j | Part of a covered facility.
r4/2)277- 2^3
Wh«r« to ••nd oompl«t«d forms:
~" U. 8. CflvktmrmntaJ Protactton Agvncy
P.O. BOK 7Q2M
WeMMnoton, DC 20024-0266
-
€\D<£U^Of^GL g\i tf&^~ "i^JlM T^ •DeAt6/ t^t
b" A//A ...
*' tijfl
Undergraund t^ectlen Vtfefl Code (UC) Uentlflcatlon No.
Af^V i t i i i i i i i 1 "
«. PARENT COMPANY INFORMATION
4.1
4.2
Parent Company- • Dun * Bradatreet No. . .. -.;. . .. .
A/y^i-i i i i-i i i i 1 •" ; ; ; ; __
• - 278373
... ..^ .... s» f W O.t •»•* •
EPA Form 935O-1 (1-M)
-------
(Imp ortant: Typt or print; rtad instructions btfort competing form.) " ~r ' " Pao*2ofS
.. '. , .. ... .. ... (Thteapaoa tar EPA ue» only.)
- . EPA FORM R
' PART B. OFF-SITE LOCATIONS TO WHICH TOXIC '
— ' CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTW) . • -
Facility Mama
A//A
Straat Addraa
City
State
'- •• •
County
Zip
1 1 1 1 l-l 1 1 1
1
2. OTHER OFP-SiYE LOCATIONS - Number these locations sequentially on this and any additional paae of this form you use.
| | Othor off-slt* location fij/fi
EPA fcentmcatlen Number (RCRA O. No.) | (
/ ' '
1 1 1 1 1 1 1 1 1 1
Facility Nama
Straat AddraM
City
Stata
County
Zip
1 III l-l 1 II
•
•
to location undar oontral of reporting faculty or parent company? | | [ |
Va« N»
| | Other off-slt* location
EPA Identification Number (RCRA O. No.) | ,
1 1 1 1 1 1 1 1 1 1
PacMty Nama
A) /A
Straat Addrau
City
Stata r .-
County
Zip '
1 1 1 1 l-l 1 1 1
to location undar control of raportlng faculty or parent company? j j [ j
Ye* No
["~| Other off-site location
EPA Identification Number (RCRA O. No.) | |
1 1 1 1 1 1 1 1 1 1
Faculty Nama ...
StFWt AttOTeWS
City
Stata
County
Zip • • -
1 III l-l 1 II
to location urioar control of reporting facJOty or pai>i ii uui«<« 171 i i i i
Ye* No
j | ChaO IT addWonal psga» of Part i are attached. ... • : *, . •
..'• ' . ' ..••:•-••
- 278379
EPA Form 9350-1(1-48)
-------
f/mpcrtonr: Type or print; read ln'~"vetlora before completing form.) -•••••• ' v • • -. • • • .- • -. ' . - :- pag> 3 of 5
...'.... . CThJaepeeeterePAueeomy.)
EPA FORM R
_ _ PART III. CHEMICAL SPECIFIC INFORMATION
1. CHEMICAL IDENTITY
1.1
1.2
1.3
1.4
2.
| I Trade Secret
CAS.| | | |
(Provide a generic name in 1.4 below. Attach substantiation form to this submission.) . . _
1 1Z 1 0 I ~U_LZJ -P7| (U*erieadln| seres if CAS number does not m space provided.)
Chemical or' Chemical Category Name «
Arvtomcenc.
Oenerle Chemical Name
(Complete emyH 1.1 to ehaoked.) :
*
MIXTURE COMPONENT IDENTITY (Do not complete this section if you have completed Section 1.)
Oenerle Chemical Name
Provided by Sutler (Urntt the name to a maximum of 70 eharaetare (e.e.. number*, tettere. m«nei. punctuation)).
3. ACTIVITIES AND USES OP THE CHEMICAL AT THE FACILITY (Check aO that apply.)
3.1
3.2
3.3
Manufacture:
Process:
Otherwise Used:
a.l 1 Produce b. 1 i Import . e.| 1 For on-srie
1 — > !— « I—J use/processing
dO5s«5lSon e.Q| As a byproduct f. Q As an Impurity
a. fl As a reactant "•[~~lAlJL!SE!itotlon c. rP^_an.artteie
d. | \ Repackaging only
*-JZHprocess*tg'aJd b. | \ As a manufacturing aid c.j | AnOary or other use
4. MAXIMUM AMOUNT OP THE CHEMICAL ON SITE AT ANY TIME DURING THE CALENDAR YEAR
|0|*fi (enter code)
5. RELEASES OP THE CHEMICAL TO THE ENVIRONMENT
You may report releases of less than
1.000 fes. by checking ranges under. A.I.
5.1 Fugitive or non-point air omissions
5.2 Stack or point air emissions
5.3 Dischargee to water 5-3-1 |
-------
ft. TRANSFERS OF THE CHEM' ". IN WASTE TO OFF-SITE LOCATIONS
*»••» fan 1.000 fee. by oheoHne.
«• ^
B.1 Dtooherp* to POTW
Other off-alte location r—i
8.2 (Enter Meek number I I
from Pan 1. Section 2.) «— J
6.3 Other off-«ne location f~~1
(Enter Meek numeer I 1
tram Peril. Section 2.) « >
6.4 Other off-«Ke location r— 1
(Enter Meek number 1
from Part 1. Section 2.) 1— '
A.Totaj Transfers
ftos/vr)
A.1
rieuuiltiu Ranges
0 1-409 600-000
•
iv»necK a BoaKionai nrormauon is provi
- •
r
A.2
Enter
Estimate
WA
A//4
tJ/fi
A///}
8. Basis of Estimate
(sntsr code)
•>
s.ib D
6.25 D
e.sb D
e.4b Q
C. Type of Treatment/
•Disposal (enter cede)
u. 1 1 1
..>= 1 1 1
••* 1 1 1
Ided on Part IV-Supplemental Information)
7. WASTE TREATMENT METHODS AND EFFICIENCY
A. General
Wastestream
(enter code)
7.1. [yJl
7.2. f J
7;3. n
7.4. [~~]
7.5. {__]
7.6. j |
7.7. j |
7.8. D
7.9. rn
7.10. m
7.11. rn
7.12. |~~]
7.13. Q
7.i4. r i
a
7.1b
7.2b
7.3b
7.4b
7.5b
7.6b
7.7b
7.8b
7.9b
7.10b
7.11b
7.126
7.13b
7.14b
Treatment
Method ^ . /
(enter code)
IAII II I
AtfAl I
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I
I I-
C. Range of
influent
Concentration
(enter code)
Me [10
7.2c | |
7.3c j |
7.4c \ |
7.5c [ |
7.6c j^j
7.7c | |
7.80 Q
7.9c |~~|
7.10C' | |
7.11c | |
7.12c | |
7.13C j {
7.14c j~Tj
D. Sequential
Treatment?
(check If
aDDlteablat
7.1d Q
7.2d Q
7.3d [ ]
7.4d Q
7.5d \^~\
7.6d r~~]
7.7d |~|
7.8d { ]
7.9d | |
7.10d Q]
7.11d [ "I
7.12d | |
7.13d j j
7.14d | j
E. Treatment
Efficiency
Estimate
7.1e Qfa %
*
7.2e %
7.3e %
7.4e %
7.5e %
7.6e %
7.7e %
7.8e %
7.9e %
7.10e %
7.11e %
7.12e %
7.13e . %
7.140 %
F. Bassd on
Operating
Data?
Yes No
7.11 Q 0"
« n n
« n n
7.4. Q Q
»-• n n
'.«• n n
».» a a
7... a D
"• a a
7.i« Q Q
p1 ™"i i "™i
7.«f n n
7.13f Q Q
7-^ n n
| | (Check If additional ^formation Is provided on Part IV-Supplemental Information.)
8. OPTIONAL INFORMATION ON WASTE MINIMIZATION
(Indteate actions taken to reduce the amount of the chemical being released from the faclty. See the Instructions for coded
ttems and an explanation of what Information to Include.)
