From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]
Sent:
Friday,
August
01,
2003
10:
52
AM
To:
Bradfield,
John
Cc:
Dail.
Lynn@
epamail.
epa.
gov;
kphanks@
rti.
org;
jwalke@
nrdc.
org;
tim_
hunt@
afandpa.
org
Subject:
RE:
MACT
Definitions
John,

I'm
not
recommending
to
our
management
adding
antifungal
treatments
to
PCWP
and
don't
feel
we
need
any
clarification
on
this
issue.
As
proposed,
only
kiln­
dried
lumber
(
not
all
lumber)
is
considered
to
be
a
PCWP.
Therefore,
application
of
coatings
such
as
antifungals/
moisture
retardants
to
lumber
is
outside
of
the
scope
of
the
PCWP
source
category.

We
reviewed
information
you
submitted
on
the
proposed
wood
building
products
(
surface
coating)
rule
relating
to
application
of
wood
treatments,
fire
retardants,
and
antifungal
coatings
to
PCWP
products.
We
determined
that
these
chemicals
can
be
applied
using
different
techniques
during
different
stages
of
production
(
e.
g.,
during
blending
or
forming
of
the
substrate,
or
after
manufacturing
of
the
substrate
is
complete).
Application
of
wood
treatments,
fire
retardants,
and
antifungal
coatings
to
PCWP
that
occurs
after
the
substrate
manufacturing
process
(
i.
e.,
following
completion
of
hot
pressing)
are
subject
to
the
wood
building
products
(
surface
coating)
rule.
Likewise,
we
determined
that
laminates
(
e.
g.,
foils
and
paper)
applied
to
PCWP
prior
to
pressing
of
the
substrate
would
be
covered
by
the
PCWP
rule,
while
laminates
applied
following
pressing
are
covered
by
the
wood
building
products
(
surface
coating)
rule.
(
see
comment
2.1.2
in
EPA
document
EPA­
453/
R­
03­
003,
Summary
of
Public
Comments
and
Responses
for
the
Wood
Building
Products
(
Surface
Coating)
NESHAP
­
Background
Information
for
Final
Standards).

"
Bradfield,
John"
<
jbradfield@
cpama
To:
"
Hanks,
Katie
P."
<
kphanks@
rti.
org>
il.
org>
cc:
Mary
Kissell/
RTP/
USEPA/
US@
EPA,
"
Otwell
Lawrence
(
Otwell,
Lawrence)"
07/
31/
03
04:
52
PM
<
lpotwell@
gapac.
com>,
"
Otwell
Lawrence
(
home)
(
Otwell,
Lawrence
(
home))"
<
lpotwell@
mindspring.
com>,
"
Vasquez
Paul
(
Vasquez,
Paul)"
<
pjvasque@
gapac.
com>,
"
Hunt
Tim
(
Hunt,
Tim)"
<
tim_
hunt@
afandpa.
org>,
"
George
Ellis
(
E­
mail)"
<
george.
ellis1@
ipaper.
com>,
"
Ferguson,
Phil"
<
phil.
ferguson@
ipaper.
com>,
"
Bigbee
Kurt
(
Bigbee,
Kurt)"
<
Kurt.
Bigbee@
APAWood.
org>,
"
Wagner,
Louis"
<
lwagner@
cpamail.
org>
Subject:
RE:
MACT
Definitions
Katie,

On
our
conference
call
a
couple
of
weeks
ago
we
left
a
number
of
items
on
the
table
to
deal
with
later.
Do
you
have
any
time
in
Mid­
August
to
talk
about
antifungal
treatments?
If
you
have
any
other
definitional
questions
by
that
time
we
can
talk
about
them,
too.

John
Bradfield:
jbradfield@
cpamail.
org
Director
of
Environmental
Affairs
Composite
Panel
Association
18922
Premiere
Court
Gaithersburg,
MD
20879­
1574
USA
301.670.0604
x229
Fax:
301.840.1252
Visit
the
CPA
Web
Site:
http:\\
www.
pbmdf.
com
