oEPA
                 United States
                 Environmental Protection
                 Agency
             Office of
             Solid Waste and
             Emergency Response
DIRECTIVE NUMBERr 9445.05(85)

TITLE:  Analytical Methods to Determine the Presence of
      Creosote and Its Toxic Characteristics
APPROVAL DATE:

EFFECTIVE DATE:
                               i-is-ss
                 ORIGINATING OFFICE: office of solid waste

                 I? FINAL
                 D DRAFT

                   STATUS:
             [  ]  A- Pending OMB approval
             f  J  B- Pending AA-OSWER approval
             [  3  C- For review i/or content
             f]  D- In development or circulating
REFERENCE (other documents):
                                             headquarters
  OSWER       OSWER       OSWER
VE    DIRECTIVE   DIRECTIVE    Dl

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PART 261  APPENDICES                                           DOC: 9445.05(85)


Key Words:      Creosote, Analytical Methods

Regulations:    40 CFR Part 261

Subject:        Analytical Methods to Determine the Presence of Creosote
                and Its Toxic Characteristics

Addressee:      Don B. Howard, C-K Associates, Inc., Baton Rouge, Louisiana

Originator:     Agnes M. Ortiz, 'Chemical Engineer, Office of Solid Waste

Date:           1-18-85

Summary:

     Creosote is present in K001 and U051.  K001 refers to the wastes from wood
preserving processes that use creosote and/or pentchlorophenol.  U051 refers to
creosote as a commercial chemical product which is only considered hazardous
waste if discarded or intended to be discarded.  Essentially, U051 is not
present unless raw creosote is discarded.

     Creosote is an extremely complex mixture of many compounds, and there is
no single analytical method that can detect its presence.  Recent information
indicates that the procedure outlined in the footnote associated with creosote
in 40 CFR Part 261, Appendix III, is not a reliable'method to detect creosote.

     Since EPA is primarily concerned with the toxic compounds that are present
in creosote, EPA recommends that the owner or operator analyze for the toxic
compounds identified as being present in K001 in 40 CFR Part 261, Appendix VIII.
Analytical methods for these compounds are provided on Appendix III of 40 CFR,
Part 261.

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                                            tm i s
 Mr.  Don  B.  Howard
 C-K  Associates,  Inc
 11848  South Harrell's  Perry  Road
 Suite  A
 Baton  Rouge,  Louisiana   70816

 Dear Mr.  Howardt

     This letter is  in response to your  November 6,  1984,  re-
 quest  for an  analytical  method  to  determine  the  presence of
 creosote.  Alan  Corson referred your  letter  to me, because I have
 been working  with creosote regulations.   In  order  to properly
 reply  to your letter,  I  feel that  some clarification is  necessary.

     K001 refers to  wastes from wood  preserving  processes  that
 use  creosote  and/or  pentachlorophenol, which I presume is  the
 case that you described.  U051  refers to creosote  as a commercial
 chemical  product which is only  considered as a hazardous waste  if
 discarded or  Intended  to  be  discarded.   In other words,  you will
 not  have  4051 unless raw  creosote  is  discarded.

     As  you may  know,  creosote  is  an  extremely complex mixture  of
 many compounds.  The concentration distribution  of  these compounds
 varies depending both  on  reaction  conditions and  on  the  source  of
 coal used.   Unfortunately, we  are  aware  of  no single analytical
 method with which to determine  creosote  presence.  Recent  in-
 formation indicates  that following the procedure outlined  in the
 footnote  associated  with  creosote  on  Appendix III, is not  a
 reliable indicator of  the presence of creosote.   EPA is  presently
 working  on  a  proposed  rule to  amend the  hazardous  waste, regulations
 concerning  creosote.

     However, we  are not  concerned with  creosote per se  but
 rather,  the toxic compounds  that are  present in  creosote.  I  .
 therefore,  recommend you  analyze  for  the toxic compounds identi-  ,
 fied as  being present  in  K001 on Appendix VII.  If any of  these
 are  present at  the facilities  you  are concerned  with, a  potential
 hazard still  exists.   Analytical methods for these compounds are
.provided  on Appendix III of  40  CFR part  261.  Refer  to Test Hethod
 for  Evaluating Solid Waste (SW-846),  Second  Edition; Test  Methods
 8100,  8250, and  8310.

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     I hope these recommendations will be of assistance.. Please
feel free to contact roe again, if you have any questioas at
(202) 475-8990.

                                Sincerely,
                                Agnes M. Ortiz
                                Chemical Engineer
                                Methods Program, WH-562B
cc:  Region VI

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