A. Type of
modification
(enter code)
m
B. Quantity of the chemical In the wasteslream C. Index D. Reason for action
prior to treatment/disposal . (enter cods)
• Current Prior j Or percent
reporting year , change
yea/ (tbs/yr) (tos/yr) ,
! % nn
278331
LJU
EPA Form 9350-1 (1-88)
-------
(Important: Type or print; read • 'actions btfort computing form.)
EPA FORM R
. PART IV. SUPPLEMENTAL INFORMATION
UM this Motion If you need addKtonal space for answers to cjueetJone In Parts I and HI.
Number or tetter this Information sequentially from prior sections (e.g.. O.E. F. or 5.54, $.55).
Pag* $ of 5
fTN» apaoa lor EPA ua*
ADDITIONAL INFORMATION ON FACILITY IDENTIFICATION (Pan 1 - Section 3)
3.5
3.7
3.8
3.9
3.10
8>C Coda
1 1 1
Out 4, Braoitr
•Baaae*
1 1 - 1
1 1 1
1 • 1 1 - 1
1 1 1
i 1 1
EPA Hantlllcatlon Nunfear(a) RCAA LO. No.)
1 I I 1 1 1 1 1 1 1
NPOeSParmtt
MBJB^B*
1 1 1
Nam* of Raeo
«••••»
1 1 1 1
1
•i
1 1 - 1 1 1 1 - 1 1 1 I
J
Mng Straam(a) or Watar Booyoy
1 1 1 1 1 1 1 1 1
1 1 1 1 1 1 1 1
ADDITIONAL INFORMATION ON RELEASES TO LAND ( Part III • Section 6.6)
Releases to Land
5.5 | | | | (—-.,
5.5 MM M»)
5-5 !»>< i— '«*>
5.S a
5.5 a
5.5 a
A. Total Release
(tes/yr)
A.I
Reporting Rang**
0 1-490 MO-OTO
A.2
Enter
Estimate
8. Baste of
Estimate
(enter code)
«_«> D
6.5 b D
5.5 b Q]
ADDITIONAL INFORMATION ON OFF-SITE TRANSFER ( Part III - Section 6)
6-__ Ofacharga to POTW
Other efl-slta location r—i
6 (Emar block nwnoar 1
from Part 1. 6actlon2.) »— J
Ottw on-atto location I— I
6. (Emar Mock nvcnear _ . II
— r- from Pan 1. Section a.) 1— J
•
8. a
6.
6.
a
a
A.Total Transfers
(tes/yr)
A.I
Reporting Ranges
0 1-«» SOO-0M
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code)
«•_ 'CD
6. bD
6. bD
C. Type of Treatment/
Disposal (enter code)
6. c. LZ
«•__ c. [Z
i i
l i
ADDITIONAL INFORMATION ON WASTE TREATMENT (Part III - Section 7)
A. General Wastestream
(enter code)
7. . n
7. . n
7. . n
7._. n -
7. . n
B. Treatment
Method
(enter code)
7. b LZ
7. b LZ
7. b LZ
7. b LZ
7. b LZ
1 1
1 1
1 1
1
1 1
C. Range of
Influent
Concentration
(enter code)
7. c
7. e
7. c
7. c
7. c
n
n
n
n
n
D. Sequential
Treatment?
(check If
applicable)
7. - n
.7. « n
7. , n
7. ,. n
7. - n
E. Treatment
Efficiency
Estimate
7. e - %
7. • %
7. e %
7. e %
7. e %
F. Based on
Operating
Data?
V«s No
7. , n n
7. . n n
7. - n n
7. . n n
». . n n
EPA Farm 9350-1 (1-«8) *• ' ^
-------
Form Approved OMB No.; 2070-0091
(Important: Type or print; read instructions before completing form.)
Approval Firplr... 01/91
Page 1 of 5
- U.S. Environmental Protection Agency . . . -.
o-B=A TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM FORM
~ ' R
Section 313. Title III of The Superfund Amendments and Reauthorization Act of 1986
PART 1. FACILITY IDENTIFICATION INFORMATION
l.
| | Yes (Answer 1.2) | U^No (Do not answer 1.2) . I I
15-87-0 1054538- 3- \/A
t a sanitized copy? 1 . 3 Reporting Year
Yv | | NO i £ffT'7
2. CERTIFICATION (Read and sign after completing all sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true
and complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the oreparers
of this report. ' v
Name and official title of owner/operator or senior management official
James _.%. fhtchetier Vice. 'PfKifanh' Mdrv.oer
Signature //-, _^^ *^ ^ ^^ '
3. FACILITY IDENTIFICATION
3.1
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
Facility or Establishment Nam*
Street Address
City _ County .
^S^/O 1 ^^ 1*^*^ J*^/*\X5 lf\/*~\ r**^^
^^XCy^,! t_- Fil f\\^,*A ' *^~ "
State i Zip Code
Technical Cdtttact
KYR\h^^f'f~ l\ fY^l ~& *f ^Q Y~\
Public Contact
wafh A. Franch
a. SIC Code b. c.
Latitude Longitude
Oeg. Mln. Sec. Oeg. Mln. Sec.
Dun & Bradstreet Number (s) j,
0 \0\ - 1 3| / \**. R,y*r- SuLt>«*;^
b.
C.
Undergraund Injection Well Code (UIC) Uentlflcatlon No.
273333
4. PARENT COMPANY INFORMATION _A
4.1
4.2
Name of Parent Company
AJ/A •
Parent Company' • Dun & Bradstreet No.
AMi.i i i i.i i i i '
. A%^"
2r^ •
EPA Form 9350-1 (1-88)
-------
(L..portnnt: Type or print; read instructions before completing form.)
Page 2 of 5
(This spac* for EPA UM only. )
EPA FORM R
PART II. OFF-SITE LOCATIONS TO WHICH TOXIC
' CHEMICALS ARE TRANSFERRED IN WASTES
I. PUBLICLY OWNED TREATMENT WORKS (POTW)
Facility Nam*
A; /A
Street Address
City
Stat*
County
Zip
I III l-l I II
'•
2. OTHER OFF-SITE LOCATIONS - Number these locations sequentially on this and any additional paga of this form you use.
| 1 Other off-site location flj/fi
EPA Identification Number (RCRA ID. No. ) [ ,
I I I I I 1 I 1 1 1
Facility Nam*
Sir MI Address
City
Stat*
County
Zip
1 1 1 1 l-l 1 1 1
»
1* location under control o1 reporting facility or parent company? | | [ [
Yea No-
I | Other off-site location
EPA Identification Number (RCRA IO. No. ) | (
1 1 1 I 1 1 1 1 1 1
Facility Nam*
NW
Street Address
City
Stat*
County
Zip
till l-l 1 1 1
-
Is location und*r control of reporting facility or parent company? I I [ [
Y«s No
| | Other off-site location
EPA Identification Number (RCRA O. No.) [ ,
1 1 1 1 1 1 1 1 1 1
Facility Nam*
tv /A
Street Address
City
Stat*
County
Zip -
1 III l-l 1 II
Is location under control of reporting facility or parent company? [ | j j
Yes No
| | Crwck If additional pages of Part a are attached.
EPA Form 9350-1 (1-88)
?78384
-------
(Impcrtart: Type or print; read instructions before completing form.) • paga 3 of s
(This spac* for EPA usa only. )
EPA FORM R
_ PART 111. "CHEMICAL SPECIRC INFORMATION
1. CHEMICAL IDENnTY
1.1
1.2
1.3
1.4
2.
1 1 Trade Secret (Provide a generic name in 1.4 below. Attach substantiation form to this submission.)
CAS* |
Chemical or Chamlcal
| 3| Zj ~|6 14" 1 ~ / 1 (Use lading zeros if CAS number does not fill space provided.)
Catagory Nam* rv ' • r
L)i ben zcforan
G*n*rlc Chamlcal Nam* (Compl*t* only If 1. 1 1* cnackad. )
MIXTURE COMPONENT IDENTITY (Do not complete this section if you have completed Section 1.)
