From:
Louis
Wagner
[
mailto:
lwagner@
voyager.
net]

Sent:
Wednesday,
August
27,
2003
12:
01
PM
To:
Katie
Hanks
Subject:
Re:
Fiberboard
Coatings
in
the
PCWP
NESHAP
As
promised:

­­­­­
Original
Message
­­­­­

From:
Louis
Wagner
To:
Hunt,
Timothy
;
Jim
Rabe
;
Allison
Casey
;
Paul
Vasquez
Cc:
John
Bradfield
Sent:
Friday,
May
30,
2003
1:
15
PM
Subject:
Fiberboard
Coatings
in
the
PCWP
NESHAP
In
answer
to
EPA's
question
about
including
fiberboard
asphalt
coating
operations
in
the
PCWP,
please
suggest
to
them
that
the
following
wording
be
added
to
the
end
of
the
definition
of
Miscellaneous
Coating
Operations
in
section
63.2292
of
the
rule:

Miscellaneous
coating
operations
also
include
the
application
of
coatings
to
fiberboard
and
cellulosic
ceiling
tiles
that
occurs
at
the
same
site
as
fiberboard
manufacture.

This
paragraph
is
consistent
with
the
wording
and
intent
of
the
final
NESHAP
for
Wood
Building
Products
­
Surface
Coating.
See
FR
Vol.
68.
No.
102.
pps.
31746­
31788
or
more
specifically
page
31748.

EPA
staff
who
worked
with
the
Surface
Coating
NESHAP
have
already
recognized
that
the
asphalt
for
some
product
lines
and
coatings
used
to
convert
fiberboard
to
ceiling
tile
are
applied
as
part
of
the
product
manufacture
and
are
virtually
HAP
free.

If
you
intend
to
mention
this
issue
during
the
June
4,
2003
meeting
with
EPA,
I
am
sure
that
either
Jim
Rabe,
Allison
Casey
or
Paul
Vasquez
would
be
happy
to
make
the
presentation
as
manufacturers
of
these
products.
Otherwise,
feel
free
to
present
them
with
this
email.

Louis
Wagner
Director
of
Technical
Services
American
Fiberboard
Association
