From:
Billy
Martin
[
mailto:
wpwmm@
huber.
com]
Sent:
Wednesday,
September
17,
2003
3:
55
PM
To:
kphanks@
rti.
org
Cc:
KISSELL.
MARY@
epamail.
epa.
gov
Subject:
Re:
Continuous
presses
Attachments:
Katie
Hanks
Questionnaire.
doc,
EmissionTestResults.
jpg,
EmissionTestResults2.
jpg,
EmissionTestResults3.
bmp,
EmissionTestResults4.
jpg,
EmissionTestResults5.
jpg
Ms.
Hanks,

I
apologize
for
the
late
reply,
but
I
do
hope
you
got
my
earlier
messages.
Attached
please
find
the
requested
information
in
your
note.
I
took
the
liberty
to
repeat
your
requests
onto
a
separate
document
and
provided
the
information
below
each
request.

Also
attached
are
the
relevant
documents
that
provide
some
insight
to
the
HAP
data
you
requested.
I
had
to
scan
the
pages
and
they
are
in
a
jpeg.
format.

I
hope
this
information
meets
your
needs.
Should
you
have
additional
questions,
please
don't
hesitate
to
contact
me.

Respectfully,

Billy
Billy
M.
Martin
Director,
Environmental
Affairs
Huber
Engineered
Woods
423­
775­
8820
423­
775­
8821
(
fax)
wpwmm@
huber.
com
>>>
"
Hanks,
Katie
P."
<
kphanks@
rti.
org>
08/
22/
03
12:
06PM
>>>

Mr.
Martin,

My
company
is
the
contractor
assisting
the
U.
S.
EPA
with
development
of
the
plywood
and
composite
wood
products
(
PCWP)
national
emission
standards
for
hazardous
air
pollutants
(
NESHAP).
We
received
your
comments
on
the
proposed
NESHAP
and
we
are
in
the
process
of
evaluating
the
maximum
acheivable
control
technology
(
MACT)
options
for
continuous
PCWP
presses.

In
order
to
look
at
the
MACT
options,
we
have
been
reviewing
the
information
you
submitted
and
we
are
gathering
additional
information
(
as
needed)
on
the
types
of
enclosures
used
on
continuous
presses.
We
have
a
few
questions
regarding
the
continuous
press
used
by
J.
M.
Huber
in
Spring
City,
TN.

First,
can
you
describe
the
enclosure
(
if
any)
or
emissions
capture
method
used
for
the
Spring
City
press?
Has
actual
capture
efficiency
been
determined
for
the
press?
Is
there
a
press
preheater,
and
if
so,
are
emissions
from
the
preheater
routed
to
RTO
system?
More
importantly,
can
you
tell
us
what
test
method
was
used
to
collect
the
VOC
emissions
data
presented
in
Attachment
I
of
your
comments?
We
would
also
be
interested
in
any
HAP
emissions
data
that
are
available.
Please
call
me
if
you
would
like
to
discuss.
Thank
you.

Katie
Hanks
RTI
International
3040
Cornwallis
Road
Research
Triangle
Park,
NC
27709
(
919)
316­
3732
(
919)
541­
7155
(
fax)
kphanks@
rti.
org
1.
Describe
the
enclosure
(
if
any)
or
emissions
capture
method
used
for
the
Spring
City
press?

The
original
design
for
emissions
capture
for
the
continuous
press
in
TN
(
constructed
in
1996­
97)
included
the
manufacturer
(
Siempelkamp)
recommended
direct
exhaust
points
located
at
the
in­
feed,
out­
feed
and
heat
tunnel
to
the
press.

The
continuous
press
was
enclosed
within
a
building
with
a
separation
wall
between
the
finish
and
handling
line,
forming
line
and
warehouse
and
the
press
control
room,
thermal
oil
pump
room,
and
hydraulic
room
walls.