O*n*rtc Chamlcal Nama Provldad by Suppllw (Limit th* nama to a maximum of 70 character* (a.g.. numbars. lattara. spac**, punctuation)).
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
3.2
3.3
Manufacture:
Process:
Otherwise Used:
a.l 1 Produce b. 1 1 Import c.l 1 For on-stte
1 — 1 1— 1 1 — 1 use/processing
d- D distribution e. Q As a byproduct f. Q As an Impurity
a.l 1 As a reactant b. 1 1 A» a formulation C- (T^As an article
I — 1 1— (component LJ— 1 component
d. | | Repackaging only
a. | | procelsln'ti'afd b. Q As a manufacturing aid c. Q Ancfllary or other use
4. MAXIMUM AMOUNT OF THE CHEMICAL ON SITE AT ANY TIME DURING THE CALENDAR YEAR
|Q 1 tf | (enter code)
S. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT
You may report releases of less than
1,000 Ibs. by checking ranges under. A.I.
5.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to water 5.3.1 Q
(Enter lattar coda from Part 1
Sactlon 3. 10 for straams(s).) ( 1
5.3.2 | I
5.3.3 Q
5.4 Underground Injection
5.5 Releases to land
Ibl^ l^ I (antarcoda)
S.5.2 fO \0 ]_*3 (ant*r cod*)
5.5.3 I | (antarcoda) .
| J (Cnack If additional Information Is provioad on
5.1a
5.2a
5.3.1a
5.3.2a
5.3.3a
S.4a
5.5.1a
5.5.2a
S.5.3a'
A. Total Rele
(Ibs/yr)
A.I
Reporting Ranges
0 1-499 500-899
-
ase
A.2
Enter
Estimate
(^*fQ
10
0
MA
A//4
A///?
• HC
Zfr)
/v7A
B. Basis of
Estimate
(enter code)
S.lb fil
5.2b [^
5.3.1b Q
S.3.2b Q
5.3.3b Q
5.4b QJ
5.5.1b f*T|
5.5. 2b [£]
5.5.3b Q
.
C. % From Stormwater
5. 3. 1c fj/fi
5.3.20
5.3.30
J Information.)
EPA Form 9350-1 (1-88)
-------
EPA FORM ft. Part III (Continued)
Page 4 of 5
8. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report tranatar*
of In* than 1.000 Ib*. by chocking
rang** undw A. \ . _
6. 1 Discharge to POTW
Othw orf-«tt« location I 1
6.2 (Entw block number
from Part », Section 2.) 1— '
6.3 Othur off-slta location 1 1
(Ent*r block numbw
from Part ». Section 2. ) 1 1
6.4 Other off-*lta location I 1
(Entw block numbw
from Part H. Section 2. ) ' '
A. Total Transfers
(Ibs/yr)
A.I
Reporting Ranges
0 1-400 500-409
-
A.2
Enter
Estimate
AY/I
A/A
AM
WA
8. Basis of Estimate
(enter code)
6.1b LJ
6.2b I — I
6.3b I I
6.4b []
1 1 (Check If additional Information Is provided on Part IV-Supplemental Information)
C. Type of Treatment/
Disposal (enter code)
6.2c
6.3c
6.4c
EPA Form 9350-1 (1-88)
-------
Form Approved OMB No.:_207Q-0093
(Important: Type or print; read instructions before completing form.)
Approval P«plr«.. 01/91
Paqe 1 of 5
_ U.S. Environmental Protection Agency . . . _.
offlA TOXIC CHEMICAL RELEASE INVENTORY REPORTING FORM FORM
" ' R
Section 313, Title III of The Superfund Amendments and Reauthorization Act of 1986
PART 1. FACILITY IDENTIFICATION INFORMATION
l.
1 . 1 Does this report contain trade secret Information? 1 .2 - Is this a sanltli
. | | Yes (Answer 1.2) | k-J^No (Do not answer 1.2) . [ ] Yes j
13-87-01054539-5- \ZA.
»d copy? 1.3 Reporting Year
m ^ • / ^7
2. CERTIFICATION (Read and sign after completing all sections.)
I hereby certify that I have reviewed the attached documents and that, to the best of my knowledge and belief, the submitted information is true
and complete and that the amounts and values in this report are accurate based on reasonable estimates using data available to the preparers
of this report. ' i.
Name and official title of owner /operator or senior management official
SlQnjtturv g . — « ^^ -^ / \^J
3. FACILITY IDENTIFICATION
3.1
3.3
3.4
3.5
3.6
3.7
3.8
3.9
3.10
3.11
Facility or Establishment Name -
Street Address
City _ County
~*)Q\ ^ YY~\ K.C'^A f\G ¥y^.
State . Zip Code
l//l/$//Ol <£L- 2- I ^! / |5| 3l-l I I I
Technical Gdhtact
Robert And^son
Public Contact
Kafh A. Franch
a. SIC Code b. c.
z.4-,^,/ A//4, , 4fA
Latitude Longitude
Oeg. Mln. Sec. Oeg. Mln. Sec.
Ol^ \7\ /\S\O\O O\8 \O\O 7 \C\C
Oun & Bradstreet Number(s) «,
a._ .n •21') ^C*7^/1 A//£J
0 \O\- \O\I |«X| - \O\/\ f\O fV/rl - | | | | - | | | |
EPA Identification Number (RCRA I.O. No.) b
V \A\O\ 0\0 \3 \ > \2- 1 57 /i/ \O /VA/I \ \ \ \ \ \ \ \ \
NPOES Permit Number(s) 1 b.
Name of Receiving Streem(s) or Water Body(s)
K&*«£ntfitinmfnkJ Ser -frT^
b' V/A
N/'/'A - #>
Underground Injection Well Code (UIC) Identification No. . .I^J*
**r*f i i i l l l i i i 1 N.
4. PARENT COMPANY INFORMATION ^
4.1
4.2
Name of Parent Company
AJ/A
Parent Company's Oun & Bradstreet No. ...".. ' . £
I\J /Pt\ 1 1 1 1 - 1 II 1
^SP
|iyOO-OO • • v% *
EPA Form 9350-1 (1-8fl)
-------
(Important: Type or print; read instructions before completing form.)
Page 2 of 5
(This space for EPA use only.)
EPA FORM R
PART II. OEF-SITE LOCATIONS TO WHICH TOXIC
- ' CHEMICALS ARE TRANSFERRED IN WASTES
1. PUBLICLY OWNED TREATMENT WORKS (POTW)
Facility Name
A/ /A
Street Address
City
State
"- •' •
County
Zip
1 III l-l 1 II
•
2. OTHER OFF-SITE LOCATIONS - Number these locations sequentially on this and any additional page of this form you use.
| 1 Other off-site location f^/fa
EPA Identification Number (RCRA IO. No. ) ,
1 1 1 1 1 1 1 1 1 1
Facility Name
Street Address
City
State
County
Zip
1 III l-l 1 II
4.
•
Is location under control of reporting facility or parent company? 1 1 I 1
Yes No-
f ] Other off-site location
EPA Identification Number (RCRA IO. No.) (
1 1 1 1 1 1 1 1 1 1
Facility Name 1 i
Street Address
City
State ••
County
Zip
1 1 1 1 l-l 1 1 1
' -. '- _ '
Is location under control of reporting facility or parent company? 1 1 1 1
Yes No
I""] Other off-site location
EPA Identification Number (RCRA O. No.) (
1 1 1 1 1 1 1 I 1 1
FacmtyNam. ^fl
Street Address
City
State
County
Zip • '
. I 1 1 l-l 1 1 1
Is location under control of reporting facility or parent company? [ [ L |
Yes No
I"""] Check If additional pages of Part 1 are attached. • '. - •
2783S9
EPA Form 9350-1 (1-88)
-------
(Important: Type or print; read instructions before completing form.)
EPA FORM R
PART III. CHEMICAL SPECIFIC INFORMATION
Page 3 of 5
(This space) (or EPA UM only.)
