Follow-up questions on Treated Wood Council's analytical data and supplemental comments from 

November and December, 2013 

The following questions are being asked to evaluate whether the sampling and analytical approach 

used by TWC presents results that are comparable to data EPA has collected for comparisons with 

traditional fuels: 

_1. __ Wood sampling- please provide details on t he 8 samples of wood. Are these all aged samples 

of commercially available treated wood? If not, please explain how these were obtained, noting 

especially whether they were obtained from commercially available wood products and represent a 

fresh or aged sample. 

Creosote Non·Tie Treated Wood (TW)- 40-50 year old pole material, origin<~ ll y and currently 

commerciaJ.!y-available. 

Creosote with DOT Borate TW- aged tie material. originally and currently commerciallyavailable. 

Pentachlorophenol TW- aged utility pole, originally and currently commercially-available. 

Copper Naphthenate TW- 3 year old treated, originally and currently commercially-available 

Copper Naphthenate with Borate TW- newly treated tie, commercially-available 

Borate TW- 5 year old structural lumber, originally and currently commercially-available 

Copper-based, watc'rbome TW- aged decking material, originally and currently commerciallyavailable. 

Org<~n c-based, waterborne TW- newly treated decking material, commercially-available. 

± 

_2. __ _ Wood moisture content - for comparisons to data on a dry basis, should we assume a 20%. 

moisture content for the laboratory data provided by TWC? Your assumption is OK. and represents a 

rough estimate of the mean of all samples. Our laboratory did not dry the material as this could cause 

a loss of some volatile HAPS prior to analysis. 

~ 

_3. __ _ Anion data- Cl, F, N, and S: These data were prepared using an aqueous leach method and 

apparently do not represent a total value as presented in EPA's November 2011 tables. In your 

December 2013 supplement, you compare them directly with the total values, but it is unclear whether 

this is an appropriate comparison. How would you recommend using the data provided by this test for 

comparing to totals for traditional fuels? Do you propose another method to make the TWC laboratory 

data more comparable to EPA's November 2011 tables or have any supplemental data available that 

could help ensure an appropriate comparison? Weathered ~nd freshly treated wood (lumber) 

samples submitted for analysis in 2013 were analyzed for water-leachable onions including chloride, 

fluoride, nitrate, nitrite and sulfate, mther than for total levels of chlorine, fluorine, nitrogen and sulfur. 

It is not possible to correlate one value to the other. 

However, certilln observa tion~ and calculations can be made to help determine the levels of 

tot<ll chlorine, fluorine, nitrogen and sulfur. 

First, there is no fluorine in the active or inert ingredients of ilny of the wood preservative 

chemistries in the TWC Petition. Any measurements detected in the 2013 analysis would have been 

[ Formatted: No bullets or numbering 

[ Formatted: No bullets or numbering 

[ Formatted: Indent: First Une: 0.5" 
n<1tural amounts in the wood before tre<~tm nt. EPA dat~ show 0-128 mgLkg of fiuorine in untreated 

wood. 

Second, we can further add that there is no chlonne, nitrogen or sulfur in the active or mert 

rngredients in the borate, creosote, co~:mer naQhthenate (CuNaQ}, creosotcLboragte or CuN;"~(2Lborate 

treated wood in the TWC Petition. 

Third: there is no nitrogen or sulfur in the active or inert ingredients in (lentachlorouhenol 

treated wood in the TWC Petition. The chlonne in the uentachloroQhenol is accounted for in the 

anal~s s for (lentachloro(lhenol. 

Fourth, there ma~ be chloline, nitrogen or sulfur in the fuel oil carrier in the oil-borne treated 

wood {creosote, COf2!JCr na(2hthenate, (2entachloro(2henol or dual treated}. Since we are comQ<uing 

these treated woods to fuel oil, the amounts in the treated wood would lwa~s be less than the 

amounts in the whole fuel oil. 

