From:
Bradfield,
John
[
mailto:
jbradfield@
cpamail.
org]

Sent:
Wednesday,
July
30,
2003
3:
00
PM
To:
KISSELL
MARY
TOM
(
KISSELL,
MARY
TOM)

Cc:
Hunt
Tim
(
Hunt,
Tim);
Hanks,
Katie
P.;
Harvey,
Dave
(
E­
mail)'

Subject:
EPA
Work
Practices
Questions
Dear
Mary
Tom,

Attached
is
the
response
from
our
group
to
your
questions
on
work
practices
that
you
asked
earlier.
Don't
hesitate
to
call
if
anything
is
unclear.

<<
EPA
Work
Practices
Questions.
doc>>

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
TO:
Mary
Tom
Kissell,
EPA
FROM:
John
Bradfield,
Director
of
Environmental
Affairs
DATE:
July
30,
2003
SUBJECT:
EPA
Work
Practices
Questions
Prior
to
meeting
with
AF&
PA
in
June
EPA
developed
a
list
of
questions
about
industry
comments
and
other
issues
that
had
arisen.
Two
of
the
questions
you
posed
were
regarding
work
practices
to
assure
the
capture
of
air
streams
from
rotary
dryers
and
hardboard
bake
ovens.
The
AF&
PA
Wood
Products
Environmental
Issues
Task
Group
discussed
this
issue
after
our
recent
conference
call
with
you
and
we
have
a
suggestion.
To
provide
some
background,
the
negative
air
systems
used
by
these
units
use
are
critical
to
their
operation
and
would
prevent
any
emission
leakage.
In
the
case
of
dryers,
loss
of
that
negative
pressure
creates
a
fire
hazard
and
would
interrupt
material
flow.
In
the
case
of
bake
ovens,
a
loss
would
lead
to
quality
problems.
Consequently,
there
is
plenty
of
incentive
to
assure
these
units
maintain
negative
pressure
and
the
incentive
has
nothing
to
do
with
emission
control.
Nonetheless,
we
understand
that
you
may
need
to
address
these
pieces
of
equipment
in
some
way.

Our
suggestion
would
be
to
explain
in
the
preamble,
that,
due
to
other
operational
requirements,
it
is
unlikely
that
rotary
dryers
or
hardboard
bake
ovens
would
lose
their
negative
pressure
operating
parameters.
If
they
did,
it
would
be
a
clear
production
problem
that
would
be
given
immediate
attention.
Consequently,
no
work
practice
requirements
are
necessary.
We
strongly
feel
that
this
would
be
a
sufficient
response
to
any
questions
on
this
matter.

Please
don't
hesitate
to
call
if
you
have
further
questions
on
this
subject.

CC:
Tim
Hunt,
AF&
PA