1. CHEMICAL IDENTITY
1.1
Trade Secret (Provide a generic name in 1.4 below. Attach substantiation form to this submission.)
1.2
CAS*
Q | 0\0 | OR I 2.1 ~\5 I 2.1 -|4| (Use leading zeros if CAS number does not fill space provided.)
1.3
Chemical or' Chemical Category Nun*
1.4
Generic Chemical Nam* (Complete only If 1.1 Is checked.)
MIXTURE COMPONENT IDENTITY (Do not complete this section if you have completed Section 1.)
2.
G*n*rtc Chemical Name Provided by Supplier (Limit the name to a maximum of 70 characters (e.g., number*, letters, spaces, punctuation)).
3. ACTIVITIES AND USES OF THE CHEMICAL AT THE FACILITY (Check all that apply.)
3.1
3.2
3.3
Manufacture: a.f [ Produce
d 1 I For sale/
a-| — 1 distribution
Process: a.f | As a reactant
d. [ [ Repackaging only
_ . . ... 1 1 As a chemical
Otherwise Used: a.| | processing aid
b. 1 1 Import
e.| | As a byproduct
b I 1 As a formulation
' 1 — 1 component
b. [ 1 As a manufacturing aid
c 1 1 For on-slte
' 1 — 1 use/processing
f . | | As an Impurity
c 1 Ixf^8 an art'cle
* 1 — 1 component
c. [ ] Ancillary or other use
4. MAXIMUM AMOUNT OF THE CHEMICAL ON SITE AT ANY TIME DURING THE CALENDAR YEAR
| QlH-l (enter code)
5. RELEASES OF THE CHEMICAL TO THE ENVIRONMENT
You may report releases- of less than
1.000 Ibs. by checking ranges under. A.I.
5.1 Fugitive or non-point air emissions
5.2 Stack or point air emissions
5.3 Discharges to water 5.3.1 |fl |
(Enter letter cod* from Part 1
Section 3. 10 for streants(s).) 1 1
5.3.2 1 1
5.3.3 Q
5.4 Underground Injection
5.5 Releases to land
fc? 1*? l^?l (enter coo*)
5.5.1 1 1
S.S.2 ID I0l6l (enter cod*)
5.5.3 | 1 _| 1 (enter cod*)
5. la
5.2a
5.3.1a
5.3.2a
5.3.3a
5.4a
5. 5. la
5.5.2a
5.5.3a
A. Total Release
(Ibs/yr)
A.I
Reporting Ranges
0 1-499 500-999
-
• A.2
' Enter
Estimate
z£c
10
0
fit/A
N/A
u/A
•LfC
/30
A//A
B. Basis of
Estimate
(enter code)
5.1b \£\
5.2b \B\
5.3. 1b Q
5.3.2b Q
5.3.3b Q
5.4b [_]
S.S.Ib [7TI
5.5.2b [£J
5.5.3b | |
C. % From Stormwater
5.3.1CA,y£>
5.3.2c
5.3.3C
278390
j j (Check If additional Information Is provided on Part rV-Suppl*rn*ntal Information. )
EPA Form 9350-1 (1-88)
-------
EPA FORM H, Part III (Continued)
Page 4 of 5
6. TRANSFERS OF THE CHEMICAL IN WASTE TO OFF-SITE LOCATIONS
You may report tranifer*
•of le«« than 1,000 lot. by checking
rang** under A.I.
6.1 Discharge to POTW
Other oft-*lte location ( 1
6.2 (Enter block number
(ram Part H, Section 2.) ' '
6.3 Other off-«lte location I 1
(Enter block number
from Part ». Section 2. ) ' '
6.4 Other off-tlte location I 1
(Enter block number I I
from Part D. Section 2. ) ' '
A. Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-400 500-099
r
A. 2
Enter
Estimate
NIK
MA
A'//?
A///I
B. Basis of Estimate
(enter code)
6.1b I |
6.2b I — I
6.3b I I
6.4b Q
D (Check If additional Information Is provided on Part IV-Supplemental Information)
*
C. Type of Treatment/
Disposal (enter code)
6.2c I
6.3c |
6.4c |
EPA Form 9350-1 (1-88)
-------
•^Important: Type or print; read instructions before completing form.)
Page 5 of S
EPA FORM R
PART" IV. SUPPLEMENTAL INFORMATION
• rf^r\ i iv» our r wbivi&iY i *>\i» ii^r^wniTm i iwiv
Use this section If you need additional space for answers to questions In Parts I and III.
Number or letter this Information sequentially from prior sections (e.g.. D.E. F. or 5.54. 5.55).
(This (pace for EPA us* only.)
ADDITIONAL INFORMATION ON FACILITY IDENTIFICATION {Part 1 - Section 3)
3.5
3.7
3.8
3.9
3.10
SIC Cod*
1 1 1
1 1 1
Dun & Bradttreet Numo*r(()
1 1 - 1 1 - 1 1 - 1
1 1 1
1 1 1
EPA Identification NumD*r(*) RCRA 1.0. No.)
" 1 1 1 1 1 1 1 1 1 1
NPOES Permit
1 1 1
Nam* of R*c*
Nurno*r(«)
1 1 1 1
1
1 1 - 1 1 1 1 - 1 1 1 1
1
iving Stream(s) or Water Booy(s)
1 1 1 1 I 1 1 1 1
1 1
1 i 1 1 1 1 1 1
<•
ADDITIONAL INFORMATION ON RELEASES TO LAND ( Part III - Section 5.5)
Releases to Land
5.5 1 (*nt*r cod*)
5.5 | (*nt*reod«)
5.5 1 (*nt*r cod*)
5.5 a
5.5 a
5.5 a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1-490 50O-899
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code)
5.5 b Q
5.5 b | |
5.5 b Q
ADDITIONAL INFORMATION ON OFF-SITE TRANSFER ( Part III
6- Discharge to POTW
Other off-site location r— i
6 (Enter block numoer 1 1
from Part a. Section 2. ) 1 1
Other off-site location l— 1
6. (Enter Block numoer 1
from Part n. Section 2.) 1— J
- Section 6)
A. Total Transfers
(Ibs/yr)
6. a
6.
6.
a
a
A.I
Reporting Ranges
0 1-499 500-999
ADDITIONAL INFORMATION ON WASTE TREATMENT (Part III -
A. General Wastestream
(enter code)
7. , n
7. . n
7. . n
7. a 1 1 -
7. a D
B.
7. b
7. b
7. b
7. b
7. b
EPA Form 9350-1 (1-88)
Treatment
Method
(enter code)
A.2
Enter
Estimate
Section 7)
C. Range of
Influent
Concentration
(enter code)
7. . n
7. c
7. e
7. C.
7. C
i
B. Basis of
Estimate
(enter code)
s-— b n
6. b I I
6. bD
C. Type of Treatment/
Disposal (enter code)
6
c.
6. c.
D. Sequential
Treatment?
(check If
applicable)
7 rl
7. d
7. „ n
7. „ n
7. d
E. Treatment
Efficiency
Estimate
7. e %
7. e %
7. e %
7. e %
7. e %
. F. Based on
Operating
Data?
Yes No
7. , n n
7. f
7. , n
7. f 1
7. f n n
278392
-------
'Important: Type or print; read instructions before completing form.)
Page 5 of 5
EPA FORM R
PART-1V. SUPPLEMENTAL INFORMATION
Use this section If you need additional space for answers to questions In Parts I and III.
Number or letter this Information sequentially from prior sections (e.g., D.E. F. or 5.54. S.5S).
(Tni« space tor EPA use only.)
ADDITIONAL INFORMATION ON FACILITY IDENTIFICATION (Part 1 - Section 3)
3.5
3.7
3.8
3.9
3.10
SIC Coda
1 1 1
1 1 L
Dun & Bradstreet Numoer(s)
1 1 - 1 1 • 1 1 - 1
1 1 1
III
EPA Identification Number(s) RCAA I.D. No.)