Fifth, the onl~ two chcmi~tries that might contain chlorine, nitrogen or sulfur are coeecr-bascd 

waterborne treated wood (ACQI (nitros::en} and organic waterbonl\! treated wood (El2} {chlorine, 

nitrogen <1nd sulfur} {Table 2 in the Dec. 4, 2013 Su(!f2lemen!al Comments}. We ~<:~ n estimate the 

maximum Cl, Nand S content in ACQ and El2 treated wood by using the AWPA stand<Hd retentions and 

the chemical structure of the active ingredients and esscntral formulants containrng Cl, Nor S, as 

~ummarized m the table below. These values re12resent just the amount added durmg the origmal wood 

treatment and do not io1Ciude estimates of com(2onents naturally occurring in iLrmber, nor do we 

auem12t to estimate losses over time due to weathering. 

The table also gives" com12arison to total chlorine, fluorine, nitrogen and sulfur ranges found In wood 

and biomass fuels as Qublished b~ US EPA in "Contaminant Concentrations in Traditional Fuels: Tables for 

ComQarison." November 29, 2011. These data were orisinall~ Qublishcd by USEPA OAQPS rn docket 

numbers EPA-HQ-OAR-2002-9958-3255 and EPA-HQ-OAR-2003-0119-2484. 

Non-HAP Com!Jonents rn ACQ- and El2-TrPated Wood vs. Untreated Wood 

Concentration range, !lQI1l Chlorine Fluorine Nitrogen Sulfur 

Wood and Biomass NO- NO- 2200- NDMaterials' 54QQ 128 4@1 6100 

ACQ-D: content from .. - 150 ·-

awves' - -

ACQ-0: conteoH from iner1 - 5260 - - ·- solvent' -

ACQ-0: total contribution - -

-- - 5410 --

-

EL2: content from DCOI' ill .. 

- Z2 22 

H2: content from 1.6 -

-- 3.3 ---
~~njoac•opr1d 

EL2: t01al co•Hrehul•on ill - 32 §§ 

~lti!!Cd wood andJ>iomass, including bark, bagasse, hog fuel and agncuhural [! ~nt residues 1 66.7% CuD+ 33.3% OldCC:ildrme h~lammonlum brcarbonateLcarbonate, or ··ooAs~·· (Cu. ,~N· HCOdmd ' 2·Aminoethanol or' MEA" (C1!:!?NOJ 

• ti,S·D•chloro·2·N oovl·4:)mthiazohn·3-cnt' or ·ocOt" (Cu!:i.,Q.NOSI; 981(, of El2 formulation. 

~(6·Chloro·3..::Qyt~dmyl}rnl'thyi)·N·n•tro 2·111lld_a1ohdmlmllle (C ~!::il .. CIN,D~); 2o/o of EL2 formulat•on 

Exilm(llc: 

tn ACO·D trcilted wood th~ AWPA minim!,Jm retention for UC4A exQosure {ground contact} is 0.40 

lbs£ft ·. ACQ·D contams 66.7% CuO and 33.3% DDABC, w1th ethilnolamine {MEAl formulant added ilt 

2.75 x CuO. DDABC contams 3.61% Nand MEA contains 22.94% N Thus, 

Fronl_Df-!i~.QC· 0.;]9 lb; ~O.:Q. x 0.333 lb ~ OD!?-JK x ft1 wood -

X 0.0361 1!! N X tO" = 150 [/ROI N 

-- - ft ~··':'.2 9L. - lbACQ·D 321bs lb ODABC 

from M[A. QA? lbs ACQ·O x 0 61J7 IDS CuD x l. 75 lbs MEA x ft 1 woo:1 X 0.2194 l!.l N x 10' = 5260 j21JIT1 N 

It wood lbACQ·D illCUO p ~~~ lb MFA 

Thus, the total n1trogcn added to wood freshly-treated with ACQ-D commercial formula lions is 

estimated to be 5410 QQm, mostly from the re ive!~ volatile amine solvent. Weilthered wood burned 

for fuel value will have a fracuon of this ilmount. 

~ 

The following questions are being asked to evaluate whether the preservative types that were 

sampled and analyzed are representative surrogates for the entire category of wood preservative: 

1. Preservative solution· Are there differences in the preservative solution (inactive and active 

ingredients, ) that was used on the wood that was sampled and analyzed, and other preservative/wood 

combinations within the same category, that might affect the contaminants present in the treated 

wood ? t:!.Q_If so, please explain generally, without revealing any confidential business information, if 

possible. 

. [ Formatted: No bullets 0< numbering