From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]
Sent:
Monday,
August
25,
2003
2:
40
PM
To:
Chad
Darby
SECOR
Email
Subject:
Re:
Plywood
MACT:
Production
Based
Limits
The
proposed
rule
requires
that
the
production­
based
compliance
option
be
met
before
controls.
You
cannot
use
control
devices
to
meet
the
production­
based
compliance
option.
We
received
comment
on
this
issue
and
EPA
may
change
the
requirements
for
the
final
rule;
however,
my
recommendation
to
EPA
management
is
to
include
the
proposed
requirements
in
the
final
rule
wihout
change.
The
final
rule
will
be
signed
in
February
2004.

You
can
use
emissions
averaging
with
a
biofilter
to
achieve
the
required
reduction.
(
You
cannot
use
emissions
averaging
with
the
production­
based
compliance
option.)

Chad
Darby
SECOR
Email
To:
Mary
Kissell/
RTP/
USEPA/
US@
EPA
<
cdarby@
secor.
com>
cc:
Subject:
Plywood
MACT:
Production
Based
Limits
08/
21/
03
07:
42
PM
Mary
Tom,
Could
you
please
clarify
a
few
points
for
me?

1.
If
a
facility
wishes
to
comply
with
production
based
limitations
for
the
Plywood
MACT,
can
they
do
so
by
installing
controls
that
do
not
necessarily
meet
the
control
requirements
of
the
standard?

The
reason
I
ask
is
that
I
am
interested
in
the
possible
use
of
biofiltration
at
a
facility,
but
am
concerned
that
it
may
not
meet
90%
overall
control
efficiency.
However,
if
it
were
to
meet
70%
efficiency,
then
the
production
based
limits
of
the
dryer
could
be
met.

2.
In
the
example
above,
if
a
dryer
is
to
be
controlled
by
biofiltration
and
it
turns
out
to
be
only
85%
efficient.
Can
the
facility
calculate
the
amount
of
emissions
resulting
from
the
5%
of
control
efficiency
that
the
device
falls
short
of
and
offset
this
with
emissions
averaging
for
another
source.

Example.
A
dryer
has
100
tons
of
total
HAPs
emissions
with
a
biofiltration
system
that
is
only
85%
efficient.
If
the
control
device
were
90%
efficient
overall
(
as
is
required
by
the
standard)
then
5
more
tons
of
HAPs
would
have
been
destroyed.
Since
the
biofilter
cannot
be
improved,
can
the
facility
control
5
tons
of
press
vent
HAPs?

Thanks
for
your
help
on
this.
I
look
eagerly
toward
your
comments.

Chad
Darby
Senior
Engineer,
M.
S.
M.
E.
SECOR
International
Incorporated
7730
SW
Mohawk
St
Tualatin,
OR
97062
Ph.
(
503)
691­
2030
Fax
(
503)
692­
7074
cdarby@
secor.
com