. 1 1 1 1 1 1 1 1 1 1
NPOES Permit
1 1 1
Numoer(s)
III!
1
1 1 - 1 1 1 1 - 1 1 1 1
1
Nam* of Receiving Stream(s) or Water Body(i)
1 1 I 1 1 1 1 1 1
1 |
1 1 1 1 1 1 1 1
t>
ADDITIONAL INFORMATION ON RELEASES TO LAND ( Part III - Section 5.5)
Releases to Land
5.5 (enter code)
5.5 (enter coo*)
5.5 (enter code)
5.5 a
5.5 a
5.5 a
A. Total Release
(Ibs/yr)
A.1
Reporting Ranges
0 1-409 SOO-flOB
A.2
Enter
Estimate
B. Basis of
Estimate
(enter code)
5.5 b n
5.5 b D
5.5 b [3
ADDITIONAL INFORMATION ON OFF-SITE TRANSFER ( Part III - Section 6)
°- Discharge
to POTW
Other off-site location r— i
5 (Enter block number
from Part H. Section 2. ) 1 1
Other off-stte location r~ ~|
6. (Enter block number 1
from Pan a. Section 2.) 1— '
A. Total Transfers
(Ibs/yr)
A.1
Reporting Ranges
0 1-499 500-899
6. a
6.
6.
a
a
ADDITIONAL INFORMATION ON WASTE TREATMENT (Part III -
A. General Wastestream
(enter code)
7. a D
7. a D
7._a D
7. a 1 1 -
7. a C
B.
7. b
7. b
7. b
7. b
7. b
Treatment
Method
(enter code)
A.2
Enter
Estimate
Section 7)
C. Range of
Influent
Concentration
(enter code)
7. c
7. c
7. c
7. c.
7. c
n
n
n
n
B. Basis of
Estimate
(enter code)
6-_ b D
6. bD
6. bQ
C. Type of Treatment/
Disposal (enter code)
6. c.
6. c.
0. Sequential
Treatment?
(check If
applicable)
7. . n
7. d L 1
7. d
7. d
7. d n
E. Treatment
Efficiency
Estimate
7. e %
7. e %
7. e %
7. e %
7. e %
i
F. Based on
Operating
Data?
Yes No
7. , n :
7. . n :
7. f
7. , n :
7. , n :
EPA Form 9350-1(1-88)
270393
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APPENDIX B.
TRIP REPORTS
-------
MIDWEST RESEARCH INSTITUTE
Suite 350
401 Harrison Oaks Boulevard
Gary, North Carolina 27513
Telephone (919) 467-5215
Facsimile (919) 467-8060
Date: September 22, 1988
(Revised May 10, 1989)
Subject: Site Visit—Koppers Company, Inc., Salem, Virginia
Wood Treatment Operations: Engineering Evaluation
EPA Contract 68-02-4379, Work Assignment No. 13 and 25
MRI Project 8950-13 and 8952-25
From: C. Vaught <*V
To: Bruce Moore
Industrial Studies Branch
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
I. Purpose
To gain an understanding of the treatment process and practices
employed by Koppers and identify potential sources of odor.
II. Place and Date
Koppers Company, Inc.
Post Office Box 908
Salem, Virginia 24153
(703) 380-2061
September 1, 1988
III. Attendees
Koppers Company (Koppers)
Mark Franck, Plant Manager
U. S. Environmental Protection Agency (EPA)
Bruce Moore
Midwest Research Institute (MRI)
Becky Nicholson
Chuck Vaught
-------
IV. Process Description
The Koppers facility, located in Salem, Virginia, is a wood
preserving plant that treats 20 to 25 percent seasoned and 75 to
80 percent unseasoned (green or undried) cross ties and switch ties for
the Norfolk & Southern Railroad. The plant treats approximately
3,000 ties per day and operates 24 hours per day, 5 days per week. The
plant has been in operation since 1955. A process flow diagram for the
Koppers wood treatment process is presented in Figure 1 and photographs
from the plant visit are attached.
A. Wood Treatment Process
The Koppers plant operates three steel treatment cylinders or
retorts, each 8 feet in diameter and 140 feet long. The retrofits operate
on a staggered schedule. Approximately 1,000 ties (approximately
3,200 ft of wood) are treated per charge in each retort. The charge is
rolled into the retorts on 16 small raiTears each of which holds
approximately 70 ties with small wood spacers between each tie. After the
charge is loaded and the door is closed, the retort is filled with about
20,000 gallons of a 60/40 creosote/coal tar mixture (just enough to cover
the ties) from one of four 50,000-gallon working tanks.
The creosote and coal tar are mixed off site by the supplier. The
plant is designed to use creosote solutions containing no more than
7 percent naphthalene. Excessive quantities of naphthalene in the
preservative can precipitate and clog various transfer pipes. Koppers
specifies to their preservative supplier that the creosote solution
contain 7 percent naphthalene.
After the retort is filled and sealed, the contents are heated to
between 190° and 200°F and 24 inches of mercury vacuum is pulled on the
system for 16 to 18 hours (Boultonlzing). This lowers the moisture
content of the unseasoned wood by removing water from the sapwood and
replacing it with the creosote oil. Water and vapors are carried out
under induced vacuum to a condenser; the condensate is sent to an effluent
treatment system. At the end of the Boultoning cycle, the creosote
solution is pumped from the retort back to the work tanks. The vacuum is
maintained in the retort for an additional one-half hour to reduce further
the moisture content of the wood. By monitoring how much water has
condensed in the condenser, the operator knows when the optimum moisture
content has been reached. At that point, 50 psi pressure is applied for
30 minutes to an hour to force the residual creosote solution into the
wood. Next, 30,000 gallons of the creosote solution from the working
tanks is reintroduced into the retort, heated to between 190° and 200°F,
and pressurized to between 160 and 170 psig for 2 to 4 hours depending on
the species of wood (Rueping process). The creosote used in the Rueping
process must contain less than 3 percent water in order for proper
treatment to occur. The Boultonizing cycle dehydrates the creosote
solution in addition to the charge that is being treated.
-------
A Vent to
T
Atmosphere
( Scrubber J
w
o
R
K
T
A
N
I
W
0
R
K
T
A
N
w
o
R
K
T
A
N
K
t
W
O
R
K
T
A
N
K
\
[ Creosote/Coal Tar
^
fe
H
r-*r
Vapors
RETORT N
Noncondensables
A Steam
•
I
STEAM JET
INJECTOR
Water
Spray Water
Irrigation
Field
Oil/Water
Separator
(used as
holding tank)
Water
1
| Steam
Condensate
Aeration
Tank
Effluent
Holding
Tanks
Naphthalene/Creosote
Naphthalene
Recovery
Tanks
Liquids
Gases
Wood
Figure 1. Process flow diagram of Koppers1 Salem, Virginia wood treatment operation.
-------
The Rueping process compresses the air in the interior wood cells
and forces the preservative into the wood. The pressure is maintained
until the target preservative retention level is reached. Koppers1 target
retention as specified by the Nolfolk & Southern Railroad is 7 to 8 pounds
of preservative per cubic foot of wood with 65 percent of the annual rings
in the tie being treated for red oak. When this is accomplished, the
pressure is relieved and the retort is emptied of preservative. The
expanding air in the interior wood cells expels the preservative leaving
an empty, treated cell (i.e., the creosote adheres to the cell walls).
The vacuum (22 to 24 inches of mercury) is then reapplied for about 1 hour
to extract residual creosote that tends to drip upon removal of the
charge, thus producing a cleaner product and allowing recovery and recycle
of excess preservative (which currently costs $0.80 to $1.40 per
gallon). A diagram depicting the pressure fluctuations during a treatment
cycle is shown in Figure 2.
Following the final vacuum, the retort door is opened, the rail
bridge is lowered, and the charge is pulled from the retort by a small
locomotive. During the site visit, a small amount (approximately
5 gallons) of creosote spilled from the retort into the sump below when
the retort door was opened.
