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:
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ORIGINATING OFFICE: office of solid waste
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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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