From:
Hanks,
Katie
P.
Sent:
Tuesday,
September
16,
2003
9:
59
AM
To:
'
Bradfield,
John'
Cc:
Mary
Kissell
(
E­
mail);
Nicholson,
Rebecca
Subject:
RE:
Estimate
of
the
number
of
RTO's
needed
to
comply
with
PCWP
The
rationale
for
how
we
grouped
process
units
for
purposes
of
doing
the
cost
estimates
was
documented
in
the
proposal
BID
in
Chapter
4.
The
BID
states
that:
"
Several
plants
have
multiple
process
units
requiring
controls.
The
flow
rates
for
these
process
units
were
summed
and
divided
across
control
equipment
as
necessary.
In
most
cases,
the
total
dryer
flow
was
assumed
to
be
routed
to
one
or
more
RTO
dedicated
to
controlling
dryer
exhaust,
and
the
total
press
flow
was
assumed
to
be
routed
to
one
or
more
RTO
dedicated
to
controlling
press
exhaust.
Because
RTO
fuel
costs
increase
exponentially
with
gas
flow
rate,
RTO
sizes
were
assumed
to
remain
less
than
about
150,000
dscfm.
(
The
largest
RTO
mentioned
in
the
MACT
survey
responses
was
around
150,000
dscfm.)"

We
did
not
receive
public
comments
on
our
combinations
of
process
units
and
controls.

­­­­­
Original
Message­­­­­
From:
Bradfield,
John
[
mailto:
jbradfield@
cpamail.
org]
Sent:
Monday,
September
15,
2003
5:
01
PM
To:
Hanks,
Katie
P.
Cc:
Kissell.
Mary@
epamail.
epa.
gov;
Hunt
Tim
(
Hunt,
Tim)
Subject:
RE:
Estimate
of
the
number
of
RTO's
needed
to
comply
with
PCWP
Katie,

A
follow
up
question
came
up
regarding
the
RTO#
estimate
you
developed
for
the
compliance
extension
issue.
Any
feedback
you
could
provide
would
be
appreciated.
See
the
attached
memo.

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
­­­­­
Original
Message­­­­­
From:
Kissell.
Mary@
epamail.
epa.
gov
[
mailto:
Kissell.
Mary@
epamail.
epa.
gov]
Sent:
Friday,
September
05,
2003
2:
41
PM
To:
Bradfield,
John
Subject:
Estimate
of
the
number
of
RTO's
needed
to
comply
with
the
PCWP
ru
le
as
proposed
John,
FYI.
Mary
Tom
­­­­­
Forwarded
by
Mary
Kissell/
RTP/
USEPA/
US
on
09/
05/
03
02:
49
PM
­­­­­

"
Hanks,
Katie
P."
<
kphanks@
rti.
org>
To:
Mary
Kissell/
RTP/
USEPA/
US@
EPA
cc:
Mike
Thrift/
DC/
USEPA/
US@
EPA,
09/
05/
03
02:
22
PM
"
Nicholson,
Rebecca"
<
rlnicholson@
rti.
org>
Subject:
Estimate
of
the
number
of
RTO's
needed
to
comply
with
the
PCWP
ru
le
as
proposed
I
went
back
into
our
mill­
by­
mill
cost
analyses
for
the
proposal
and
counted
the
number
of
RTO's
we
estimated
would
be
needed
to
comply
with
the
proposed
PCWP
rule.
The
mill­
by­
mill
analyses
reflected
the
population
of
PCWP
facilities,
process
units,
and
APCD
as
of
April
2000.
The
proposal
cost
analyses
assumed
that
each
process
unit
(
or
groups
of
process
units
at
a
facility
with
total
exhaust
flow
of
less
than
or
equal
to
150,000
dscfm)
in
need
of
MACT
control
would
be
controlled
with
an
RTO.
I
counted
205
RTO's
(
excluding
those
MACT
APCD
already
in
place
as
of
April
2000).
We
did
not
account
for
use
of
other
MACT
APCD
such
as
RCO,
biofilters,
of
incineration
in
an
onsite
combustion
unit.
We
also
did
not
account
for
use
of
emissions
averaging
or
the
production­
based
emission
limits.
Thus,
205
is
a
worst­
case
estimate
of
the
number
of
RTO
needed
as
of
April
2000.
Since
April
2000,
the
number
of
RTO's
needed
has
been
reduced
by
34
because
of
facilities
installing
APCD
and
plant
closures.
Thus,
the
worst­
case
number
of
RTO
that
would
be
installed
to
meet
the
PCWP
standards
(
as
proposed)
would
be
171.

John
Bradfield
of
the
Composite
Panel
Association
is
very
interested
in
this
information,
so
you
may
want
to
forward
this
email
to
him
at
jbradfield@
cpamail.
org
Katie
Hanks
RTI
International
3040
Cornwallis
Road
Research
Triangle
Park,
NC
27709
(
919)
316­
3732
(
919)
541­
7155
(
fax)
kphanks@
rti.
org
TO:
Katie
Hanks,
RTI
CC:
Mary
Tom
Kissell,
EPA
FROM:
John
Bradfield,
Director
of
Environmental
Affairs
DATE:
September
15,
2003
SUBJECT:
RTO
Estimates
Thanks
for
all
your
work
on
coming
up
with
an
estimate
of
the
number
of
RTO's
that
may
be
needed
for
the
PCWP
MACT.
In
the
email
Mary
Tom
passed
along
to
me,
you
indicated
that
171
was
probably
a
conservative
(
high)
estimate.
In
further
discussion,
two
items
you
mentioned
in
the
email
about
assumptions
lead
several
of
us
in
the
Wood
Products
Environmental
Task
Group
to
think
that
it
is
not
that
conservative
an
estimate.
However,
I
want
to
be
sure
we
understand
your
assumptions
correctly.

You
mentioned
combining
process
units.
Some
can
be
combined
and
some
can
not,
particularly
certain
press
and
dryer
units.
Did
you
assume
all
press
and
dryer
units
could
be
combined
up
to
a
total
exhaust
flow
of
less
than
or
equal
to
150,000
dscfm?
If
you
could
confirm
this
was
your
assumption,
we'd
appreciate
it.
Also,
150,000
dscfm
is
on
the
large
side
of
things
relative
to
an
RTO.
For
all
the
arcane
reasons
that
start
with
the
fact
that
no
two
plants
are
alike,
many
plants
may
not
be
able
to
install
big
units.
Even
if
big
units
are
feasible
they
may
not
be
operationally
desirable.

If
we
understand
your
estimate
correctly,
the
171
number
might
be
on
the
low
end
and
250­
300
would
be
a
better
high
end
estimate.
Again,
the
basic
assumption
for
this
exercise
is
that
RTO
is
the
compliance
mechanism
of
choice,
disregarding
alternatives
that
may
or
may
not
be
available.

Again,
thanks
for
any
further
feedback
you
can
provide
on
your
assumptions.