B. Effluent Treatment System
Koppers is in the process of closing its wastewater treatment
lagoons and is installing an aboveground effluent treatment system. The
effluent treatment system will handle condensate exiting the condenser and
the scrubber water used to treat the working tank vapors. These effluents
are initially fed into one of two 28,000-gallon naphthalene recovery
tanks, which are kept at about 100°F. The naphthalene (mp = 176°F)
contained in the effluent crystallizes and falls to the bottom of the
tanks where it is heated to melting and drained off the tank bottom. The
recovered naphthalene is returned to the working tanks for reuse. The
aqueous fraction of the effluent from the naphthalene recovery system is
sent to one of two 150,000-gallon effluent holding tanks. The effluent is
then sent to an activated sludge tank for biological removal of other
dissolved organics. From there it is pumped to an oil/water separator
that currently serves as a holding basin. After testing for phenol and
other organic compounds, the effluent is sent to a 7 acre spray irrigation
field. A soon-to-be-constructed city sewer line will be the ultimate
disposal route for the effluent in the holding basin.
V. Odor Sources
The three predominant sources of odor (and potential air toxics)
identified at the Koppers facility are:
1. Treated wood exiting the retorts;
2. Steam jet injectors; and
3. Blow-back vapors from work tanks.
-------
200-1
150-
UJ
DC
ts
DC
Q_
100-
Creosote
Out
Rueping
Process
50-
Wood In
Creosote In
o>
CO
o
lo
> .E
I
4
I I I I I
6 8 10 12 14 1
Time (hrs)
Boultonizing
V
Creosote
In
^ I I I
6 18 20 22 24
/Wood
X Out
Figure 2.
Creosote Out
Pressure fluctuations in the retort during the treatment cycle at
Koppers1 Salem, Virginia wood treatment plant.
-------
Visible emissions were observed from a charge that had been pulled out
14 hours prior to our visit and was being unloaded into another railcar.
During the visit, a freshly treated charge was pulled from the center
retort. As the retort door opened, a dense, white plume of gas exited the
treatment chamber and continued to be emitted as the charge was being
pulled from the retort. The charge, approximately 130 feet long, fumed
and emitted a white vapor cloud and a strong creosote odor. There was a
noticeable odor of creosote coming from the stock yard where the treated
ties are stored.
The steam jet injectors used to produce the vacuum in the retorts
are also a source of odors. To induce the vaccum on the retorts Koppers
uses two stream jet injectors. A 4-inch steam jet is used to draw the
system pressure down to between 22 and 24 inches of mercury. This usually
takes between 1 and 2 hours. Ideally, once the vacuum has been obtained,
the operator will switch over to a 2-inch steam jet to maintain the vacuum
for the remainder of the cycle to save energy. However, during periods of
high steam demand there may not be enough steam available from the power
plant's boiler to maintain a 24 inch of mercury vacuum using the 2-inch
steam jet. Therefore, the 4-inch steam jet may remain on the entire
vacuum cycle if the steam demand for the rest of the plant is high (i.e.,
heat for retorts, working tanks, buildings, etc.). The single pass water
cooled condenser, operating between the retort and the steam jet, may not
be capable of removing all of the organics, which become entrained in the
steam jet. A large, dense steam plume was emitted from the 4-inch
Injector, and a strong creosote odor was noted when the wind shifted. The
2-inch injector emitted significantly less visible emissions than did the
4-inch injector.
Working losses from the four creosote working tanks could be a
significant contributor to the odor problem. A working tank blow back
event occurs when the creosote is sent back to the work tanks. The air
displaced by the filling of the work tanks is at equilibrium with the
preservative in the tanks. The 30,000 gallons of preservative used to
fill a retort will displace approximately 4,000 cubic feet of air when the
solution is sent back to the work tanks. This event will occur twice
during the Koppers treatment cycle. It takes approximately 15 minutes to
empty the retort of preservative. The work tanks are equipped with a
common scrubber consisting of a horizontally mounted 20,000-gallon tank
half full of water with a spray system inside. When a blow back occurs
the displaced vapors from the work tanks enter the top of the scrubber and
contact the spray. The exhaust gas is then vented to the atmosphere. Its
effectiveness as a scrubber would be expected to approach zero if the
water is not changed periodically and allowed to reach saturation. At
that point it could only serve as a condenser. We did not witness a blow
back event during our visit. Currently the plant has no formal procedures
in place for periodically changing or regenerating the scrubber water.
The plant manager stated that no procedures are in place because the
scrubber has been very effective at controlling blowback odors. He states
that monitoring the water level alone has maintained the effectiveness of
-------
the scrubber. If it becomes necessary to change the water or empty the
scrubber, the water will be sent to the effluent treatment system.
Attachment
-------
Attachment
Cross ties loaded on railcars and awaiting treatment.
Unloading of a treated charge.
-------
Attachment
Initial opening of the retort door.
Lowering of the rail bridge.
-------
Attachment
10
Vapors escaping from opened retort.
Preparing to pull the charge.
-------
Attachment
11
Charge being pulled from retort,
Charge being pulled from retort,
-------
Attachment
12
View of 4-inch steam injector plume.
View of four creosote working tanks and scrubber
used to control blow back vapors.
-------
MIDWEST RESEARCH INSTITUTE
Suite 350
401 Harrison Oaks Boulevard
Gary, North Carolina 27513
Telephone (919) 467-5215
Facsimile (919) 467-8060
Date: September 22, 1988
Subject: Site Visit—Jennison-Wright Corp., Toledo, Ohio
Wood Treatment Operations: Engineering Evaluation
EPA Contract 68-02-4379, Work Assignment Nos. 13 and 25
MRI Project 8950-13 and 8952-25
From: C. Vaught
To: Bruce Moore
Industrial Studies Branch
U. S. Environmental Protection Agency
Research Triangle Park, N.C. 27711
I. Purpose
To gain an understanding of the treatment process and practices
employed by Jennison-Wright and identify potential sources of odor.
II. Place and Date
Jennison-Wright Corp.
2332 Broadway
Toledo, Oho 43609
(419) 382-3411
September 7, 1988
III. Attendees
Jennison-Wright
Don Wynn, Plant Manager
David Zook, Assistant Plant Manager
U. S. Environmental Protection Agency (EPA)
Bruce Moore
Midwest Research Institute (MRI)
Chuck Vaught
Department of Public Utilities, Environmental Services
Jeff Twaddle
-------
IV. Process Description
The Jennison-Wright facility, located in Toledo, Ohio, is a wood
preserving plant that treats air dried cross ties and floor block
material. In the tie treating operation, approximately 430 ties are
treated per charge with between two and three charges treated per day.
The plant has been in operation since 1905 and operates 20 hours per day,
5 days per week. A process flow diagram for the Jennison-Wright wood
treatment process is presented in Figure 1.
A. Wood Treatment Process
The Jennison-Wright plant operates three treatment cylinders or
retorts, each 6 feet in diameter. Cylinders 1 and 2 (see Figure 1) are
about 80 years old and are used to treat floor blocks. Each are a
100 feet long. The floor blocks are loaded into cages and rolled into the
cylinders on railcars. The creosote solution is introduced into the
cylinders from a dedicated working tank. The treatment cycle is short
(about 2 hours) and is designed only to coat the outside of the blocks
with preservative.
The focus on our visit was to characterize the treatment process and
odor control techniques associated with cylinder 3, a new, 120-foot-long
cylinder installed in 1987 to treat railroad ties. The new cylinder was
installed to replace an old, worn out cylinder. The purpose of the
installation was to improve production schedules and quality so the
facility can function in a more cost-effective, environmentally acceptable
manner and, thus, enhance the company's competitive position. Because
cylinder 3 is a new source, the State of Ohio Environmental Protection
Agency required Jennison-Wright to file a permit to assure compliance with
current State air quality requirements (permit attached). The permit
specifies that all new sources must employ best available technology (BAT)
for control of air emissions.
