From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]
Sent:
Monday,
July
28,
2003
11:
00
AM
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Subject:
Lumber
Kilns
in
Proposed
PCWP
MACT
­
Request
for
Clarification
of
Comments
Dear
Stakeholders:

EPA
is
seeking
clarification
on
comments
received
on
whether
all
lumber
kilns
should
be
part
of
the
plywood
and
composite
wood
products
(
PCWP)
MACT
source
category.
Since
several
comments
were
received
and
opinions
were
varied,
we
are
requesting
that
the
stakeholders
participate
in
a
conference
call
on
Wednesday,
August
6,
from
1:
00
to
2:
00
EDST.
If
you
have
materials
you
wish
to
share
with
meeting
participants,
please
send
them
to
everyone
on
this
e­
mail.
All
materials
and
minutes
from
the
meeting
will
be
put
in
the
docket
and
will
be
available
to
the
public.

The
call­
in
conference
line
number
is
(
919)
541­
1595.
EPA
must
initiate
the
call,
so
if
you
don't
get
through,
please
wait
a
minute
and
try
again.

If
you
have
any
questions,
please
do
not
hesitate
to
call
me
at
(
919)
541­
4516.

The
following
WWPI
members
submitted
a
public
comment
on
lumber
kilns.
We
do
not
have
contact
information
for
these
individuals.
If
one
of
you
has
contact
information
for
them,
please
forward
this
message
to
them.
Thank
you.

Bill
Crossman,
Atlantic
Wood
Industries
John
Ferlin,
President,
Brooks
Manufacturing
Company
Michael
Lodgeon,
Fontana
Wood
Preserving,
Inc.
Don
DeVries,
Thunderbolt
Wood
Treating
Company,
Inc.
Morgan
Wright,
Wood
Preservers,
Inc.

Background:
On
January
9,
2003,
the
U.
S.
Environmental
Protection
Agency
(
EPA)
published
the
proposed
Plywood
and
Composite
Wood
Products
(
PCWP)
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP)
in
the
Federal
Register.
We
noted
in
the
proposal
preamble
that
some
wood
products
industry
representatives
requested
that
all
lumber
kilns
(
regardless
of
location)
be
considered
under
the
PCWP
rulemaking
so
there
would
be
one
maximum
achievable
control
technology
(
MACT)
determination
for
all
lumber
kilns
nationwide.
We
proposed
to
include
all
lumber
kilns
in
the
PCWP
source
category
because
the
design
and
operation
of
lumber
kilns
are
essentially
the
same
regardless
of
whether
the
kilns
are
located
at
a
sawmill
or
are
colocated
with
PCWP
or
other
types
of
manufacturing
operations.
We
thought
that
broadening
the
scope
of
the
PCWP
source
category
to
include
lumber
kilns
located
at
any
type
of
facility
was
reasonable
because,
based
on
our
information,
there
are
no
currently
applicable
controls
for
lumber
kilns,
and
because
it
is
more
efficient
to
include
lumber
kilns
in
the
MACT
process
now
than
to
address
them
in
a
separate
rulemaking
(
should
kiln­
dried
lumber
manufacturing
be
listed
as
a
major
source
category
under
section
112(
c)
of
the
Clean
Air
Act
in
the
future).

During
the
public
comment
period
following
the
January
9
proposal,
we
received
comments
from
operators
of
lumber
kilns
and
wood
products
industry
representatives
opposing
the
inclusion
of
kilns
that
are
not
co­
located
with
a
PCWP
facility
in
the
PCWP
NESHAP.
The
commenters
were
concerned
about
potential
monitoring,
recordkeeping,
and
reporting
requirements
and
the
caseby
case
MACT
("
MACT
Hammer")
provisions.

Mary
Tom
Kissell.
P.
E.
U.
S.
EPA,
Office
of
Air
Quality,
Planning,
and
Standards
(
919)
541­
4516