The
total
exhaust
volume
originally
recommended
by
Siempelkamp
for
capture
and
control
from
the
continuous
press
was
approximately
35,000
acfm.
We
utilized
the
Siempelkamp
recommended
extraction
points
and
ducted
the
exhaust
gases
to
our
dryer
pollution
control
system
which
included
a
common
pressure
equalization
chamber,
followed
by
wet
electrostatic
precipitators,
followed
by
an
RTO.
The
design
of
the
dryer
APC
systems
was
such
that
the
35,000
acfm
from
the
continuous
press
could
be
accommodated.

This
proved
to
be
inadequate
in
practice.
To
improve
capture
we
added
additional
single
point
capture
hoods
at
each
frame
of
the
press
where
decompression
of
the
board
took
place,
which
were
manifolded
to
a
common
duct
and
taken
to
a
new
RTO
sized
at
65,000
scfm.
This
RTO
was
in
addition
to,
not
in
place
of
the
dryer
RTO
and
was
dedicated
solely
to
control
of
press
decompression
emissions.
The
new
side
capture
hoods
ran
from
the
outfeed
of
the
press
at
frame
57
to
about
frame
28
along
each
side
of
the
press.
This
area
is
the
primary
emission
point
for
decompression
gases.
This
approach
was
intended
to
capture
emissions
as
quickly
as
possible
during
board
decompression
along
the
press.

Additional
pick­
up
points/
hoods
were
added
at
the
screen
return
roll
at
the
press
out­
feed
and
in­
feed.
Therefore,
the
system
was
now
such
that
the
emissions
from
the
press
in­
feed
and
pre­
heater
were
directed
to
the
dryer
APC
system
and
the
emissions
emanating
from
the
press
out­
feed,
heat
tunnel,
screen
return
and
frame
capture
hoods
were
directed
to
the
new
RTO.

Since
that
time,
there
has
been
an
additional
separation
wall
added
at
the
mid­
point
of
the
press
building
to
assist
in
concentrating
and
improving
capture
at
the
press
out­
feed.

2.
Has
actual
capture
efficiency
been
determined
for
the
press?
There
have
been
no
tests
conducted
to
determine
capture
efficiency
for
the
press.

3.
Is
there
a
press
pre­
heater,
and
if
so,
are
emissions
from
the
pre­
heater
routed
to
RTO
system?

Yes,
there
is
a
press
pre­
heater
and
these
emissions
are
captured
by
a
series
of
suspended
collection
hoods
over
the
pre­
heater,
and
are
routed
to
the
dryer
APC
system.

4.
What
test
method
was
used
to
collect
the
VOC
emissions
data
presented
in
Attachment
I
of
your
comments?

VOC
area
grab
sampling
was
conducted
both
by
FID
(
direct­
reading
flame
ionization
detector)
and
Summa
canister.
The
FID
sampling
was
conducted
at
the
frame
points
as
listed
in
Attachment
I.

The
Summa
canister
sampling
occurred
at
Frame
50,
location
D
and
the
north
end
of
the
mezzanine
(
press
out­
feed
area).
These
samples
were
analyzed
in
accordance
with
EPA
Method
TO­
14.

5.
HAP
emissions
data
that
are
available.

We
have
results
of
an
investigative
emissions
test
for
THC
and
speciated
VOCs
conducted
at
the
inlet
only
to
the
press
RTO
and
the
inlet
duct
where
the
press
in­
feed
emissions
are
conveyed
to
the
dryer
wasp/
RTO
system.
These
tests
were
not
conducted
using
NCASI
Method
CI/
WP­
98.01,
Chilled
Impinger
Method
for
Use
at
Wood
Products
Mills
to
Measure
Formaldehyde,
Methanol,
and
Phenol;
therefore,
we
do
not
have
a
high
degree
of
confidence
in
the
results.
A
copy
of
the
emission
tables
and
corresponding
test
methodology
accompanies
this
response.