Jennison-Wright treats railroad ties to varying preservative
retention specifications. Ties treated for Jennison-Wright stock are
treated to a retention level between 4 and 5 pounds of preservative per
cubic foot. The Grand Truck railroad specifies product retention of
7 pounds per cubic foot, and the Norfolk and Southern railroad requires
retention of 8 pounds per cubic foot and sterilization of the ties in the
treatment cycle. The process used to treat ties for the Norfolk and
Southern railroad was observed during our visit. Jennison-Wright
considers annual production information to be confidential.
Approximately 430 ties (1,148 3 of wood) are treated per charge in
cylinder 3 using the Reuping process, which compresses the air in interior
wood cells and forces preservative into the wood. The charge is rolled
into the retorts on 14 small rail cars each of which holds approximately
30 ties. After the charge is loaded and the door is closed, the retort is
filled with about 17,000 gallons of a 60/40 creosote/coal tar mixture from
one of three, 50,000-gallon working tanks.
-------
t
w
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A
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t
r r
w w
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A A
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Creosote/Coal Tar I"
Creosote/Coal Tar (r
X
^
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L
1
-------
After the retort is filled, the contents are heated to 205°F and the
pressure in the retort is raised to about 30 psig for approximately
4 hours. The initial pressure requirement is a function of how readily
the charge accepts the creosote and obtains its target retention of 7 to
8 pounds of preservative per cubic foot of wood. By holding the
temperture of the ties at 205°F for 4 hours, the ties are sterilized to
prevent decay that destroys the wood from within. Following the
sterilization cycle, the pressure is stepped up approximately 10 psig
every 15 minutes until the pressure in the retort reaches 200 psig. The
pressure (200 psig) is maintained until the target preservative retention
level is reached. Again, the rate of increase in system pressure is
dependent on the type of wood being treated and how readily the wood cells
accept the creosote.
When the target retention level is reached, the pressure is
relieved, and the retort is emptied of preservative. A moderate pressure
of about 10 psig is maintained in the retort to aid the pump in
transferring the creosote back to the work tanks. The expanding air in
the interior wood cells expels the preservative leaving an empty, treated
cell. A vacuum (25 inches of mercury) is then applied for 1 hour to
extract residual creosote that tends to drip from the charge, thus
producing a cleaner product and allowing the recovery and recycle of
excess preservative. A diagram depicting the pressure fluctuations during
a treatment cycle is shown in Figure 2.
Following the vacuum cycle, 17,000 gallons of water are pumped into
the retort to quench the treated ties, lower their temperature, and reduce
fugitive emissions of lower boiling point organics typically associated
with odor. The quench water is recirculated in a closed loop system
through a 500,000-gallon fixed-roof tank that is half full of water. Blow
back vapors generated from the displacement of air in the work tanks are
introduced into the vapor space in the tank.
A cone-shaped water scrubber is mounted on top of the tank. The
diameters of the scrubber at the top and bottom are approximately 5 feet
and 15 inches, respectively, and it is approximately 6 feet in height. A
manifold encircles the scrubber midway up the cone and supplies eight
spray nozzles inside the scrubber with water (24 gallons per minute) taken
from inside the tank. The spray scrubs and condenses vapors and carries
the condensate back down into the tank. We observed the scrubber system
in operation during a blow back of creosote to the work tanks. No visible
emissions were observed from the scrubber during the blow back. We were
not in a position to detect whether there were odors coming from the
scrubber.
For the purposes of our visit and to illustrate the effectiveness of
the water quench system, Jennison-Wright personnel opened the retort door
and allowed us to view the charge in the retort after the pressure cycle
(before the vacuum was applied) and after the vacuum cycle (before the
water quench cycle). Following the pressure cycle, a white vapor cloud
exited the retort as the door was opened. Along the end of the charge,
excess preservative and expanding air could be seen exiting the hot ties.
-------
200—1
150 —
UJ
cc
•s; 100 —
uj
cc
CL
50 —
Sterilization
0-
5-
^ o>
^» ™~^
|| 16H
• 20-
Wood In
Creosote In
Creosote
~1 Out
I
2
I I
4 6
Time (hrs)
I
8
25—•
Figure 2.
Wood Out
I
10
Pressure fluctuations in the retort during the treatment cycle at
Jennison-Wright's Toledo, Ohio wood treatment plant.
-------
The ties appeared wet with preservative as excess preservative dripped and
fumed from the charge. After the vacuum cycle was completed, the door was
once again opened. The charge still appeared hot, and a white plume of
vapor exited the retort although not as profusely as was observed before
the vacuum cycle. The charge appeared dry with little or no excess
preservative dripping from the charge. After the water quench cycle the
treated charge was removed. The ties appeared to be substantially cooler,
and almost no visible emissions were observed. We did not detect a strong
odor of creosote from the freshly treated charge.
Attachment
-------
Attachment
State of Ohio Environmental Protection Agency
P.O. Box 1049.1800 WaterMark Dr.
Columbus, Ohio 43266-0149
Richard F. Celeste
Governor
June 22, 1988
Re: Modification to Permit to
Install No. 04-394
Lucas County
Jennison-Wright Corp.
Thomas Kmiec, P.E.
30195 Chagrin Blvd., 220E
Pepper Pike, Ohio 44124
Dear Sir:
CERTIFIED MAIL
Enclosed please find a modification to the Ohio EPA Permit
Install referenced above which will modify the terms and
conditions.
to
You are hereby notified that this action of the Director is final
and may be appealed to the Environmental Board of Review pursuant
to Section 3745.04 of the Ohio Revised Code. The appeal must be
in writing and set forth the action complained of and the grounds
upon which the appeal is based. It must be filed with the
Environmental Board of Review within thirty (30) days after notice
of the Director's action. A copy of the appeal must be served on
the Director of the Ohio Environmental Protection Agency and the
Environmental Law Division of the Office of the Attorney General
within three (3) days of filing with the Board. An appeal may be
filed with the Environmental Board of Review at the following
address: Environmental Board of Review, 236 East Town Street,
Room 300, Columbus, Ohio 43215.
Very truly yours,
Thomas G. Rigo, anager
Field Operations Section
Division of Air Pollution Control
Enclosure
cc: US EPA
Toledo Environmental Services Division
Kathleen Shannon
-------
Issuance Date; June 22, 1988
Effective Date: June 22, 1988
OHIO ENVIRONMENTAL PROTECTION AGENCY
MODIFICATION TO PERMIT TO INSTALL NO. 04-394
Name of Applicant: Jennison-Wright Corp.
Address: 30195 Chagrin Blvd., 220E
City: Pepper Pike, Ohio 44124
Telephone: (216) 464-6740
The Ohio EPA has issued a modification for the Ohio EPA Permit to
Install referenced above.
The Permit to Install issued to Jennison-Wright Corp. (PTI No.
04-394) is hereby modified in the following manner: Special terms
and conditions.
The reason for this modification is: NSPS was not included in the
initial PTI.
The above named entity is hereby granted a modification to the
permit to install described above pursuant to Chapter 3745-31 of
the Ohio Administrative Code. Issuance of this modification does
not constitute expressed or implied approval or agreement that, if
constructed or modified in accordance with the plans included in
the application, in compliance with applicable State and Federal
laws and regulations, and does not constitute expressed or implied
assurance that if constructed or modified in accordance with those
plans included in the application, the above described source(s)
of pollutants will be granted the necessary operating permits.
Ohio Environmental Protection Agency
Director
-------
JENNISON-WRIGHT CORP
APPLICATION NO 04-394
PAGE 2
APRIL 10, 1987
Substantial construction for installation must take place within
eighteen months of the effective date of this permit. This
deadline may be extended by up to twelve months, if application is
made to the Director within a reasonable time before the
termination date and the party shows good cause for any such
extension.
The Director of the Ohio Environmental Protection Agency, or his
authorized representatives, may enter upon the premises of the
above-named applicant during construction and operation at any
reasonable time for the purpose of making inspections, conducting
tests, examining records or reports pertaining to the
construction, modification or installation of the above described
source of environmental pollutants.
