[p2tech] Creosote replacement

Robert,

I recently had conversations with an IU rep currently building a new
crosstie treating facility here in the state.  It was my understanding
from him creosote IS the industry standard as it's cheap, effective,
long lasting, is relatively immobile once treated into the wood and
re-uses a waste from the iron & steel sector.  And, there's not that
many crosstie treating facilities left in the country.

If you're also helping them figure out BMP,
http://edocket.access.gpo.gov/cfr_2003/julqtr/pdf/40cfr430.03.pdf , CFR
430.03(c) provides a template from which to build an analogous timber
processing one from.

As far as discharge of wastewater from your facility
http://www.access.gpo.gov/nara/cfr/waisidx_03/40cfr429_03.htmlk, CFR
429.70 "Applicability; description of the wood preserving-water borne or
nonpressure subcategory"; CFR 429.80 "Applicability; description of the
wood preserving--steam subcategory or CFR 429.90 "Applicability;
description of the wood preserving--Boulton subcategory" are the three
preserving practices EPA promulgated standards for.

If your client is a new source (construction of facility began after
1/81) and thinks he's going to discharge to navigable waters of the U.S.
or to a city's sewage collection system, he'll see most of the EPA regs'
NSPS and PSNS say "no discharge".

E-mail back with any questions or comments about the regulatory side.
Sorry for no idea on creosote replacement.

Allen Gilliam
ADEQ State Pretreatment Coordinator



 
-----Original Message-----
From: p2tech-bounces at great-lakes.net
[mailto:p2tech-bounces at great-lakes.net] On Behalf Of Henry, Robert
Sent: Wednesday, October 21, 2009 9:45 AM
To: p2tech at mailman.great-lakes.net
Subject: [p2tech] Creosote replacement


I am working with a manufacturer of railroad ties. They currently use
creosote distilled from coal tar in a pressure treatment system. Are
there any environmentally friendly replacements for creosote? Can anyone
point me towards some studies showing replacements that work as well as
creosote? I have spent a few days searching and have not found anything
note worthy. I did notice a discussion on CR4 about cedar oil, but there
were not any valid references provided.
Thank you, 
Robert Henry 
Environmental Engineer 
IDEM, Office of Pollution Prevention and Technical Assistance 
Phone: 317-232-8188 
email: RHenry at idem.IN.gov 



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