As specified in OAC Rule 3745-31-05, a.^
Compliance with the terms and
conditions of this permit will fulfill this requirement.
The specified permit fee must be remitted within 15 days of the
effective date of this permit to install.
The proposed source shall be constructed in strict accordance with
the plans and application submitted for this permit to the
Director of the Ohio Environmental Protection Agency. There may
be no deviation from the approved plans without the express,
written approval of the Agency. Any deviations from the approved
plans or the above conditions may lead to such sanctions and
penalties as provided under Ohio law. Approval of these plans
does not constitute an assurance that the proposed facilities will
operate in compliance with all Ohio laws and regulations.
Additional facilities shall be installed upon orders of the Ohio
Environmental Protection Agency if the proposed sources are
inadequate or cannot meet applicable standards.
EMISSION SUMMARY
The air contaminant sources listed below comprise the Permit to
Install for Jennison-Wright Corp. located in Lucas County. The
sources listed below shall not exceed the emission limits/control
requirements contained in the following table:
Allowable Emissions
Ohio EPA Source BAT Applicable (Ib/hr, Ib/MMBTU,
Source No. Identification Determination Ohio EPA rule qr/DSCF,etc. )
T008 Work tank fl BAT for this 3745-31-05 No V.E.
source is NSPS Subpart
being vented Kb
thru storage
tank A (T010) &
not to exceed
210°F
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JENNISON-WRIGHT CORP
APPLICATION NO 04-394
PAGE 3
APRIL 10, 1987
Ohio EPA
Source No.
T009
T010
Source
Identification
Work tank #2
Storage tank A
Allowable Emissions
BAT Applicable (Ib/hr, Ib/MMBTU,
Determination Ohio EPA rule gr/DSCF,etc.)
Same as T008 Same as T008 Same as T008
Same as T008
BAT for this
source is a
vapor recovery
system which
reduces emission
such that there
are no visible
emissions other
than water vapor
& all gauging
is gas tight
SUMMARY
TOTAL NEW SOURCE EMISSIONS
Same as T008 except
water vapor
Pollutant
Creosote/Particulate
Tons/Year
1.70
This condition in no way limits the applicability of any other
state or federal regulation.
APPLICABILITY
This Permit to Install is applicable only to the air contaminant
sources listed and does not include the installation or
modification of wastewater disposal systems or solid waste
disposal facilities. Separate application must be made to the
Director for the installation or modification of any such
wastewater disposal systems or solid waste disposal facilities.
NSPS REQUIREMENTS
The following sources are subject to the applicable provisions of
the New Source Performance Standards (NSPS) as promulgated by the
United States Environmental Protection Agency/ 40 CFR Part 60.
Source No.
T008
T009
T010
Source Description
Work Tank II
Work Tank 12
Storage Tank A
NSPS Regulation (Subpart)
Subpart Kb
Subpart Kb
Subpart Kb
The application and enforcement of these standards are delegated
to the Ohio EPA. The requirements of 40 CFR Part 60 are also
federally enforceable.
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JENNISON-WRIGHT CORP
APPLICATION NO 04-394
PAGE 4
APRIL 10, 1987
Pursuant to the NSPS, the source owner/operator is hereby advised
of the requirement to report the following at the appropriate
times:
1. Construction date (no later than 30 days after such
date);
2. Anticipated start-up date (not more than 60 days or less
than 30 prior to such date);
3. Actual start-up date (within 15 days after such date);
and
4. Date of performance testing (at least 30 days prior to
testing).
Reports are to be sent to:
Ohio Environmental Protection Agency
Authorization and Compliance Unit
P.O. Box 1049
Columbus, Ohio 43266-0149
and Toledo Environmental Services Division
26 Main Street
Toledo, Ohio 43605
WASTE DISPOSAL
The owner/operator shall comply with any applicable state and
federal requirements governing the storage, treatment, transport,
and disposal of any waste material generated by the operation of
the sources.
REPORTING
Any reports required by the Permit to Install shall be submitted
to Toledo Environmental Services Division.
PERMIT TO OPERATE APPLICATION
A Permit to Operate Application and a $15 application fee must be
submitted to the appropriate field office for each source in this
Permit to Install. In accordance with OAC rule 3745-35-02, the
application shall be made at least ninety days prior to start-up
of the source.
PUBLIC DISCLOSURE
The facility is hereby notified that this permit, and all agency
records concerning the operation of this permitted source are
subject to public disclosure in accordance with OAC Rule
3745-49-03.
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JENNISON-WRIGHT COR?
APPLICATION NO 04-394
PAGE 5
APRIL 10, 1987
MALFUNCTION/ABATEMENT
This source and its associated air pollution control system(s)
shall be maintained regularly in accordance with good engineering
practices and the recommendations of the respective manufacturers
in order to minimize air contaminant emissions.
In accordance with OAC Rule 3745-15-06, any malfunction of the
source(s) or associated air pollution control system(s) shall be
reported immediately to the Toledo Environmental Services
Division. Except as provided by OAC Rule 3745-15-06(A)(3),
scheduled maintenance of air pollution control equipment, that
requires the shutdown or bypassing of said equipment, must be
accompanied by the shutdown of the associated air pollution
sources.
ADDITIONAL SPECIAL TERMS AND CONDITIONS
1» The Permittee shall conduct performance tests to demonstrate
that the air contaminant source operates or within 90 days of
start-up of operation will operate in compliance with the
requirements of this Permit to Install and with applicable
Ohio Environmental Protection Agency laws and rules. The
first such test shall be conducted within 15 days of start-up
of operation. A minimum of 48 hours written notice of each
test shall be given to the Toledo Environmental Services
Division.
2. Tank T008, T009, and T010 shall be equipped with a device to
determine the temperature of the stored creosote.
3. The Permittee shall remove from service two of the present
work tanks within 90 days after T008 and T009 are operational.
4. The owner/operator shall keep readily accessible records
showing the dimension of the storage vessels (T008, T009 and
T010) and an analysis showing the capacity of each vessel.
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TECHNICAL REPORT DATA
reaa instructions on me reverse oetore comaicnnei
REPORT NO.
EPA 450/3-89-028
j. RECIPIENT'S ACCESSION NO.
ti. TITLE AND SUBTITLE
Evaluation of Emission Sources From Creosote Wood
Treatment Operations
5. REPORT DATE
June 1989
.5. PERFORMING ORGANIZATION CODE
7 AuTHOR(S)
Vaught, C. C., Nicholson, R. L.
8. PERFORMING ORGANIZATION REPORT NO.
9. PERFORMING ORGANIZATION NAME ANO AOORESS
Midwest Research Institute
401 Harrison Oaks Boulevard, Suite 350
Gary, North Carolina 27513
I 10. PROGRAM ELEMENT NO.
I
,11. CONTRACT/GRANT NO.
i 68-02-4379
12. SPONSORING AGENCY NAME ANO AOORESS
U. S. Environmental Protection Agency
Control Technology Center
Researcn Triangle Park, N.C. 27711
i 13. TYPE OF REPORT ANO PERIOD COVERED
I Final
H4. SPONSORING AGENCY CODE
I
EPA 200/04
15. SUPPLEMENTARY NOTES
16. ABSTRACT
This document discusses each of the preservatives and the processes used to
treat a variety of wood products concentrating on the use of creosote for the
treatment of crossties. Of particular concern are the emission sources associated
with the release of odor and air toxics and the technologies currently in use to
control them.
7.
KEY WORDS ANO DOCUMENT ANALYSIS
DESCRIPTORS
b.IDENTIFIERS/OPEN ENDED TERMS C. COSATI Held/Group
Wood treatment
vJood preserving
Creosote
Pentachlorophenol
Air pollution control
:13. DISTRIBUTION STATEMENl
Release unlimited
. 19. SECURITY CLASS IThis Report i
: Unclassified
: _ i. NO. Or rf
! 87
20. SECURITY CLASS i This sage i
•• Unclassified
:2. PRICE
Form 2220-1 (R«». 4-77) DEVIOUS EDITION is OBSOLETE
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